There are few things in life more frustrating than sitting across from FDA, during an inspection, and not being properly prepared with documented evidence of compliance. If the DHRs are not being properly completed or maintained, rest-assured, the investigator will cite the issue as a Form 483 observation.
Process Validation should be considered one of the basic tenants associated with the manufacturing of finished medical devices that are safe and effective in their intended use. However, what happens when a device establishment fails to implement an effective program for process validation?
If an establishment is manufacturing finished medical devices that are sterile, there should never be any excuses for not properly maintaining and monitoring the cleanroom or CER.
Put significant effort into the design and development planning phase. It really is the road map for a successful design and development process.
Device manufacturers should actually be listening when a customer calls with a complaint. Although being on the receiving end of a complaint is never pleasant, your customers are trying to tell you something.
Don’t be that organization that fails to file MDRs. FDA takes the need to report adverse events very seriously, so failing to file MDRs is a mortal sin in the eyes of FDA.
If clinicians performing clinical trials are categorized as Totally Restricted Investigators by FDA, then the clinical work is a wasted effort. Ensure that an appropriate level of due diligence is pursued prior to partnering with the clinicians selected to execute the clinical investigation.
For those of you that are struggling to comply with 21 CFR, Part 820.50, you have two options: one, bite the bullet and script a reasonable procedure needed for effective purchasing controls, including supplier management; or two, embark on a ” hegira ” to escape the wrath of FDA.
Everything from unannounced notified body audits to a rescript of the directive into a regulation injected with steroids, changes are lurking on the horizon when it comes to the MDD.
The use of electronic filing will make your lives easier. Considering the initial requirement to report deaths and serious injuries was born in 1984, it is about time industry moved into the 21st century in regards to the reporting of adverse events.
