Investigation summary: the non-conformances were reviewed for this batch; there were no non-conformances that may be associated with this defect.Risk assessment: in 2017, for this defect type, complaints were reported at an average of 3 per month.Occurrence rate varies between customers, but a total of 26 have been recorded for this specific defect from january to august 2017.Severity is negligible (s1).The defect was previously investigated, the failure mode and root cause of the complaint is known.Investigation activities: the brown staining present on the sf paper top web was observed and reported during the design verification activities.Test results have confirmed the staining to be cosmetic in nature.Samples were shared with customers prior to product launch and the physical appearance of the product was accepted by the customer.The staining occurs as a result of the interaction between the paper and the moist heat sterilization process.Investigation conclusions: the water mark type staining is cosmetic in nature, appears only on the outside of the packaging and does not permeate in any way onto the product.Furthermore, microbial permeability testing, cytotoxicity testing, and testing for residual solvents and volatile species has been completed on the packages displaying the brownish stain.The testing confirmed that they do not present any risk to the use of the product and have no impact on the effectiveness, sterility, quality, or safety of bd posiflush sf 10ml saline flush syringe.Corrective action: required.Capa (b)(4) has been raised following unit level discussions in september 2017.Exceptions: lot numbers manufactured prior to lot 6315951 may have associated staining complaints as a result of sterilizer component issues.This was addressed in capa (b)(4)and the associated corrective action was implemented november 2016.Lot number 6315951 was the first lot number manufactured post corrective action implementation.Lot numbers prior to lot 6315951 may generate customer complaints for staining, these complaints are not within scope of this pic and shall be addressed on an individual basis.
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