Warning Letter – BTS S.p.A. FreeEMG and PocketEMG

Recipient: BTS S.p.A.
Product: FreeEMG and PocketEMG
Date: 5/10/2012

This inspection revealed that these devices are adulterated within the meaning of section 501(h) of the Act, 21 U.S.C. § 351(h), in that the methods used in, or the facilities or controls used for, their manufacture, packing, storage, or installation are not in conformity with the current good manufacturing practice requirements of the Quality System regulation found at Title 21, Code of Federal Regulations (CFR), Part 820. Failure to establish and maintain adequate procedures to control all documents that are required by 21 CFR 820. All obsolete documents shall be promptly removed from all points of use or otherwise prevented from unintended use, as required by 21 CFR 820.40(a). For example: (b)(4) is the software version currently used for the FreeEMG and it is maintained within a folder on your firm’s computer system. However, it was observed that the previous versions of this software were not removed from the same electronic folder, were still marked as released, were still available for use, and were not marked as obsolete. We reviewed your firm’s response and conclude that it is not adequate. In the response to the observation. your firm provided a print screen showing the change so that previous software revisions are marked as obsolete and are made inaccessible. However, evidence that your firm reviewed other files to ensure that obsolete procedures were removed was not provided. Evidence that your firm updated procedures to ensure that obsolete documents were not made available was not provided. Also, your firm did not provide evidence to indicate that a systemic corrective action was considered (e.g., implementing a correction to prevent future occurrences and/or the use of obsolete documents for other products manufactured).

FDA office: CDRH

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 offering: Dec 3, 4, & 5, 2024 – 12:00 pm to 5:00 pm CET

Register Now


 

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.