All batches are released according to the required specifications.Filling is performed in a grade a environment.A 100% visual inspection of all filled syringes is performed to remove syringes with foreign material.The scrap percentage is within normal ranges.After visual inspection an acceptance quality limit (aql) sample is performed to check whether the visual inspection is performed conform the procedure.During assembly, pouching and packaging the operators wear protective clothing and hair caps.Investigation showed that no deviations related to this complaint were reported in the batch record assembly.At each start up assembly, every 30 minutes and at the end of the work order a visual inspection of 24 consecutive syringes is performed as an in process control check.No deviations were reported.The pouching process is performed in a class d environment.A visual inspection is performed of the sealed pouches and no deviations were observed.Foreign material is not a specific parameter that is checked during this visual inspection.Investigation showed that no deviations related to this complaint were reported in the batch record pouching.At each start up pouching, every 60 minutes and at the end of the work order a visual inspection of 10 pouches (at start up) and 4 pouches (every 60 minutes/at the end) is performed as an in process control check.No deviations were reported.After the pouching process and sterilization the product is packaged on packaging line spl03.During packaging, at each start up, every 30 minutes and at the end of the work order a visual inspection is performed on 2 completely packaged folding boxes.No deviations were reported related to foreign material in the pouch.The sample checked during final inspection is conform: no deviations were reported.The provided photos show partially used syringes without tip cap.Air bubbles are visible.No foreign material is observed.Based on the provided photos the complaint cannot be confirmed.One used ophthalmic syringe was received as complaint sample.The syringe has no remaining volume and the used needle was not returned.There are no component deviations observed to the returned syringes.Based on the investigation the complaint cannot be confirmed.A visual inspection is performed on 40 reference samples and ok, no deviations observed.In addition the product of one reference was completely pushed out and visually inspected with a magnifying glass and no deviations observed.Since no manufacturing related deviations were identified and no deviations to the returned complaint sample could be observed, a conclusive root cause could not be determined.A potential root cause for foreign material could be attributed to: a component related issue.This is unlikely as a 100% visual inspection of all filled syringes is performed to remove syringes with foreign material.Cannula : no conclusion can be made as this is outside of the manufacturing control.A product quality issue; however this is very unlikely as no deviations were reported concerning this complaint during the filling process, filling is performed in a grade a environment as well as a 100% visual inspection is performed to remove syringes with foreign material.A root cause outside the control of the manufacturing site could not be eliminated.Review of the manufacturing documentation, lot complaint history and evaluation of samples found no issues which would have contributed to the reported complaint condition.Although an atypical complaint trend was identified, the product and none of the complaints have been confirmed manufacturing related through manufacturing investigation or returned sample evaluation - this complaint is not explicable from a technical point of view.No further action is required.The manufacturer internal reference number is: (b)(4).
|