During an internal audit, we have reviewed our complaint database and realized that we had missed reporting this near incident to the fda.As we have never supplied electrodes of that design (neonatal electrodes with a fixed lead) to the use so far, it was initially determined that the near incident was not reportable.However, the product is covered under an existing 510k and we therefore file this report.An investigation was performed to determine the likelihood of a re-occurrence.For this purpose retained lots of samples from each month of 2013 were examined.Some of the labels did not fully adhere to the electrodes over their entire surface.However, in each case force needed to be applied to tear the label from the electrode.The near incident was classified as a singular event with a very low repeat probability.No field action was initiated.In order to improve the design of the product, the specification of the label has been modified.Effective (b)(6) 2014, a soft foam material is used to replace the plastic film as a label on all neonatal and pediatric electrodes with fixed lead.This foam material adheres and conforms so well to the electrode and the lead that it cannot be separated from the electrode.
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