Integra has performed a thorough review of the reported incident.There was no product received back, as such only a dhr review was conducted.The dhr review concluded there were no assembly component related failures at the time of release.With the information provided a root cause could not be reliably determined.Should new information become available, the file will be re-opened and the investigation will be amended as appropriate.
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The device was returned for evaluation therefore the failure analysis integra has performed a thorough review of the reported incident.The visual inspection of the returned photos noted: the first photo depicts the clear and blue syringe attached to the applier.There is fluid in both syringes.There appears to be two and a half ml of clear fluid however the blue side cannot be determined from the angle in which the photo was taken.However the blue side is not full.The second photo depicts the clear and blue syringes at a different angle.The three ml mark is visible on the blue syringe but the other numbers are not.There is fluid in both syringes however the blue side is not full.The dhr review concluded there were no assembly component related failures at the time of release.Our investigation was unable to determine a root cause or establish a relationship between the device and the reported condition.No enhancements or improvements were generated for the reported condition.Based on the evidence available the reported condition of product appearance and insufficient volume was confirmed.Between 05nov2019 and 30jun2020, approximately 2,200 mdrs submitted electronically by integra lifesciences via trackwise, integra's complaint handling system, were not received by cdrh due to a computer system issue.Within this time period, an error with integra's middleware, which facilitates communications between trackwise and the fda system, caused the complaint records to close and indicate we had received an acknowledgement 3 from the fda when we had not.Integra interpreted the acknowledgement as a successful submission; however, subsequent investigation revealed the acknowledgement 3 received was from our middleware and not from the fda (these acknowledgements have been retained as part of the documentation of the mdr).The malfunction was related to the relocation of the trackwise application to a new data center during the transition of integra's corporate headquarters from plainsboro, nj to princeton, nj.Previously, integra had been successfully receiving acknowledgements 1, 2, and 3 from the fda, and our records reflect these acknowledgements, including the date and time stamps.Capa pr (b)(4) and nc 20-011 have been opened by integra to further investigate the nonconformance and develop a corrective action plan.The middleware error has been corrected, and integra has filed mdrs since the correction and verified that the appropriate acknowledgements have been received from the fda.Integra is resubmitting all impacted mdr reports for the time period 05nov2019 through 30jun2020.Integra lifesciences contacted (b)(6) , director of regulatory programs, office of product evaluation and quality and (b)(6) , assistant director, mdr team, office of product evaluation and quality on july 8-9, 2020 to report these issues regarding mdr reports.
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