Your firm failed to establish SOPs describing the handling and retrieval of electronic data. Handling of electronic data includes the security (e.g., audit trails) and statistical analysis of raw data. Specifically, the SOP for handling electronic data should describe a procedure for the archiving of multiple statistical analyses of the clinical pathology raw data with the study records. For Study [redacted], multiple sets of statistical analyses were maintained on the firm’s electronic server, and were not archived appropriately.
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We address this response below, in relation to each of the noted violations. These violations include, but are not limited to, the following: 1. Failure to adequately validate a process whose results cannot be fully verified by subsequent inspection and test, as required by 21 CFR 820.75(a).
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Your supplier, which was used to fill ampoules was disqualified for this service due to quality issues , but was left on your approved suppliers list because the supplier is still approved for other services. The supplier remained on the approved supplier list for all products, and/or services. There is no method for disqualifying suppliers from providing specific products and/or services. The response dated January 7, 2013 cannot be assessed at this time. Your response states that all supplier evaluation and control procedures will be revised to include an appropriate mechanism to ensure suppliers are qualified and disqualified on a product or service-specific basis. These procedures will also be reviewed to assure compliance with the Quality System Regulation . Additionally, you will also electronically prevent the issuance of purchase orders unless a supplier is approved for a specific product or service.
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Failure to establish and maintain adequate procedures for the identification, documentation, validation, or where appropriate, verification, review and approval of design changes before their implementation, as required by 21 CFR 820.30(i). For example: the device design was revised to include an [redacted] for both the ActiveCare DVT and ActiveCare+SFT devices. Your firm’s design validation report No.71365539, Safety Technical Report OVP, includes design verification test results where the device was tested at [redacted] but does not appear to include testing of production units under actual or simulated conditions as indicated in your Design Verification and Validation procedure referenced in your Design Changes Procedure.
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You have failed to validate with a high degree of assurance, a process where the results cannot be fully verified by subsequent inspection and test, (21 CFR 820.75(a)). Specifically: You have not validated the preparation of the [redacted] bonding solution which is used to bond the [redacted] subassembly, a component of the Trima ACCEL disposable set; You have not validated the preparation of the [redacted] which is used to bond the [redacted]subassembly and [redacted] subassembly, components of the Spectra disposable sets.
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Failure to validate the design under defined operating conditions and by using initial production units, lots, batches, or their equivalents, as required by 21 CFR 820.30(g). Your firm failed to perform design validation for the data analysis software used in the Cal Ver EP Evaluator to determine out of specification stability results for Verichem products.
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Your validation procedure describes your acceptance criteria and states [redacted]. However, your validation report does not address [redacted]. In addition, your testing described in your Validation Protocol [redacted] does not account for detection of [redacted]. Your validation data and results should ensure that all your acceptance criteria are met. In addition, your microbiological results provided with your response do not indicate whether the results reflect [redacted].
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Failure to adequately ensure that when the results of a process cannot be fully verified by subsequent inspection and test that the process shall be validated with a high degree of assurance and approved according to established procedure [21 C.F.R. § 820.75(a)]. “Specifically, the procedure “Validation of the Aseptic Filling Process Utilizing the Media Fill Method,”[redacted], states that initial validations should be conducted consecutively and prior to routine production fills and subsequent re-qualifications should be performed [redacted] as appropriate. In addition, the procedure states that routine production may not resume until acceptable qualification or validation runs are achieved or until all appropriate investigations and/or repeat media fills have been performed with acceptable results. However, validation of the aseptic filling process in filling suite [redacted] for [redacted] bottles was inadequate in that the [redacted] re-qualification of the [redacted] Aseptic Filling Process utilizing the Media Fill Method [redacted]performed on March 23, 2009 failed. The failure produced [redacted] contaminated units out of approximately [redacted] units inspected. In addition, the subsequent validation of [redacted] for filling [redacted]and [redacted] bottle [redacted performed on May 20, 2009 also failed.
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Failure to establish and maintain procedures for the identification, documentation, validation or where appropriate verification, review, and approval of design changes before there implementation as required by 21 CFR § 820.30(i). Specifically, your firm’s design change request form and design change review form included with your CSO Design Change procedure (procedure includes no signature and date of approval for implementation and no revision history) does not require validation or verification of design changes before there implementation. Your firm has failed to ensure that after the design requirements are established and approved, changes to the design,
both pre-production and post-production are also validated (or verified where appropriate), and approved before implementation.
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