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warningletter

Software Warning Letters

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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11. Failure to exercise appropriate controls over computer or related systems to assure that changes in master production and control records or other records are instituted only by authorized personnel [21 CFR 211.68(b)] in that there are no procedures for control of the software including procedures to control inappropriate or incorrect changes to the specifications...
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Data management software systems …We are writing to you because on February 28 through March 3, 1997, Investigator James E. Moore from the Food and Drug Administration (FDA) collected information that revealed a serious regulatory problem involving the products known as the “_____” and the “_____” data management software systems, which are made and marketed...
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You have failed to appropriately validate the sterilization equipment and process in use. You could not provide documented evidence which established a high degree of assurance that the sterilizers and the sterilization process in use are effective and could consistently produce a product meeting its predetermined sterility specifications and quality attributes. You have failed to...
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3. The software was changed, consistent with the new performance specifications. 2. Failure to validate software programs by adequate and documented testing, when computers are used as part of an automated production or quality assurance system, as required by 21 CFR 820.61. For example: a) The validations were not documented for the computer software used...
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3. Failure to assure that specification changes shall be subject to controls as stringent as those applied to the original device, as required by 21 CFR 820.100(a)(2). This would also be a violation of the Quality System Regulation, 21 CFR 820.70(i). For example, no documentation of specific software changes, which were made to the _____...
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3. Failure to maintain written validation protocol and procedures for software and hardware maintenance for the _____ computer system version _____ . 4. Failure to have documented validation for the _____ software and the _____ software. Observation #12. Security controls should be established in writing. They should address the automated test system, as well as...
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Metuchen Analytical, Inc. 6/13/97 Drugs 5. Lack of validation data to support the adequacy of the computer software (PC1000 version 2.5 supplied by [purged text] used to run the HPLC systems.
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Radia Industry Co. 6/3/97 Sterilization of plasma separators 1. Failure to conduct processing control operations in a manner designed to assure that the device conforms to applicable specifications, as required by 21 CFR 820.100(b)(2). For example, there was also an incorrect maximum conveyor speed observed on February 24, 1997, by the investigator and one member...
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We regret to inform you that your certification is incomplete, and therefore inadequate, as submitted. Your certification states that “the computer hardware, firmware and software in my laser allow it to perform all the procedures of the PMA approved device in an identical manner. ” A certification must establish that the limitations of operation required...
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Nucletron Corporation 5/21/97 Brachytherapy products b. Specific versions of Veriflex software are ordered, but no SOPs exist which require verification of the version received. Furthermore, the Purchase Order database, used to check incoming components against part numbers, lists obsolete software versions under the current part number. 3. Failure to follow complaint procedures and to maintain...
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Bernafon-MAICO Inc. 5/06/97 3. Software revisions have been made without Engineering Change Order (ECO) control, resulting in the distribution of audiometers with unapproved software. ECOs do not include a record of software source code changes and obsolete versions are not archived [21 CFR Part 820.100 (a)(2)]. Software source code is not controlled under the document...
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Lack of written procedures to identify quality assurance problems reported in complaints and repair requests; failure of screening repair and serice requests to identify complaints; and failure of engineering change orders to include a record of software source code changes 3. Software revisions have been made without Engineering Change Order (ECO) control, resulting in the...
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LKC Technologies 5/2/97 Opthlamic Diagnostic Units b. The device history record for a UTAS E-2000 Electrodiagnostic System, serial number “0322,” failed to indicate that the “Final Test” (software virus scan) was performed.
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On April 9, 1997, Mr. Mark Tseng and Mr. Emir Galevi of the United States (U.S.) Food and Drug Administration (FDA) conducted a pre-announced inspection of the computer monitor manufacturing facility, Daesun Industrial Co., Ltd., in Kyunggi-Do, South Korea. The FDA inspectors reported several serious deficiencies found in Daesun Industrial Co., Ltd.’s quality control and...
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Walter Graphtek GMBH 4/29/97 Digital electroencephalography devices 1. Failure to assure that specification changes shall be subject to controls as stringent as those applied to the original device, as required by 21 CFR 820.100(a)(2). For example, there are no documented procedures for the initiation, verification, validation, approval, implementation and documentation of device hardware and software...
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Institute for Radiological Image Sciences 4/23/97 Software for calculation bone density During a Food and Drug Administration (FDA) inspection of your firm located in Frederick, Maryland, on March 23 and 26, 1997, our Investigator determined that your firm manufactures the IRIS software program used for calculating bone density, which is a device as defined by...
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IRIS software program. During a Food and Drug Administration (FDA) inspection of your firm located in Frederick, Maryland, on March 23 and 26, 1997, our Investigator determined that your firm manufactures the IRIS software program used for calculating bone density, which is a device as defined by Section 201(h) of the Federal Food, Drug, and...
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We regret to inform you that your certification is incomplete, and therefore inadequate, as submitted. Your certification states that “the computer hardware, firmware and software in my laser allow it to perform all the procedures of the PMA approved device in an identical manner. ” A certification must establish that the limitations of operation required...
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Irwin Memorial Blood Centers 3/20/97 Blood Center Please be advised that the agency’s memorandum dated April 6, 1988, entitled “Recommendations for Implementation of Computerization in Blood Establishments” indicates as a data security issue that “if key elements of the database are changed, these changes should be traceable as to the time and person making the...
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Cordis Corporation 3/19/97 Stent Delivery 2. The validation of the balloon forming machines conducted from April 1995 to February 12, 1996 is inadequate due to the following: A. The Programmable Logic Controller which controls the balloon forming machine was not qualified.
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Fischer Imaging Corporation 3/19/97 X-ray and mammography systems (a) At least [purged word] systems observed with in-process component and system mis-assemblies such as miswired parts; incorrect or defective printed circuit boards (PCB); missing hardware; defective computer or monitor; incorrect labeling; and defective components such as hand switches, foot switches, collimators, radiation detectors, x-ray tube, cables,...
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Automated Voice Systems 3/18/97 Environmental controller 1. Failure to control written manufacturing specifications and processing controls to assure that a device conforms to its original design or any approved changes in that design [21 CFR 820.100]. For example, our investigation determined that your firm failed to ensure that all changes made to your Mastervoice ECU...
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Multimedia Medical Systems 3/18/97 Therapac-Plus and Compute-Rx-Plan Software 2. Failure to have approved, dated, and signed Device Master Records for Therpac-Plus Software and related Standard Operating Procedures (SOP) 100 through 133 [21 CFR 820.181]. 3. Failure to establish written procedures for the manufacturing and processing of the finished device [21 CFR 820.160]. There is no...
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Separation Technology 3/7/97 Centrifuges 4. Failure to document, review, approve, and validate changes to components, finished devices, labeling, packaging or manufacturing process specifications [21 CFR 820.100(b)(1),(2) & (3)], e.g., there is no documentation of the prior approval of the software specification change initiated 1/24/97 that was an attempt to correct the failures described above. Also,...
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Medical Information Technology 3/6/97 Blood Bank Software Manufacturer c. Quality Assurance audits do not cover any quality assurance activities associated with the software customization program. 4. Failure to establish an adequate complaint handling program for the [purged text] as required by 21 CFR 820.198 in that complaints are not reviewed by a formally designated unit...
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Internazionale Medico Scientifica 3/5/97 Mammography Systems The above-stated inspection revealed that these devices are adulterated under section 501(h) of the Act, in that the methods used in, and the facilities or controls used for the manufacturing, packing, storage, and installation are not in conformance with the Good Manufacturing Practice (GMP) for Medical Devices Regulations, as...
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Sunquest Information Systems 3/3/97 Blood Bank Software manufacturer 1. Failure to implement and verify solutions to quality assurance problems [21 CFR 820.20(a)(3)]. For example, our investigation disclosed that representatives of your quality assurance program made recommendations to correct software defects which were not been implemented in a timely manner. Specifically, our investigation determined that some...
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Synaptic Corporation 2/28/97 2. Failure to establish a Device Master Record which includes all device specifications including appropriate drawings, composition, formulation and component specifications. For example, the Master Record for the [purged text] does not include the checksum value of the software, which is used to assure that [purged text] are correctly programmed.
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Diagnostic Specialties 2/10/97Microplate processor 5. Your firm failed to qualify the [purged text] microplate processing instrument, as well as, the [purged word] Control Software and the [purged text] Software, for their intended use.
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Abbott Laboratories 1/31/97 Internal Complaint Handling System During the inspection, our investigator identified a serious limitation inherent in your firm’s complaint database software system. Your current database software system does not provide for the recording of multiple complaint codes for a single complaint. Consequently, some computer generated reports for management review of complaint trends may...
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8. Failure to adequately validate the _____ system software used for inventory tracking of quarantined, rejected, and released materials for finished products and for release and materials transfer functions [21 CFR 211.68].
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a. The reason for changes made to the CNC software programs was not documented nor signed off by a designated individual. b. When the CNC software is changed, the previous versions are overwritten or lost, thus making traceability of the software’s evolution impossible. 4. Failure to conduct processing control operations in a manner designed to...
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WARN 12/05/96 Lady of the Lake Blood Bank Deviations noted included: 1) lack of proper validation of computer system software; 2) failure to establish and implement adequate computer security in allowing software vendor unrestricted modem access and not consistently documenting this access; 3) not conducting a secondary review of computer software modifications; 4) lack of...
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WARN 12/03/96 Berlex Appropriate controls are not exercised over the [purged text] Software, used by Quality Control and Technical Services, to assure that changes in laboratory control records are instituted only by authorized personnel. There are no written procedures defining the appropriate use for the abort, terminate, suspend, restart, and stop functions which are accessible...
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WARN 11/27/96 Stedim S.A. Failure to validate software programs by adequate and documented testing, when computers are used as part of an automated production or quality assurance system, as required by 21 CFR 820.61. For example: The previous inspection revealed that your firm had not performed any validation of the computer software which controls the...
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WARN 11/14/96 Digisonics 1. Failure to establish and implement adequate quality assurance procedures that provide detailed descriptions of the procedures to be used to perform regression testing after changes to the software have occurred [21 CFR 820.100(a)(2)]. We acknowledge your response to the FDA-483 dated July 10, 1996. The information in your response is inadequate...
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WARN 09/06/96 S&W MEDICO TEKNIK A/S -Patient monitoring 1. The software for the device identified as the Diascope traveller has been modified to add color to the monitor display. This is a very significant change since a new graphic controller (new hardware) had to be used in addition to a new color LCD display and...
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09/09/96 NEURODYNE MEDICAL CORPORATION – Biofeedback units Product labeling for the MEDAC System/3R states, “MEDAC System 3R–is a new configuration for rehabilitation & pain management applications where more than 2 EMGs are needed. All of the stress assessment software features of the standard MEDAC along with 4 channels of surface, PPG (heart rate, pulse height,...
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WARN 09/06/96 NIDEK CO., LTD. Our investigator determined that your firm manufactures sterile and non-sterile products which include ophthalmological, optometrical, semiconductor measurement equipment, and intra-ocular lense. 2. Failure to prepare and implement quality assurance procedures adequate to assure that a formally established and documented quality assurance program is performed. For example: a) The firm has...
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Bennett subsidiary of Trex medical Corp. 8/15/96 (component supplier of high frequency programmable generators for use in imaging systems) 2. Validation protocols for software revisions fail to always specify test parameters such as normal input values, boundary values, out-of-range values and the expected outputs values
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Soring Germany 8/9/96 ultrasonic dissection/aspiration devices 2. Failure to establish and implement specification control measures to assure that the design basis for the device is correctly translated into approved specifications, as required by 21 CFR 820.100(a)(1). For example, there is no documented software validation for the software which operates all devices manufactured by your firm....
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Walter Graphtek Germany 7/1/96 EEG devices 3. Failure to perform planned and periodic audits in accordance with written procedures by appropriately trained individuals not having direct responsibility for the matters being audited, as required by 21 CFR 820.20(b). For example, the following areas were identified as having not been audited under your internal quality assurance...
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GE Medical 6/16/96 X-Ray France Failure to validate software programs by adequate and documented testing, when computers are used as part of an automated production or quality assurance system, as required by 21 CFR 820.61. For example, the software control processes have not been validated to correct the most serious faults. Failure to subject any...
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Somerset Medical Center Blood Bank 5/29/96 1. The validation of the Meditech Computer System is incomplete and/or inadequate for the following reasons: a. Computer documentation did not include testing procedures, system requirements, and system specifications which were specified to Somerset Medical Center. b. There is no assurance that all program changes resulting from the software...
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Planmed OY 5/9/96 Finland 3. Failure to routinely calibrate measurement equipment, to establish adequate calibration procedures, and to maintain records of calibration, including the next calibration date; and failure to validate software programs by adequate and documented testing, when computers are used as part of an automated production or quality assurance system, as required by...
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Cobe 4/16/96 Hemodialysis 10. Failure to have adequate checks designed and implemented to prevent inaccurate data output, input, and programming errors when automated data processing is used for manufacturing or quality assurance purposes, as required by 21 CFR 820.195. For example, the computer search process for complaints by serial number is not designed to detect...
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Abaxis 4/5/96 blood analyzer 1. Failure to validate computer software programs by adequately documented testing, when computers are used as part of an automated production or quality assurance system (21 CFR 820.61). The computer programs which control the automated assembly of rotor parts, loading of reagent beads, dispensing of reagent beads into proper cuvettes, and...
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Barton Carey Medical Products 4/3/96 our Investigator determined that your firm manufactures vascular and burn compression garments. These garments are devices as defined by Section 201(h) of the Federal Food, Drug and Cosmetic Act (the Act). The Inspection revealed that your devices are adulterated in that, the methods used in, or the facilities or controls...
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PIE Medical Equipment 4/1/96 Netherlands ultrasound 1. Failure to maintain records documenting that production and quality assurance measurement equipment is routinely calibrated, inspected, and checked according to written procedures and to validate software programs by adequate and documented testing, when computers are used as part of an automated production or quality assurance system, as required...
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SoftwareCPR Training Courses:

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)

Multiple participants from the same company: If you register 5 or more from the same company before March 15, 2025, receive a special discounted registration of $1999 per person.  These registrations may be transferred to another person at any time. Email training@softwarecpr.com to register and secure the TEAM discount.

 

For private, in-house courses, please contact us.

Email training@softwarecpr.com for more info.

 


 

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
See our post titled: 1st Quarter 2025 Agile Compliant Courses Scheduled

 

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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