Failure to Validate Software


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FDA Warning Letter: Inadequate documentation of Validation (ucm531231)

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Your 483 response, dated June 3, 2016, indicates you have begun validating your [redacted] process for all of your juice products and validation will be completed “in the next couple of weeks.” However, as of the date of this letter, you have not provided any documentation of your ongoing validation efforts and/or the results of such process validations.

 

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Warning Letter: Failure to adequately validate software (ucm399011)

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Failure to adequately validate software used as part of production and the quality system for its intended use according to an established protocol, as required by 21 CFR 820.70(i). Specifically, actions were not taken to ensure that computer errors would not result in the loss of dosimetry and run dose data from the Dosimetry Measurement Application (DMA) module of [redacted].

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Warning Letter: Failure to perform validation of device software (ucm402449)

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Failure to perform validation of device software, as required by 21 CFR § 820.30(g). Specifically, your firm failed to validate the software calculator for the STAAR Visian MICL Lens (ICL models MICL 12.1 mm, MICL 12.6 mm, MICL 13.2 mm, MICL 13.7 mm).

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Warning Letter: Failure to validate software (ucm399525)

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Failure to validate computer software for its intended use according to an established protocol when computers or automated data processing systems are used as part of production or the quality system, as required by 21 CFR 820.70(i). For example, your firm’s [redacted] Software Operating System used to log, evaluate, and investigate complaints, incoming, in process, and finished non-conformances was not validated to prevent deletions of records by employees.

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Warning Letter: Failure to validate computer software (ucm399523)

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Failure to validate computer software for its intended use according to an established protocol when computers or automated data processing systems are used as part of production or the quality system, as required by 21 CFR 820.70(i).

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Warning Letter: Failure to validate computer software (ucm399519)

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Failure to validate computer software for its intended use according to an established protocol when computers or automated data processing systems are used as part of production or the quality system, as required by 21 CFR 820.70(i). For example, during the inspection your firm confirmed that its software program [redacted] version [redacted] released on August 28, 2009, for documenting condom production control tests has not been validated for its intended uses.

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Warning Letter: Medical device company failed to validate computer software (ucm 355751)

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Failure to ensure that all inspection, measuring, and test equipment, including mechanical, automated, or electronic inspection and test equipment, is suitable for its intended purposes and is capable of producing valid results, as required by 21 CFR 820.72(a). For example, your firm’s design verification procedure does not require that test equipment and software are fully validated, as needed, and prior to use in design verification activities.

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Warning Letter: Hospital stretcher manufacturer failed to validate computer software (ucm 355751)

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Failure to validate computer software for its intended use according to an established protocol when computers or automated data processing systems are used as part of production or the quality system, as required by 21 CFR 820.70(i). Specifically, [redacted], developed by [redacted], is used to transfer and make changes to drawings used to manufacture devices. There is no protocol or documentation demonstrating that this software has been validated for its intended use.

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Warning letter: Failure to validate (ucm337808)

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Failure to validate computer software for its intended use according to an established protocol when computers or automated data processing systems are used as part of production or the quality system, as required by 21 CFR 820.70(i). For example, your firm uses custom automatic machines in the needle production process. Your firm stated that it performed software validation for the automatic machines and that the software protocol was tested, but these validation activities were not documented.

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Warning Letter: Failure to validate computer software (ucm340155)

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Failure to validate computer software for its intended use according to an established protocol when computers or automated data processing systems are used as part of production or the quality system, as required by 21 CFR 820.70(i). For example: There is no evidence that validation was completed for the [redacted] software used by your firm to provide the customer with the graphic representation of the flow rate of the device. [redacted], indicated that your firm did not have user requirements, input, or output requirements for the [redacted] software.

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