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warningletter

Software Warning Letters

Failure to validate computer software for its intended use according to an established protocol, as required by 21 CFR 820.70( i). For example, the firm did not validate software for electronic records and electronic signatures. Your written responses dated Feb. 25, April 3, and April 13,2000, stated that you would formalize the policy regarding electronic...
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.Failure to maintain device master records (DMR’s) for each type of device including or referring to the location of device specifications, including appropriate drawings, composition, formulation, component specifications, and software specifications, as required by 21 CFR 820.181(a) . For example:.
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You have also failed to establish written procedures for all operations being performed by your blood bank. No written procedures are established for registering donors electronically, registering donors manually on your mobile unit, maintaining your donor base and searching for duplicate and/or unsuitable donors on a set schedule, review of donor suitability records to assure...
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Limberg Eye Center 4/17/00 Failure to maintain complete and accurate records [21 CFR 812.140(a)]. Information on some of the case report forms (CRFS) did not agree with the computerized subject records and vice versa for those records that were originally captured on the CRF and then transcribed to the computerized source records. Moreover, UCVA readings...
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Harper Hospital Blood Bank 4/13/00 Failure to perform/maintain computer validation [21 CFR 211.68] in that: there was no validation protocol to show how the system was tested and what were the expected outcomes; there was no documentation to identify the operator performing each significant step, date completed, whether expected outcomes were met, and management review;...
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Euclid Systems – contacts 4/12/00 The devices are adulterated within the meaning of Section 501(h) of the Act, in that the methods “used in, or the facilities or controls used in the manufacture, processing, packaging, storage, or distribution of Orthokeratology (itaflurofocon B), toric, and aspheric contact lenses, are not in conformance with the Quality System...
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Exmoor advised in its response that professional auditor training will be provided and that subsequent in-house training will be conducted and documented for key staff with auditing responsibilities. Furthermore, training needs will not only be assessed during appraisal and counseling sessions, but also during Quality Management Review Meetings, external audits, internal audits and corrective actions....
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Electric Mobility – Scooters and power chairs 4/3/00 “…Your firm did not validate your _____ computer system which is used for quality control data, order entry and inventory functions. [21 CFR 820.70(i)” SoftwareCPR keywords: production software validation
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St. Joseph’s Hospital and Medical Center Blood Bank 3/16/00″…6. Inadequate computer security in that employees have access to functions they are not qualified to perform. For example, Technical Assistants (TA) have access to the Blood Order Processing function, Blood Label Check function and Blood Product Testing function, although they are not qualified to perform the...
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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, the _____ used to ____ in _____, has not been validated, to assure it is...
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Thoratec Laboratories 3/10/00″..4. .The implementation of corrective and preventative action (CAPA) procedures at your firm is incomplete in that your procedures do not include reference to the Access electronic database. This database captures information from sources such as complaints and nonconformance reports for use during management reviews. In addition, battery assembly defects, such as loose...
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Individual Monitoring Systems -Electroencephalogry 2/11/00 “…Failure to validate computer software for its intended use. For example, your firm has not validated the software used to perform sensitivity calibration of the ActiTrac device. “ SoftwareCPR keywords: production software validation.
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http://www.fda.gov/foi/warning_letters/m3401n.pdf
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Compnay: SOL PharmaceuticalsProduct: Active pharmaceutical ingredients Poduct Category: Human Drugs Date: 1/21/200 In addition, our investigative team found it impossible to trace computer generated …because they were not date stamped.
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Diasorin, Saluggia Italy 23-Dec-99 production/QC software validation for reagents”8. Failure to ensure that all equipment used in the manufacturing process meets specified requirements and is appropriately designed, constructed, placed, and installed to facilitate maintenance, adjustment, cleaning, and use [21 CFR 820.70(g)] in that the Gamma Counter Data Transfer Validation, dated March 31. 1999. did not...
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7. Failure to maintain complete and adequate written SOPS that reflect current bloodbank operations as requiredby21 CFR 606.100(b) and 606.60. For example, with respect to the computer system in use, there were no SOPS available for security procedures for unauthorized access, review of the system and correction of errors, and control of changes in hardware...
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3d) Standard operating procedure Routine Release of Crossmatched Blood and Blood Products has not been updated to include computter operations utilizing xxx Blood Bank and Blood Donor Computer System versionyyyy. Specifically, the procedure does not include what type of second verification of information entered into the computer should be performed when blood products are released...
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Failure to validate the EtO sterilization process for ATI plasma exchange tubing setsand off-the-shelf software for compiling clinical trial data. Also there are no procedures established and maintained for monitoring and controlling the process parameters for the ATI plasma exchange tubing sets to ensure that specified requirements are met as required by 21 CFR 820.75....
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Mountain View Blood Bank 10/5/99 The _____ Procedure, Revision Date 10-26-94, required donors who test repeatedly reactive for HTLV- 1/2, HIV, HBsAg and HCV to be permanent y deferred and the donors notified. Employees lacked adequate training because they were not following this procedure [21 CFR 606.20(b)]. The donor deferral files were not adequate to...
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Failure to review and evaluate all complaints and maintain a record of the reason no investigation was made and the name of the individual responsible for the decision not to investigate; failure to maintain records that demonstrate that each batch, lot, or unit of device meets in-process or finished device specifications; failure to validate and...
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6. Failure of the DMR (device master record) to include device specifications including appropriate drawings, composition, formulation, component specifications and software specifications, as required by 21 CFR 820.181(a). For example:
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CRS-USA LASIK 8/18/99 Clinical Trial Software Validation There was no verification that the data submitted by the clinical investigators matched source data at the site. The only data verification was performed by the computer data service, xxxx and involved scrutinizing the data for such errors as out-of-range data, field entry omissions, exam dates out-of-range, and...
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South Florida Blood Bank 8/12/99 The inspection revealed that complete and accurate donor deferral records are not being maintained. A deferred donor that tested repeatedly reactive HBsAg on February 12, 1998 (Unit #2251435) was improperly re-entered for donation on August 12, 1998 without a neutralization test being performed. This donor should have remained in deferral....
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Drager Medizintechnik GmbH, 6-Aug-99, Intensive care ventilators, anesthesia and incubators 1. Failure to validate computer software used as part of the quality system for its intended use according to an established protocol as required by 21 CFR 820.70(i). For example, the data in the Excel spreadsheet identified as a “Hit List” of top nonconforming components...
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Vitalograph Ltd., 6-Aug-99, Spirometers and peak flow meters 4. Failure to establish and maintain process control procedures for the monitoring and control of process parameters during production, as required by 21 CFR 820.70(a) and (b). For example, the firm failed to measure the temperature of the wave-soldering machine at the start of every PCB Kit...
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Linweld 8/2/99 Significant deviations include, but may not be limited to the following: Failure to maintain a computer system with validated program capabilities for operating a medical gas facility [21 CFR 1-11.68]. Examples include: No testing of the system after installation at the operating site. Operating sites are part of the overall system and lack...
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Company: Gensia Sicor Pharmaceuticals Inc.Date: 7/21/99 Product: Drug Products Failure to maintain laboratory records to include complete data derived from all tests necessary to assure compliance with established specifications and standards [21 CFR 211.194]. Specifically, your firm failed to properly maintain electronic files containing data secured in the course of tests from 20 HPLCs and...
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Novartis 7/1/99 b. The annual product reviews did not include all stability results. A problem in the firm’s computer system prevented the results of stability data from printing. Additionally, the stability data from these annual reviews was used to support the Tegretol XR expiration date extension. SoftwareCPR keywords: drugs, pharmaceuticals, computer validation
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Prucka 30-June-99 Multi-channel electrocardiographic amplifiers, CardioLab EP System and CardioCath Catheterization Lab System software 2. Failure to establish and maintain procedures for validation of the device design, including software validation, and documentation of the validation, as required by 21 CFR 820.30(g). For example: a. Standard operating procedures have not been established for software validation. b....
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Solvay Pharmaceuticals 6/23/99 Computer System Validation 1. The xxxx computer system, used to monitor and maintain such critical systems as the xxxx and xxxx systems, has not been validated. Our inspection revealed that the xxxx computer system is used to monitor temperature, conductivity, water pressure and time (in hours) for replacement of xxxx for the...
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14. Failure to validate the software programs, Shimadzu and _____ that are used to run the laboratory HPLC equipment, during analysis of raw materials and finished products. The _____ software does not secure data from alterations, losses, or erasures. The software allows for overwriting of original data. There are no written procedures for the use...
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Picker 7-May-99 MRI equipment The following, deviations from the Device Quality System Regulations were documented: 1) Failure to maintain a design file necessary to demonstrate that the design was developed in accordance with the approved design plan as required by 21 CFR 820.30(j). For example, there is no documentation of any module testing of the...
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Failure to investigate the cause of nonconformities relating to product, processes and the quality system; failure to develop, conduct, control and monitor production processes to ensure that a device conforms to its specifications; failure to establish and maintain procedures to prevent contamination of equipment or product by substances that could reasonably be expected to have...
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Incomplete records for all blood components produced; failure to routinely review error messages on computer system. The inspection also revealed that _____ error messages on your computer system are not routinely reviewed, processed, and investigated to determine final disposition. The instructions for computer system training do not include a clear written explanation of what error...
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With regard to FDA-483 Item 4, Braun was cited for not reporting two MDR reportable complaints, Mfr reports #1641965-1998-00018/24, to FDA within the 30 days time frame. Your response indicated that Braun is currently changing the complaint handling system from tracking complaint information on an _____ spreadsheet to using an off-the-shelf database system, _____ tracker....
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B) Failure to validate the computer system controlling the air separation process.
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Failure to exercise appropriate controls over computer or related systems to ensure that changes in records are instituted only by authorized personnel; failure to concurrently maintain a record from which unsuitable donors may be identified; and failure to maintain and/or follow standard written operating procedures to include all steps to be followed in the collection,...
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GE 9-April-99 Solar Model 7000/8000 Patient MonitorsJohn Welch, Jr. Chief Executive Officer General Electric Company 3135 Easton Turnpike Fairfield, Connecticut 06431 Dear Mr. Welch: We are writing to you because on March 8-12, 1999, investigators from the Food and Drug Administration (FDA) collected information from your Marquette Medical Systems, Milwaukee, WI, facility that revealed a...
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The Center for Devices and Radiological Health (CDRH), Office of Compliance, Division of Enforcement I, Diagnostic Devices Branch has reviewed the January/February 1999 Establishment Inspection Report of your firm, and the Form FDA 483 dated February 5, 1991, that was issued to you at the close of the FDA inspection. They also reviewed your product...
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Radionics 22-March-99 Xknife Stereotactic Radiosurgery System 1. Failure to establish and maintain procedures to ensure that formal documented reviews of the design results are planned and conducted at appropriate stages of the device’s design development, that appropriate representatives are included, and that the results of a design review, including identification of the design, the date,...
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Abbott 17-March-99 In vitro diagnostic products 2. Failure to document all activities required by 21 CFR 820.100(b) as they relate to corrective and preventive action. For example: a. There is no documentation of the management review and approval of the decision not to send a customer communication to alert Axsym instrument users of a system...
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Baxter 3/12/99 Catheters 2. Failure to validate production processes with a high degree of assurance where the results of a process cannot be fully verified by subsequent inspection and test [21CFR 820.75). Specifically, your firm does not have sufficient documented evidence, that the Pulmonary Artery Catheter balloon forming, and the polyethylene (PVC)compounding processes meet their...
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In response to your inquiry concerning the need to maintain manual discard records when the same date is computerized, I can assure you that duplicative, manual records are not required, PROVIDED your computer system(s) are validated to ensure that all necessary data is entered, that the stored data is safely backed-up in the event of...
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Medical Equipment Designs 9-March-99 Diathermy devices Since 1990, you also modified the design of the Meditherm by introducing software to control the device. Major changes in the intended use of the Meditherm and design changes which could significantly affect safety or effectiveness, such as the introduction of software, require a new premarket notification (510(k)) submission...
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Urometrics 9-March-99 Penile tumescence monitors 1. Failure to establish and maintain procedures for the identification, documentation, validation, or appropriate verification, review and approval of design changes before their implementation as required by 21 CFR 820.30(i) in that there is no data to show that the NEVA program version 2.2.1 (revised 1/20/99) was validated or verified....
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Chronimed 3/2/99 Glucose test strips and meters 5. Failure to establish and maintain plans that describe or reference the design and development activities and define responsibility for implementation as required by 21 CFR 820.30(b). For example, there is no plan for the software validation for Version 104. 6. Failure to ensure that the design input...
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Compex S.A. 2/22/99 Muscle and nerve stimulation devices 2. 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 failed to validate the software...
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Diehl Inc. Food Processing 2/12/99 The chart recorder and the computer display on the xxxx units did not correspond to the mercury-in-glass (MIG) thermometer. The chart recorder or computer display may show a reading up to 3 degrees F higher than the MIG thermometer. SoftwareCPR keywords: Production software, validation, electronic records
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Inadequate process validation; failure to validate the test methods used to analyze raw materials and the finished product; failure to institute process qualification for the laboratory instruments used to perform in-process and finished product testing; failure to qualify or validate the firm’s computer software programs; and failure to perform investigations into out-of-specification weight and diameter...
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Being Agile & Yet Compliant (Public)

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

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

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