Update to h6 type of investigations, investigation findings and investigation conclusions added and h10 per no product investigation completion.As no device was returned for evaluation, no visual inspection, functional testing or dimensional testing could be performed.Imagery was reviewed.Annular area and average diameter measured at 328.8 mm2 and 20.6 mm, respectively, indicative of an over-sized 23mm thv, likely implanted to facilitate a better grip against the calcium-free annulus.No calcium deposits were noted on the annulus, which appeared to be somewhat irregular in shape.The reported event does not allege a malfunction that could be related to an edwards manufacturing deficiency.Therefore, no device history review and lot history review was required.As no device was returned and there is no evidence to support a manufacturing/design defect potentially contributed to the complaint, a manufacturing mitigation review is not required.It should be noted that the thv was deployed in native aortic position to treat aortic insufficiency.Review of provided imagery revealed no indication of annular calcification but disclosed small annular dimensions relative to thv sizing election (implantation of an over-sized thv can be used to over-compensate for the absence of calcium through improved gripping forces).Based on this information, it is likely that the thv was implanted in a calcium-free landing zone.The sapien 3 ultra (s3u) thv with the commander delivery system (ds) is currently only indicated for valve replacement involving native calcific aortic stenosis as well as replacement of a failing surgical or transcatheter bioprosthetic aortic valve, a surgical bioprosthetic mitral valve, or a native mitral valve with an annuloplasty ring.Therefore, this was off-label operation.The ifu and training manuals in this section are for tf (transfemoral) procedure in aortic/mitral position and were reviewed for relevant guidance for an s3 implant using a commander ds.No ifu/training deficiencies were identified.Implantation of thv in a non-calcified native aortic annulus using the sapien 3 ultra (s3u) valve with the commander delivery system (ds) is not an indicated use of the device.The risk management file captures risks for indicated device use only.The review of the risk management file is completed, and no further action is required at this time.The migration and embolization were unable to be confirmed due to unavailability of medical record/applicable imagery.The reported event does not allege a malfunction that could be related to an edwards manufacturing deficiency.A review of ifu/training materials revealed no deficiencies.It should be noted that the thv was implanted within non-calcified native aortic annulus, which is not an indicated use of the sapien 3 ultra thv with the commander delivery system.Therefore, this was off-label operation.As reported, ''valve being implanted for ai - valve was deployed, closed & in the final stages of the procedure.Getting ready to remove tee prob & noticed that the valve had migrate into the lvot.Physician got access again & in the process of attempting to cross the valve it popped out into the lv''.Per the instructions for use (ifu), valve migration requiring intervention is a known potential adverse event associated with transcatheter valve replacement (thv).In this case, review of provided 3mensio revealed that patient lacked annular calcium, which is needed to provide secure anchoring for the valve.Despite deployment of an over-sized thv (as a likely attempt to enhance the gripping force), it is possible that the forces acting on the thv overcame the strength of valve attachment due to the absence of calcification, causing the thv to dislodge and move towards the ventricle.As such, available information suggests that procedural factors (off-label operation) may have contributed to the complaint event.Per the instructions for use (ifu), valve embolization is a known potential complication associated with the transcatheter aortic valve replacement (tavr) procedure.In this case, the thv migrated towards the ventricle due to lack of calcium, which would have led to further weakened attachment forces against the annulus.Subsequent manipulations by the physician, while attempting to cross the loosely attached valve, likely caused it to embolize into the ventricle as a result of the compromised anchoring.As such available information suggests that procedural factors (thv migrated) may have contributed to the complaint event.Since no device problem was identified affecting distributed product, no pra is required.Since no edwards defect, which could have resulted in the complaint, was confirmed, no preventative or corrective actions are required.The ifu and training manuals have been reviewed and no inadequacies have been identified with regards to warnings, contraindications, and the directions/conditions for the successful use of the device.Complaint histories for all reported events are reviewed against trending control limits on a monthly basis, and any excursions above the control limits are assessed and documented as part of this monthly review.
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