The event has been reported with a delay due to our retrospective examination of the record.At the time ((b)(6) 2017) the complaint was reviewed and found not to be reportable.Current day, we compared the record with equivalent events, and found an inconsistency with the reporting decisions.With the current knowledge and the current team of complaint handlers, we have come to conclude the event should have been reported.As a remedial effort, we will report it within capa # (b)(6).The product was not need for investigation in the laboratory of the manufacturer since the failure is known and already investigated.A review of the device history record was performed with no abnormality found.As a corrective action, related to the complaint, mcp capa (b)(6) had already been opened.Packaging of hls cannulae is currently made with medical paper pouch and needs to be changed with stronger material i.E.Tyvek and better plastic film with higher tear strength.The thickness of cardboard box is also need to be increased for higher rigidity since the cardboard box working both as a shelf box and a shipper box.Based on the capa (b)(6), the most probable root causes can be defined as: packaging instructions are insufficient and the training of the instructions were not successful.Product does not own a shipper box with optimum dimensions.There is no control point for packaging integrity after mcp tr till customer.No specific shipping procedure xpo to customer and no specific packaging procedure in xpo.Health hazard evaluation (hhe) has been performed for this capa ( (b)(4)).In summary of the hhe, the identified risk is formally justifiable for this device and issue because of the seldom or unlikely likelihood of occurrence of harm.Based on this, no field action has been performed ((b)(4)).According to the hls cannulae design verification report performed on (b)(6) 2016 ((b)(4)), verification outcome of shelf life test passed acceptance criteria no visible damages of the packaging to a critical degree for further improvement in the scope of capa, the ecr (engineering change request) with the number ((b)(4)) has been initiated to change the primary packaging of hls cannuale from medical paper to tyvek blister packaging.
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