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warningletter

Software Warning Letters

Knoll Pharmaceutical 12/14/98 Your firm’s equipment qualifications for the Amsco SG-116 autoclave and the computer control system for the 60″ film coating pan were inadequate. SoftwareCPR keywords: software validation, CDER, Drugs, Pharma
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Soft Computer Consultants 12/4/98 Blood Bank Computer SoftwareDESIGN CONTROLS 1) Failure to establish and maintain plans that describe or reference the design and development activities, and define responsibility for implementation including the plans that describe the interfaces with different groups that provide input to the design and development process [21 CFR 820.30(b)]. 2) Failure to...
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Ultramedic Ltd. 11/25/98 Infusion Pump Analyzers 6. Failure to have an established protocol to validate computer software for its intended use 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 validation protocol for the validation study...
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North American Science Assoc 11/24/98 Contract Testing Laboratory Failure to maintain adequate controls over computers and related systems to assure that changes in the master production and control records or other records are instituted only by authorized personnel [21 CFR 211.68(b)]. For example: (1) there is no current listing of individuals who have access to...
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North American Science Contract Test Laboratory 11/24/98 Failure to maintain adequate controls over computers and related systems to assure that changes in the master production and control records or other records are instituted only by authorized personnel [21 CFR 211.68(b)]. For example: (1) there is no current listing of individuals who have access to the...
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Allergy Laboratories 8/14/98 8. There are no controls for computer generated labeling used for product inserts. It was noted during the inspection that finished HealthTest HIV 1 + 2 and HBsAg test kits were relabeled from “For in vitro use only” to “For Research Use Only”. SoftwareCPR keywords: software validation, CDRH, devices
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ICS Medical 10/29/98 Diagnostic opthalmic devices 1. Failure to develop, monitor, and control the software development processes to ensure that the software used in _____ conforms to its original design or any approved changes. 2. Failure to review the software development process to identify actions needed to prevent the recurrence of software nonconformances. 3. Failure...
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Villa Sistemi Medicali, S.p.A. 9/30/98 Dental x-ray systems Failure to maintain Device Master Records (DMR) that includes or refers to the location of: device specifications including component specifications, software specifications; production process specifications; quality assurance procedures; and labeling specifications as required by 21 CFR 820.181(a)(b)(c) and (d). For example, the firm has no Device Master...
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Review of the _____ which consisted of the software and hardware components necessary to _____ DHRs and maintain them as electronic records, revealed the following:. Changes to processes were not always reviewed and evaluated or revalidated, where appropriate, and documented [21 CFR 820.75(c)], in that the software validation dated _____ was completed for software _____...
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Bernafon-MAICO Inc. 5/06/97 “Computer Validation The inspection found that the xxxx Computer System, used to add bulk quantities of solvents to the manufacturing processes (from a tank farm) for Ticlopidine and Bromocryptine Mesylate drug substances has not been validated (FDA-483 Item #16). The response to FDA-483 Item #16 is inadequate. Your firm’s commitment is to...
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Failure to validate and document significant manufacturing processes and quality assurance tests to assure specific requirements are met, e.g., robot and manual welding processes, and software used to program the chip in the control device of the automatic air mattress. Your firm’s response dated July 30, 1998 and signed by Edward A. Kroll, Director, TQM...
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Sabratek Corp. 8/19/98 Infusion pumps 1. Failure to identify the actions needed to correct and prevent recurrence of non-conforming product. For example, it was determined that the _____ had a software problem which prevented the infusion rate from exceeding the bolus rate while operating in the “PCA” mode. While the software has been revised, the...
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Allergy Laboratories 8/14/98 4. Failure to routinely calibrate, inspect, or check for accuracy and to exercise appropriate controls for automatic, mechanical, or electronic equipment or other types of equipment, including computers, used in the manufacture, processing, packaging, and holding of a drug product according to a written program designed so as to assure performance [21...
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Imaging Sciences International Inc. 7/21/98 CommCat IS-2000 Imaging System dental tomographic and panoramic X-ray machine c) Repair requests beyond the one-year warranty period are not reviewed to determine whether they are complaints, nor is information obtained by the software phone service documented and reviewed for potential complaints.
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Multidata Systems Intl. Corp. 7/16/98 Decision Support Systems (DSS) for Radiation Support device 1. Failure of management with executive responsibility to appoint a member of management to establish authority over and responsibility for (a) ensuring that quality system requirements are effectively established and effectively maintained, and (b) reporting on the performance of the quality system...
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Failure to investigate adverse device effects;failure to install password clearance on computer You failed to investigate the failure of the _____ when operating in MS Access. The system locks up at random and it is unknown whether the software which controls the _____ during _____ which operates off of MS Excel, could be similarly affected....
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Hil-rom 6/25/98 Isolette C2000 Infant Incubators Failure to assure that all inspection and testing equipment is suitable for its intended purposes and is capable of producing valid results. The inspection revealed that the _____ automated simulator test has not been updated to keep current with hardware and software changes made to the C2000 device. (FDA...
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m. concerning the _____ software, used for the handling, storage, and distribution of product…Your response states that the _____ software will be validated. Please note that the establishment of an adequate validation protocol, including system specifications and criteria for demonstrating that the software will meet the requirements, is necessary in order to conduct adequate validation.
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.Select Brand Antacid Peppermint Tablets, 75’s, Lot #7026, manufactured on March 1997, was placed “On Hold”, but was not physically labeled as such, nor did the computerized inventory system indicate this status. Accucal Calcium Antacid Peppermint Tablets, 150’s, Lot #7075 was marked “Rejected” as stored in the warehouse, but this status was not indicated in...
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7. You have failed to establish appropriate procedures to assure that computerized processing control systems and data storage systems used in the production and quality systems at Ansell, Inc. are secured and managed to assure the integrity of processes and data that could effect the conformance of the condoms to established specifications. Examples of such...
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Lumisys 5/12/98 MammoWorks” an interactive database designed for mammography practices and teleradiology devices. 1. Failure to develop, conduct, control and monitor production processes to ensure that a device conforms to its specifications [21 CFR 820.70]. For example, your firm does not have sufficient evidence which provides a high degree of assurance that your production process...
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DeRoyal Cientifca Esophageal Stethoscopes 5/1/98 “1. 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). This would also be a violation of the GMP Regulation, 21 CFR...
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Failure to establish adequate written-recall procedures and to validate the computer software programs designed to facilitate recall of distributed drug products.
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Bioresearch 3/31/98 TMJ diagnosois software Your firm failed to obtain a new 510(k) or pre-market approval after making significant changes to the BioPAK System. Analysis software, i.e., “The Interpreter,” was added to the system to aid in the diagnosis of temporomandibular joint disorders. In addition, your firm is promoting an indication for use (“implants”) that...
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Hitachi 3/30/98 In vitro diagnostic analyzers 1. Failure to establish and maintain procedures for implementing corrective and preventive action, as required by 21 CFR 820.100(a) (4). This would be a violation of the 1978 Good Manufacturing Practices Regulation, 21 CFR 820.162, inadequate failure investigation. For example, software release versions were not documented as required or...
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.Controls on your laboratory computer system software _____ allow saved chromatograms to be re-integrated without designation as a saved file. The saved chromatograms that are re-integrated then cannot be restored as original data. SoftwareCPR Keywords: Part 11
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… Failure to ensure that automatic, mechanical, and electronic equipment, including computer(s) are inspected or checked according to a written program designed to assure proper performance [21 CFR 211.68]. For example, your computer software used for tracking raw material, finished product quarantine/release, and archiving master formulas has not been validated…. SoftwareCPR Keywords: Drug, Pharma
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Scottcare 2/25/98 TeleRehab II Cardiopulmonary Monitoring System Failure to maintain a complete Device History Record (DHR) in that it does not contain updates to software or their location, or document rework and evaluation of non-conforming finished devices or part.
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Nikkiso Co. Ltd. 1/27/98 Hemodialyzers 2. Failure to validate computer software for its intended use according to an established protocol when software is used as part of production or the quality system, as required by 21 CFR 820.75(j). For example, the software used to perform _____ has not been validated. This software is part of...
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Witt Biomedical Corp. 1/23/98 Cardiac catherization monitoring system Failure to establish and maintain adequate procedures for changes to a specification, method, process, or procedure, e.g., software installation procedures are being changed without using an approved process pursuant to established procedures;
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Mennen Medical Ltd. 1/21/98 Patient Monitors c. The approval page for the Horizon 9000WS Cathlab’s software located in the document control department contained the signature of the originator of the document, but it lacked an approval signature. This approval page was different from the approval page for the same software located in the production department....
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Failure to document approval of all documents established to meet the requirements of part 820, including the date and signature of the individual(s) approving the document, as required by 21 CFR 820.40(a). For example, the device master record was not signed or dated to indicate approval, and the master and working copies of Software for...
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No evidence of validation of computer system or software; use of unrecognized testing methods for testing and release of finished products; and no review and approval by the Quality Control Unit of Oxygen USP and Nitrogen NF. 1. No documented evidence of the validation for the computer system or associated software that is responsible for...
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Failure to validate the finished device testing software for the ProNeb and Duraneb 2000 compressors and complaint handling software according to established protocols; failure to establish written procedures for monitoring and control of process parameters; failure to establish written procedures and to develop specifications for the contract manufacturer; and failure to establish final acceptance procedures....
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b. Changes made to the software program for the _____ have not been formally reviewed and approved by designated representatives of the firm…..Your response is not adequate because it does not include documentation showing formal review and approval of the software program changes. a. A user manual (or SOP) is not available for the _____...
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3) There are insufficient controls in place to ensure the integrity of calculated data generated by the _____ software in the Quality Control Laboratory, in that:.
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Failure to review, evaluate and investigate complaints involving the possible failure of a device to meet any of its performance specifications; failure to thoroughly evaluate and investigate complaints; and failure to validate software used in tracking and trending service and complaints. 4. Failure to validate software used in tracking and trending service and complaints. For...
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4) Failure to produce documented evidence to demonstrate the computer controlled/automated system for the manufacturing of liquid oxygen and nitrogen has been validated.
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The Food and Drug Administration (FDA) inspected your medical practice on September 3, 4 and 15, 1997, and determined that you are using an unapproved excimer laser system assembled by _____ an engineering consultant with _____ and representatives of _____ This laser system contains software developed by _____ with your input into its design. This...
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You failed to respond to calibration failures of the ultraviolet (UV)/visible spectrophotometer as required by your procedures. Instruments were not taken out of service, logbooks did not reflect passing/failing calibrations, certificates of calibrations were incomplete, there was no investigation into the cause of failures and no record was maintained of the corrective action taken as...
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Failure to establish and implement an adequate complaint handling system. Although the computerized complaint system used by your firm allows input from all departments, there is no system in place to assure that all service records are reviewed and evaluated for potential inclusion in the complaint handling system.
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We acknowledge that you have destroyed key components of the _____ and thus have terminated your _____ of this device. Please advise this office, in writing, within 15 working days of receipt of this letter, of the specific steps you have taken to prevent recurrence in future _____ of violations similar to those listed above....
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Failure to validate the heat sealing equipment; failure to validate the software in use to calculate GPL and MPL unit values; failure to provide adequate documentation to assure that the product will maintain its functionality throughout its labeled expiration date; and the quality assurance program failed to respond to device quality problems identified as a...
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1. Failure to validate major equipment used in the manufacture of medical devices (i.e. computer-driven Kiwa mills, Mori Seiki SL2B lathe, and Citizen lathes);
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Failure to establish and maintain procedures for finished device acceptance to ensure that each production run, lot, or batch of finished devices meets acceptance criteria; failure to establish and maintain an adequate organization structure; and failure of the device master record to include, or refer to the location of, for each type of device, device...
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a) Failure to validate finished device testing software, some of which were incorrectly programmed. b) Test software failed to contain a test process/calculation to assure that finished device accuracy specifications were met. e) Failure to establish written and approved manufacturing procedures for finished device test software for MRX multi board and single board devices.
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4. The HPLC computer software (_____, which is used for data acquisition, calculations, and system control, is not validated in that areas such as system operations, system maintenance, change control, data back-up and archival, system security and disaster recovery have not been evaluated.
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Your software system which is used to defer donors, does not flag subsequent donations of donors who previously tested positive for certain viral markers. Your procedure, “Computer Entry of Donor Deferrals”, describes four donor status codes (N-Normal, D-temporarily deferred, P-permanently deferred and R-permanently deferred allogenic donor but acceptable autologous donor). However, the software system interprets...
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In addition, there was no assurance that the dispensing pump delivers accurate doses. For example, daily accuracy tests on the pump were not documented and the _____ software, revision _____ was not validated to verify installation, operation, and performance.
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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
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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
See our post titled: 1st Quarter 2025 Agile Compliant Courses Scheduled

 

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:  June 24-26, 2025 (Boston, MA)

Special pre-registration discount through January 31, 2025

Private, in-house courses can be scheduled. Contact us.

Email training@softwarecpr.com for more info.

 


 

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

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