It was reported to philips that it was found that some symbols on device label and packaging label were not explained in the instructions for use (ifu).Additional information has been requested.The efficia dfm100 defibrillator, model# 866199, is substantially similar to the heartstart xl+ defibrillator (model # 861290) and will be reported in the united states under device model # 861290.
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This report based on potential safety and/or compliance issues related to philips distributed products.The scope of this assessment is symbols on the dfm100 product label [ref-02] and dfm100 packaging label [ref-03] not defined in the dfm100 ifu symbols glossary.Complaint and distribution data from other philips products were not included in this assessment.The labeling non-conformance related to safety, efficacy, quality, or regulatory requirements.During the internal review in als product label localization project [ref-10], it was found that some symbols on the dfm100 product label [ref-02] and packaging label [ref-03] were not defined in the dfm100 ifu symbols glossary [ref-04].The symbols that convey directions for use are not defined in dfm100 ifu [ref-04] symbol glossary.Therefore, the device may be used in a way or in an environment that the device is not indicated for.This may cause the device to fail in clinical use and lead to a delay in or no therapy.There is also a regulatory non-compliance for this issue because this fails iso 20417 [ref-05] sub-clause 6.1.3 f) requirement: ¿if the label includes symbols or safety-related colors, they shall be explained in the instructions for use.¿ although, the dfm100 ifu [ref-04] conveys these directions for use elsewhere in the ifu without the use of the symbols.See appendix 1 for excerpts.Since the symbols that convey instructions for use are not defined, the device may be used in a way or in an environment that the device is not indicated for.This may cause the device to fail in clinical use and lead to a delay in or no therapy.There were no complaints, the worst-case severity was chosen based on the hazard.Saf-37, env-06, env-01, and mon-30 all have a maximum severity of s3.Therefore, s3 will be selected as the severity level for all possible complaints.Dfm100 ifu [ref-09] is proto-release status for revision min edmr, the missing symbol definitions are updated.
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