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Samples received by shm: the samples consist of five (5) products.Four (4) samples were received in unused conditions without their original package and one (1) sample was received in used condition without its original package.Visual inspection: the samples were visually inspected, at a distance of 12? to 24? and normal conditions of illumination.Results: four (4) samples has the retractor inactive in unused conditions.One (1) sample has the cannula broken.Other analysis due to the fact there was no lots were programed to be manufactures in the near future, a review of the manufacturing process for them was conducted by quality engineer on (b)(6) 2019 in order to verify that there are no situations or practices that could create the event as described in ?description of non-conformance?.Both part numbers belong to the cleo product family and are manufactured with the same process, procedures and controls.However the one has a 42? buckle while the other has a 24? buckle.During the verification the following operations were reviewed: line clearance record was reviewed; no discrepancies were observed.Inserter assembly operation was audited by the quality engineer and it was performed by the production personnel according to the manufacturing procedures.Training records were reviewed, operators are trained on operation been performed.Maintenance records from ?site threader? machine were reviewed; no anomalies were detected.Functional test was performed as follows: three (3) samples were taken from cleo production line and tested; after removing the white cap the site was inserted into the insertion pad.The inserted cannula was twisted around and pulled from the insertion pad, in neither of the worse test cases produced can cause the cannula to brake or detach.Results: no detachment was detected in any of the tested samples and the cannula was not remove from the site.Mitigation: the retractor assemblies are 100% visually inspected by the production personnel to assure that the needle is properly threaded.Qc performs an in process audit at 1 hour intervals to verify that needle is properly threaded on the retractor assemblies.Root cause: the customer reported: ?while removing the needle, short tube was no longer palpable? in order to perform a complete root cause analysis of this failure mode, corrective and preventative action was open on (b)(6) 2017.Action taken: corrective and preventative action was open on (b)(6) 2017 in order to implement corrective actions for this failure mode.This remediation mdr was generated under protocol (b)(4), as a result of warning letter cms# (b)(4).
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