During the implant procedure, the nurse notified the territory manager that the stimulator's shelf-life had exceeded.The territory manager confirmed this and exchanged the product prior to the implant.The implant procedure was completed without complications and there was no harm to the patient.No further complications were reported.The device was not implanted.The expiration date in the product's labeling indicates the validated shelf life for the product, which has been validated through shelf life studies (accelerated aging (06-0580) and real time aging (06-01723)).Neither the product's sterility nor performance is affected as the sterile barriers have not been compromised.Currently, an extended shelf life study initiated on march 19, 2018, is underway to evaluate extending product expiration date to at least five (5) years; this data will verify product sterility and performance for the extended time period (refer to capa-(b)(4) for full correction details).A review of current procedures confirmed that field personnel are required to verify the expiration date of the stimulator prior to implant.Additionally, a review of shipping and receiving procedures indicated that there is no implemented process to prevent expired products from being shipped out.The operating room procedures (50-0129, page 3) state:the clinical specialist must check all expiration dates and product models for accuracy per patient/clinician requirements before each procedure.Based on this information, the expired product was confirmed/replicated, the product did not meet specification and the stimulator is used for treatment of pain.The cause of the expired product was an issue with manufacturer material control issues.Device history record was reviewed and there were no non-conformances.
|