Failure to establish and maintain adequate procedures for validating the device design to include software validation and risk analysis, as required by 21 CFR 820.30(g). For example, [redacted] Software Development Manager, indicated the diagnostic algorithm system for the PAD software was enhanced to version [redacted] from [redacted] in September 2007, to include the Arabic and Persian languages. The pediatric capability transfer for the PAD device was conducted on 1/18/07, and 2/19/07. Your validation protocol ( [redacted]) failed to document how you validated the software upgrade or how you validated the pediatric capability transfer. 2. Failure to establish and maintain adequate procedures for acceptance of incoming product to include inspection, testing, or other verification as conforming to specified requirements, as required by 21 CFR 820.80(b). For example: a) The Heartsine Samaritan AED System Traveler form ( [redacted]) indicates that Internal Inspection and In QAT testing was not performed for serial numbers [redacted] and [redacted]. Additionally, the required Monitoring Mode for steps [redacted] through [redacted] was not performed for serial number [redacted] b) The Heartsine Samaritan PAD Unit [redacted] form ( [redacted]) indicates that Internal Inspection and In QAT testing was not performed for serial number [redacted] c) The Heartsine Samaritan PAD [redacted] Page ( [redacted]) indicates that [redacted] Inspection and Inspection of [redacted] were not performed for serial numbers [redacted] and [redacted]”
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