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Cook ireland ltd (manufacturer) is submitting this report on behalf of cook medical incorporated (cmi)(importer).Exemption number: e2016031.Information pertaining to section g.1 as follows: importer site contact and address: (b)(4) cook medical incorporated (cmi) 1025 acuff road p.O box 4195 bloomington indiana 47402-4195 importer site establishment registration number: 3005580113 1 x zso-7-10 of lot c1313077 was returned to cirl for an evaluation.During the lab evaluation it was determined that there were no anomalies on the device that could have contributed to the migration event.The pigtail anti-migration features were found to be correct/ as expected.There was evidence of damage noted on the duodenal end of the stent which is consistent with the removal of the stent.It was noted during the lab evaluation that the anti-migration feature (in this case the pigtails) should be placed just above the stricture and that the most probable root cause of this customer complaint could be attributed to incorrect size selection (both too short or too long for the stricture) could cause migration, or incorrect placement of the stent across the stricture which could also attribute to stent migration.It is also possible that the user used an incorrect method to place the stent or to remove the introducer components.However as the operational conditions of use could not be replicated in the laboratory setting, it is not possible to conclusively determine the root cause of the customer complaint.The customer complaint was confirmed based on customer testimony.As per instructions for use (ifu) : ¿this device is used to drain obstructed biliary ducts¿.As per a precaution included in the instructions for use for this device: ¿the tapered tip end of the stent* or side holes* must be positioned in the common bile duct while the other end remains in the duodenum.¿ step 6 of the ifu instructs the user "after confirming stent position, gently remove wireguide, then guiding catheter* from endoscope while maintaining position of stent with pushing catheter".Step 7 then instructs to "gently remove pushing catheter from accessory channel".It should be noted that stent migration is stated as a potential complication associated with the placement of zso devices in the ifu.Prior to distribution all zso devices are subjected to visual inspection and functional checks to ensure device integrity.There is also a visual inspection of the product and packaging at packaging, packaging qc, and post sterile qc.A review of the manufacturing records for the biliary stent device of lot c1313077 did not reveal any discrepancy related to the complaint issue.There is no evidence to suggest that this issue affects the entire lot # c1313077; upon review of complaints this failure mode has not occurred previously with this lot # c1313077.Prior to distribution, all zso--7-10 devices are subjected to 100% inspection to ensure device integrity.These inspections and functional checks are outlined in internal procedures in place at cirl complaints of this nature will continue to be monitored for potential emerging trends.
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