FDA Warning Letter- Not Conforming to Manufacturing Requirements

WARNING LETTER

Criticare Technologies, Inc was issued a warning letter from the FDA. Excerpts from a warning letter of interest to software professionals:

CMS# 686915

Criticare Technologies, Inc.

6901 TPC Drive, Suite 300OrlandoFL 32822United States

July 12, 2024

Inspection Dates: March 21, 2024, through May 10, 2024

Inspection Issue(s):

These violations include, but are not limited to, the following:

  • Your firm has not adequately performed a design verification for your nGenuity device to confirm that the design output meets design input requirements, as required by 21 CFR 820.30(f). Specifically, the SpO2 accuracy specifications, in a document dated 2006, are defined as (b)(4) for the range of (b)(4) and (b)(4) for the range of (b)(4). Two Pulse (b)(4) Reports from 2000 and 2001 were provided during the inspection to support the above accuracy claims. However, these reports do not support the claims made for the (b)(4). For example, the reports did not include acceptance criteria, a rationale for the sample size of (b)(4) participants, and traceability for the devices reviewed. Your firm has been relying on older design documents for your nGenuity device yet have not performed a sufficient design review to confirm the current design has been verified.
  • Your firm has not adequately conducted design validation for your nGenuity devices as required by 21 CFR 820.30(g). Specifically, the 8100E Series (b)(4) provided during the inspection did not include acceptance criteria and did not document a rationale for the sample size of (b)(4) collecting (b)(4) on (b)(4) participants. Your firm has been relying on older design documents for your nGenuity device yet have not performed a sufficient design review to confirm the current device design has been validated.

Finally, you should know that this letter is not intended to be an all-inclusive list of the violations at your firm’s facility. It is your firm’s responsibility to ensure compliance with applicable laws and regulations administered by FDA. The specific violations noted in this letter and in the Inspectional Observations, FDA 483, issued at the close of the inspection may be symptomatic of serious problems in your firm’s manufacturing and quality management systems. Your firm should investigate and determine the causes of any violations and take prompt actions to address any violations and bring the products into compliance.

About the author

Allison joined SoftwareCPR in 2022, bringing along over ten years of passion for building teamwork and growth in organizations. This is established in part by the greatest University the South has to offer- Mississippi State.

SoftwareCPR Training Courses:

Being Agile & Yet Compliant (Public)

Our SoftwareCPR unique approach to incorporating agile and lean engineering to your medical device software process training course is now open for registration!

  • Agile principles that align well with medical
  • Backlog management
  • Agile risk management
  • Incremental and iterative software development lifecycle management
  •  Frequent release management
  • And more!

3 days virtual (Zoom) with group exercises, quizzes, examples, Q&A.

Lead Instructor: Mike Russell

Next public offerings:

  • Americas: 11-13 February 2025
  • EU/Eastern Europe/Middle East/Africa/Atlantic/eastern South America: 18-20 February 2025
  • Southern Central Northeastern Pacific: 24-26 February 2025
Register using form at this link:     Agile Course Post Promo

 

IEC 62304 and other emerging standards for Medical Device and HealthIT Software

Our flagship course for preparing regulatory, quality, engineering, operations, and others for the activities and documentation expected for IEC 62304 conformance and for FDA expectations. The goal is to educate on the intent and purpose so that the participants are able to make informed decisions in the future.  Focus is not simply what the standard says, but what is meant and discuss examples and approaches one might implement to comply.  Special deep discount pricing available to FDA attendees and other regulators.

3-days onsite with group exercises, quizzes, examples, Q&A.

Instructor: Brian Pate

Next public offering:  TBD

Call or email now to schedule a private, in-house class. The fall schedule is filling up!

Email training@softwarecpr.com to request a special pre-registration discount.  Limited number of pre-registration coupons.

Registration Link:

TBD

 


 

Medical Device Cybersecurity (Public or Private)

This course takes a deep dive into the US FDA expectations for cybersecurity activities in the product development process with central focus on the cybersecurity risk analysis process. Overall approach will be tied to relevant standards and FDA guidance documentation. The course will follow the ISO 14971:2019 framework for overall structure but utilize IEC 62304, IEC 81001-5-1, and AAMI TIR57 for specific details regarding cybersecurity planning, risk characterization, threat modeling, and control strategies.

2-days onsite with group exercises, quizzes, examples, Q&A.

Instructor: Dr Peter Rech, 2nd instructor (optional)

Next public offering:  TBD

Corporate Office

15148 Springview St.
Tampa, FL 33624
USA
+1-781-721-2921
Partners located in the US (CA, FL, MA, MN, TX) and Canada.