The initial 30-day fda 3500a report cited (b)(6) 2016 as the date of event (mm/dd/yyyy) and date received by manufacturer (mm/dd/yyyy).Investigation of this complaint determined the actual date of event (mm/dd/yyyy) and date received by manufacturer (mm/dd/yyyy) is 12/14/2016.The root cause of the sub-optimal tissue processing reported by the complainant was using ethanol with a concentration of 69.7% from bottle 3 for the final dehydration step of the "factory 2hr xylene standard" protocol comprising 92 cassettes, which started in retort a at 17:51pm on (b)(6) 2016 and completed at 06:00am on (b)(6) 2016.The minimum final reagent concentration required for ethanol is 98%.The consequences of using reagent at a concentration less than the minimum required for the final dehydration step in a protocol is re-introduction of water into the tissue which cannot be displaced in subsequent processing steps; and contamination of reagents used in the subsequent processing steps, ultimately resulting in sub-optimal tissue processing.The reagent in bottle 3 was replaced and the properties of the corresponding reagent station reset at 17:48pm on (b)(6) 2016.Bottle 3 was subsequently scheduled for use for the first time in the final dehydration step of the "factory 2hr xylene standard" protocol started in retort a at 17:51pm on (b)(6) 2016.Although the measured ethanol concentration in bottle 3 was 69.7% following completion of this protocol, the ethanol concentration in bottle 3 calculated by the instrument software was 100%.This finding indicates that a user had filled bottle 3 with 70% ethanol when the default concentration configured for this bottle was 100%.Investigation showed it was likely that the user filled bottle 3 with 70% ethanol because prior to replacement of the hard disk drive (hdd) on (b)(6) 2016, the configuration of the reagent stations had been customized such that bottles 3 and 4 were designated as 70% ethanol.The hard disk drive (hdd) in this instrument had been replaced by a leica field service engineer on 09 november 2016, because it had failed.The instrument configuration at the completion of this service activity was the manufacturer default for xylene processing ie.Bottles 1 and 2 designated as formalin; bottles 3-10 inclusive designated as ethanol; bottles 11-14 inclusive designated as xylene, bottle 15 designated as cleaning ethanol and bottle 16 designated as cleaning xylene.The default concentration for all bottles and waxes in the manufacturer configuration is 100%.However, it was not identified that prior to replacement of the hdd the configuration of the reagent stations had been customized such that bottles 3 and 4 were designated as 70% ethanol, which meant that the default concentration for these bottles was 70%.
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Information provided by the complainant to a leica field support specialist (fss) indicated that the tissue samples exhibiting sub-optimal processing were derived from a "factory 2 hr xylene standard" protocol which started on (b)(6) 2016 and completed at 06:00am on (b)(6) 2016.The affected tissue samples were described as "horrendous to cut"; and were noted to be shrinking in the blocks.Information as to whether medical intervention was required to preclude permanent impairment of a body function or permanent damage to a body structure; and an identifier, gender and age or date of birth for each of the two (2) cases for which a definitive diagnosis could not be made, has been sought.
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