This mdr was generated under protocol (b)(4), as a result of warning letter cms# (b)(4).A device history record (dhr) review was conducted which indicated all inspections were completed and no issues were noted during manufacture.A product sample was received for evaluation.Visual and functional testing were performed.The samples were visually inspected, at a distance of 12 to 24 and normal conditions of illumination.All the samples were received with the skin adhesive stuck on the white cap, one (1) sample was received without the base and cannula.The sample received with the base and cannula was tested using a buckle assembly taken from the production line to replicate the failure mode.No leaks were detected in the samples.A review of the manufacturing process for was conducted by quality engineer in order to verify that there are no situations or practices that could create the event.No discrepancies were found.The root cause of the reported event was found to be excessive voids in the static bond on the patch, which may be inherited in the raw material or created during conversion and/or assembly processes.Incoming lots are inspected and reword process are in place to ensure the patch lifted above 0.030 are reworked.A new inspection fixture was designed and developed to decrease that measurement variability to 0.005.The inspection fixture was improved under the procedure to accurately determine whether our product meets the 0.030 lift acceptance criteria.A new packaging configuration was implemented which the cleo devices are stored in a cap up orientation.A corrective and preventative action has been opened to address the reported issue.
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