The complainant indicated that the device will not be returned for evaluation; therefore, a failure analysis is not available, and we are not able to determine the relationship between this device and the cause for this event. as part of our manufacturing process, all device history records are reviewed and approved by quality, prior to release of product. if additional information or the sample is received, the investigation will be reopened and responded to accordingly.
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Necrosis is a condition when skin tissue dies and becomes dehydrated.The lot code submitted is confirmed.The device history record (dhr) was reviewed, and no abnormal process conditions were present during the manufacturing of the product that could have led to the condition described by the customer.The dhr review showed that all acceptance criteria inspections per established sampling levels were within acceptable limits during the production process.There were no samples submitted with this complaint; however, there was one photo submitted with the complaint.Because no sample was returned with this complaint, a product examination was not possible.Although it is evident that the patient experienced necrosis under the electrode pad the investigation could not confirm anything manufacturing related that could have contributed to this outcome.Therefore, this complaint is unconfirmed as a product issue.It is worth noting the precautions on the directions for use does not recommend putting electrodes on broken skin with cuts or lesions, scar tissue or infections.Because the patient was burned severely this may have contributed to the necrosis experienced by the patient.This product family has been tested according to iso 10993 guidelines for biocompatibility that found both the hydrogel and skin contacting foam adhesive to be non-cytotoxic, non-irritating, and non-sensitizing.The foam adhesive is an acrylic based pressure sensitive adhesive.The raw material certifications for the release liner & web foam material was reviewed; material met product specifications and no issues or abnormalities were identified that may have contributed to the issue of necrosis.The adhesive gel formulation is proprietary but consists of 20-35% water, 32-47% glycerin, 25-35% polyacrylate copolymer, 0.5-4.5% salt (potassium chloride), and 0.1-0.6% catalyst system are the base properties to assist in determining whether there is any skin sensitivity or allergies.The hydrogel formulation was reviewed and verified the gel was made accordingly and met the specification requirements.Since this complaint is unconfirmed and no complaint trend exists, no corrective action is required at this time.This complaint will be recorded for tracking and trending purposes.
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