Failure to Validate Design


Warning Letter: Failure to Establish Validation Program (ucm366715)

Tags: |

 
"your firm failed to establish a
validation program
for the computer software Microsoft Dynamics used for production, inventory, lot number generation, and laboratory test methods used for raw material, bulk, and finished product test release.  Your firm also uses the Microsoft Dynamics program to assist your quality unit for product, document and component control.

View the original warning letter.



Warning Letter: Missing Validation Testing (ucm 359625)

Tags: | |

Your firm does not have a design history file (DHF) for the Meridian DR 200 single panel X-ray system. The system is comprised of a workstation, flat panel detectors, acquisition software and X-ray hardware. Missing elements of the DHF include:
• A design plan for the project
• Established or approved design inputs/outputs for the system
• Verification or Validation testing for the system
• Design Transfer
• Risk Management for the system
• Design Reviews.
Your firm does not have procedures to describe the content of your Device History Records (DHR’s). In addition, eleven of eleven DHR files reviewed showed that all were incomplete as the only record in the files was your testing of the flat panel detectors, which is only one part of the X-ray system. The DHRs do not include installation records; records of any non-conformities; records regarding the X-ray hardware, workstation or acquisition software; or records of final product testing and quality release of your systems.

View the original warning letter.



Warning Letter: Failure to establish adequate procedures(ucm271368)

Tags: | |

Failure to establish adequate procedures for acceptance of incoming product, as required by 21 CFR 820.80(b). For example, testing records for timers received on March 27, 2009; April 9, 2009; April 17, 2009; and May 28, 2009, only included a computer printout of the final data as the original raw data of the testing conducted and acceptance data for each of the timers were not maintained.

View the original warning letter.



Warning Letter: Validation under operating conditions(ucm239018)

Tags: | |

Failure to validate the design under defined operating conditions and by using initial production units, lots, batches, or their equivalents, as required by 21 CFR 820.30(g). Your firm failed to perform design validation for the data analysis software used in the Cal Ver EP Evaluator to determine out of specification stability results for Verichem products.

View the original warning letter.



Warning Letter: Failure to establish procedures (ucm224014)

Tags: | |

Failure to establish and maintain adequate procedures for verifying or validating the corrective and preventive action to ensure that such action is effective and does not adversely affect the finished device, as required by 21 CFR 820.100(a)(4). For example, no protocol, including acceptance criteria, was established for the validation of Change Request [redacted]. Additionally, there was no documentation showing that this change was validated.

View the original warning letter.



Warning Letter: Failure to Follow Procedures (ucm216889)

Tags: | | | |

Failure to adequately ensure that when the results of a process cannot be fully verified by subsequent inspection and test that the process shall be validated with a high degree of assurance and approved according to established procedure [21 C.F.R. § 820.75(a)]. “Specifically, the procedure “Validation of the Aseptic Filling Process Utilizing the Media Fill Method,”[redacted], states that initial validations should be conducted consecutively and prior to routine production fills and subsequent re-qualifications should be performed [redacted] as appropriate. In addition, the procedure states that routine production may not resume until acceptable qualification or validation runs are achieved or until all appropriate investigations and/or repeat media fills have been performed with acceptable results. However, validation of the aseptic filling process in filling suite [redacted] for [redacted] bottles was inadequate in that the [redacted] re-qualification of the [redacted] Aseptic Filling Process utilizing the Media Fill Method [redacted]performed on March 23, 2009 failed. The failure produced [redacted] contaminated units out of approximately [redacted] units inspected. In addition, the subsequent validation of [redacted] for filling [redacted]and [redacted] bottle [redacted performed on May 20, 2009 also failed.

View the original warning letter.



Warning Letter: Lack of validation testing (s6906c)

Tags: | |

Your validation of your device design is incomplete in that the firm has not established a protocol for conducting validation testing and did not validate the software to ensure that devices conform to the defined user needs and intended uses, as required by 21 CFR §820.30(g). Specifically, you have made 1,900 revisions to the software in three years without conducting validation testing .

View the original warning letter.



Warning Letter: Failure to validate processes (ucm076566)

Tags: | |

Failure to validate manufacturing processes and approve according to established procedures, where the results cannot be fully verified by subsequent inspections and tests. [21 C.F.R. 820.75(a)] Specifically: Computer Numerical Control (CNC) Machine #C-4 had out of specification results during operational qualification conducted during validation. These out of specification results were not investigated or addressed in the validation report.

View the original warning letter.



Warning Letter: Failure to validate before implementation (s6328c)

Tags: | |

 
"Failure to
establish and maintain procedures
for the identification, documentation, validation, or where appropriate verification, review, and approval of design changes before their implementation, as required by 21 CFR 820.30(i). Specifically: a) In June 2006, your firm recalled 2455 units of the Spectrum Infusion Pump due to several events where the pump tubing mis-loaded when it was installed by the end user. Several design changes were made to the Spectrum Pump's hardware and software to better assist the end user in installing the pump tubing. These design changes were incorporated into the blanket Engineering Change Notice (ECN # 15501). This ECN contained several individual ECNs to cover each change that was made to correct the tubing mis-loading problem. However, the blanket ECN also included an individual ECN to implement the PCA/PCEA delivery modes within the Spectrum pump. ECN# 15501 and all individual ECNs under this blanket ECN were cleared for manufacturing on May 01, 2006. However, our inspection revealed the
software verification/validation
for the pump operating software version 4.00.04 and MDL software version 5, and the design of the hardware components associated with the PCA/PCEA module were not completed at the time the re-designed Spectrum pump was released for manufacturing. Yet, ECN # 15501 was approved for manufacturing by your firm's Approval Committee (consisting of representatives from Engineering, Manufacturing, Quality Assurance and Purchasing), without ensuring that the appropriate verification/validation for the PCA/PCEA functions were completed. More significantly, 257 units of the Spectrum pumps, manufactured between May 01, 2006, and June 26, 2006, were distributed into interstate commerce with an "enabled" version of this unvalidated PCA/PCEA function as replacements for defective devices that were returned to Sigma International as a result of the June 2006 recall."

View the original warning letter.