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Definition of Correction

  • 1.  Definition of Correction

    Posted 24-Oct-2018 11:41
    I'd like to get some opinions of how to address the FDA versus ISO definition of correction.  FDA defines correction as "the repair, modification, adjustment, relabeling, destruction, or inspection (including patient monitoring) of a device without its physical removal from its point of use to some other location".  ISO defines a correction as "an action to eliminate a detected non-conformity".  During an FDA inspection, the FDA made a big deal about the definition of correction not being the exact FDA definition, however, during an ISO registrar audit, they want to see the ISO definition.  How do you make both organizations happy?

    Hoping to start a conversation about this here. Thanks!

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    Melinda
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  • 2.  RE: Definition of Correction

    This message was posted by a user wishing to remain anonymous
    Posted 24-Oct-2018 14:34
    This message was posted by a user wishing to remain anonymous

    You are operating under the regulated industry so the FDA should have a final say!


  • 3.  RE: Definition of Correction

    Posted 25-Oct-2018 09:37
    Can't say I agree with that completely. Yes, for a US company the temptation is always to let FDA "win" if only to limit criminal liability. But...

    what if your company is located OUS and FDA has limited authority?
    what if the majority of your sales are in a market that uses ISO 13485 rather than 21CFR820?
    how would this all work in an MDSAP audit?

    I think we, as regulated industry, have to ask the questions and wrestle with best practices as to the answers. Hopefully this will get resolved as FDA tries to move to ISO 13485 (they would seemingly have to tweak definitions somewhere and not have opposing ones actually in the CFR) but that will take a while. In the meantime it would be interesting to see how others are dealing with this.

    g-

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    Ginger Glaser RAC
    Chief Technology Officer
    MN
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  • 4.  RE: Definition of Correction

    Posted 25-Oct-2018 02:41
    Hi Melinda,

    My method for resolving this is to maintain a controlled Quality System Glossary that contains all of the pertinent definitions from the different regulations and standards that are applicable to the organization's products, with citations to the source external documents. There are many terms that have different definitions in different regulations and standards.

    For medical devices, the fact that definitions in applicable regulatory requirements differ from nation to nation and region to region is acknowledged in the Introduction to ISO 13485:2016 in clause 0.1 General. It is pointed out that the organization needs to understand how the various definitions will be interpreted depending on the jurisdictions in which the devices are made available.

    So my solution is to list the various definitions (with specific citations) in the Quality System Glossary regardless of how they may be <g class="gr_ gr_693 gr-alert gr_gramm gr_inline_cards gr_run_anim Grammar only-ins doubleReplace replaceWithoutSep" id="693" data-gr-id="693">conflict</g> with one another. See example below for MANUFACTURER.

    MANUFACTURER: A natural or legal person who manufactures or fully refurbishes a device or has a device designed, manufactured or fully refurbished, and markets that device under its name or trademark.

    Europe MDR

    MANUFACTURER: A person who sells a medical device under their own name, or under a trade-mark, design, trade name or other name or mark owned or controlled by the person, and who is responsible for designing, manufacturing, assembling, processing, labeling, packaging, refurbishing or modifying the device, or for assigning to it a purpose, whether those tasks are performed by that person or on their behalf.

    Canada SOR/98-282

    MANUFACTURER: Any person who designs, manufactures, fabricates, assembles, or processes a finished device. <g class="gr_ gr_761 gr-alert gr_gramm gr_inline_cards gr_run_anim Grammar only-ins replaceWithoutSep" id="761" data-gr-id="761">Manufacturer</g> includes but is not limited to those who perform the functions of contract sterilization, installation, relabeling, remanufacturing, repacking, or specification development, and initial distributors of foreign entities performing these functions.

    USA 21 CFR 820

    MANUFACTURER<g class="gr_ gr_1000 gr-alert gr_gramm gr_inline_cards gr_run_anim Style replaceWithoutSep" id="1000" data-gr-id="1000">:</g><g class="gr_ gr_1000 gr-alert gr_gramm gr_inline_cards gr_disable_anim_appear Style replaceWithoutSep" id="1000" data-gr-id="1000">See</g> standard since I am not stating it here due to copyright concerns.

    EN ISO 13485

    MANUFACTURER: See standard since I am not stating it here due to copyright concerns.

    EN ISO 14971

    MANUFACTURER: The natural or legal person with responsibility for the design, manufacture, packaging <g class="gr_ gr_752 gr-alert gr_gramm gr_inline_cards gr_run_anim Punctuation only-ins replaceWithoutSep" id="752" data-gr-id="752">and</g> labeling of a device before it is placed on the market under his own name, regardless of whether these operations are performed by that person himself or on his behalf by a third party.

    Europe MDD



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    Sam Lazzara
    Fremont CA & Las Vegas NV
    https://mdqc.blog/
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  • 5.  RE: Definition of Correction

    Posted 25-Oct-2018 07:56

    The issue here is two different applications that happen to share the same English word.

     

    The FDA definition you cited is from Part 806 where correction is one type of action to modify a device after it is shipped. If the event is reportable under 806.10 then you must classify the action as a correction, a removal or both, since they are encoded in the report number.

     

    The ISO definition you cited is the name for a family of dispositions of nonconforming product. In general, there are three dispositions: scrap, correction, and use-as-is (which ISO terms as concession). You may also consider return-to-vendor, but that just moves the disposition decision. There are three types of correction: repair, rework, and regrade.

     

    Both types of correction need to be in your QMS with the appropriate definition. However, the terms have a context, which you need to include. In the one case, correction applies to products that have been shipped while in the other case correction (usually) applies to product in the manufacturing process.



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    Dan O'Leary
    Swanzey NH
    United States
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  • 6.  RE: Definition of Correction

    Posted 25-Oct-2018 09:33
    This is actually a big deal. Why? In a recent FDA inspection, the inspector kept applying 806 whenever we talked about a "correction" in the ISO sense in our documentation (primarily CAPA documentation). This led to a lot of tension and confusion. We haven't completely determined how to deal with it yet, but we are thinking of updating our "definitions" SOP to define both (called out as US and ISO) but giving each a "nickname" or acronym that we can use when referring to them elsewhere in our QS. Hopefully, while it will still lead to a little explanation, it will limit the over-reaction about "corrections not being reported."

    g-

    ------------------------------
    Ginger Glaser RAC
    Chief Technology Officer
    MN
    ------------------------------



  • 7.  RE: Definition of Correction

    This message was posted by a user wishing to remain anonymous
    Posted 25-Oct-2018 17:07
    This message was posted by a user wishing to remain anonymous

    Would it not be clearer if the FDA term "correction" was always proceeded by the word "field"? As previously pointed out, it refers to 806 related activities for product that is in the field. That would create a clear distinction between it and the nonconformance/CAPA definition of "correction".


  • 8.  RE: Definition of Correction

    Posted 26-Oct-2018 10:26
    In our case, it was. But the inspector got hung up on "corrections" in our CAPAs, where the term is used in the ISO sense. It took a lot of convincing to get them to the point that it was not the same as our "field corrections"

    g-

    ------------------------------
    Ginger Glaser RAC
    Chief Technology Officer
    MN
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  • 9.  RE: Definition of Correction

    Posted 27-Oct-2018 10:11

    In Part 806 there are definitions of correction and removal that relate to changing devices in the field.

     

    The correction term from ISO 9000:2015 typically applies to disposition of nonconforming product. There are three types of correction – repair, rework, and regrade. In my experience, most companies don't use the word correction. Instead, they go straight to the type of correction. This approach could resolve the issue. However, this seems wrong to me, since it is driven by one FDA Investigator's failure to understand.

     

    This raises the question, is it just one FDA Investigator? It would be useful if the people who have experienced this issue were to tell us which Investigator raised it. If it is one person in all instances, that would be a different problem from multiple Investigators across the field organization (since there are no longer Districts). If Investigators are receiving training that results in the incorrect application of the term, that could result in a major issue.

     



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    Dan O'Leary
    Swanzey NH
    United States
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  • 10.  RE: Definition of Correction

    Posted 27-Oct-2018 16:10
    Edited by Kevin Randall 27-Oct-2018 16:20
      |   view attached

    Remember that the U.S. FDA uses the term "correction" in two different ways depending on the context. But because there is somewhat of a Venn diagram relationship between the two ways (more about that in a moment), the issue can become confusing.  Therefore, it is important that you keep these distinctions clear in your QMS and thus in your dealings with FDA investigators (and ISO assessors).

     

    Also noteworthy is that in the various FDA inspections I've overseen in the last couple years, I'm seeing more young new investigators at FDA rather than the more tenured pillars that have been fixtures in times past. So be patient with your FDA investigators, and diplomatically explain the differences in the way "correction" is used in your QMS.  In doing so, also be prepared to show the FDA that the way you're doing it is in fact based on the FDA's own long-standing precedents.  Then in addition, be ready to leverage the close overlaps that now exist between FDA's 21 CFR concepts/definitions vs. ISO 13485:2016.

     

    Given below is some additional commentary expanding on my preceding points.

     

    The Venn-type diagram provided below (and/or attached) illustrates FDA's two-fold usage of the term "correction":

     Correction vs. Correction

     

    Remember that FDA's original intent for 21 CFR Part 820 was to model it and its terminology after the essence of ISO 9001 and ISO 13485. For example, in the Part 820 preambles, FDA states, "…it would be beneficial…for the CGMP regulation to be consistent, to the extent possible, with…ISO 9001:1994…and the ISO committee draft (CD) revision of ISO/CD 13485…"  FDA also stated, "…the most appropriate approach to developing device CGMP regulations equivalent to the quality system specifications in ISO 9001 is to…use similar terminology where appropriate…" Although the aforesaid versions of ISO 9001 and ISO 13485 are superseded by later versions, the essence of FDA's intentions for synergy between ISO 9001/13485 and 21 CFR 820 still remain; especially as evidenced by ISO 13485:2016 (now more similar than ever to 21 CFR 820).

     

    The term "correction" used in the context of FDA 21 CFR 820.100(a)(3) (general corrective/preventive action) is a great example of where FDA uses "similar terminology [to ISO] where appropriate".  There is copious evidence of FDA doing this with the term "correction". For example, FDA's public QSIT workshops for industry for the CAPA subsystem defined "correction" as repair, rework, or adjustment relating to the disposition of an existing nonconformity. This is the identical definition from ISO (by original way of ISO 8402 now replaced by ISO 9000 and its synonymous definition "action to eliminate a detected nonconformity" recited above by Melinda). This same definition was also used in this context by FDA in its c. 2012 CAPA overview presentation by Kimberly Lewandowski-Walker.  And in Joe Tartal's FDA CAPA presentation from 2014, FDA defined correction using the aforesaid updated ISO 9000 definition.  Also noteworthy is that the IMDRF (GHTF) defines correction in this way too, and the GHTF has for some time been a favorite resource and venue for FDA to assert its perspectives.  So we use this form of "correction" when correcting nonconforming product, processes, or quality systems.  As a side note, the term "correction" does not appear in 21 CFR 820.90 (nonconformity product), which instead only refers to "disposition" where one type of disposition could be a correction (such as rework) taken under 21 CFR 820.100.  To avoid additional confusion, it is important that these demarcations between adjacent quality subsystems be clearly delineated in your QMS.

     

    In contrast to the 21 CFR 820.100 / ISO 9000 versions of correction, when FDA instead uses the term "correction" in the context of 21 CFR Parts 7 and 806 (i.e., in the context of recalls and recall reports), then FDA applies the definition from 7.3(h) and 806.2(d). This type of correction is specifically intended to address corrections of marketed products that are in violation of FDA law to such a degree that FDA would take legal action if needed to resolve the issue.  This is the reason for FDA's sensitivity about this term in the context of recalls and the consequent need for firms to use and define it appropriately, including proper distinction from the aforementioned more general type of correction in the larger context of 820.100.

     

    But remember once again the Venn-type diagram relationship between the two types of correction. The key to avoiding confusion and keeping FDA and your ISO registrars happy is by clearly showing this relationship in your QMS documentation and also being able to articulate that your approach is based on long-standing harmonized precedent.  Such an approach tends to keep your newer/younger FDA investigators in check and in sync with your logic.  And once you've properly articulated the foregoing relationship between FDA and ISO terminology, your ISO assessors should also be satisfied.  Therefore Sam Lazzara's comments are wise indeed about handling the different definitions pursuant to ISO 13485:2016 clause 0.1 (and clauses 2 and 3).

     

    Hope this helps.

    ------------------------------
    Kevin Randall, ASQ CQA, RAC (U.S., Canada, Europe)
    Principal Consultant
    ComplianceAcuity, Inc.
    Golden CO
    United States
    www.complianceacuity.com
    © Copyright 2018 by ComplianceAcuity, Inc. All rights reserved.
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  • 11.  RE: Definition of Correction

    Posted 27-Oct-2018 17:13

    The problem originates with the author of 820.100 who, in my opinion, didn't understand the difference between corrective action and preventive action. This leads to the abomination "CAPA" in which two different processes CA and PA are jammed together as if they were one. Eventually the GHTF disavowed this approach in GHTF/SG3/N18:2010 Quality Management System –Medical Devices – Guidance on Corrective Action and Preventive Action and Related QMS Processes with the statement, "The acronym 'CAPA' will not be used in this document because the concept of corrective action and preventive action has been incorrectly interpreted to assume that a preventive action is required for every corrective action."

     

    I parse 820.100(a)(3) (Identifying the action(s) needed to correct and prevent recurrence of nonconforming product and other quality problems) into four constituent parts:

     

    Identify action to correct nonconforming product

    Identify action to correct other quality problems

    Identifying action to prevent recurrence of nonconforming product

    Identifying action to prevent recurrence of other quality problems

     

    The concern is that there should have been a different set of constituent parts. The first two are misplaced. The missing ones are:

     

    Identifying action to prevent occurrence of nonconforming product

    Identifying action to prevent occurrence of other quality problems

     

    The wording in 820.100(a)(3) appears to cover correction and corrective action and doesn't include preventive action. I believe, in the context of the misunderstanding, "correct" was incorrectly used for corrective action and "prevent recurrence" was incorrectly used for preventive action. (This is the warning from the GHTF.)

     

    There are three process to consider.

    Correction eliminates a detected non-conformity

    Corrective action eliminates the cause of a detected nonconformity

    Preventive action eliminates the cause of a potential nonconformity

     

    We also need to eliminate terms such as "root cause" (the worst instance is the "true root cause", implying we have been finding false root causes all this time) and "CAPA".

     

    My hope is that the plan from FDA-CDRH that QSR "revisions will supplant the existing requirements with the specifications of an international consensus standard for medical device manufacture, ISO 13485:2016" will address the issue.

     

    Unfortunately, I'm not confident that the plan to supplant (to eradicate and supply a substitute for – Merriam-Webster) QSR with ISO 13485:2016 will resolve the problem.

     

     



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    Dan O'Leary
    Swanzey NH
    United States
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  • 12.  RE: Definition of Correction

    Posted 28-Oct-2018 12:39
    Edited by Kevin Randall 28-Oct-2018 12:48

    Melinda's original question and the ensuing discussion about the two uses of "correction" are most interesting indeed.

     

    Dan's segue about CA vs. PA and general interpretations of 820.100 are also very useful and interesting (as Dan's comments always are) in the general sense and, based on past discussions in this and other forums, are likely to evoke a cascade of additional corresponding comments. For example, CA vs. PA and the GHTF's assertions about the acronym "CAPA" were previously covered in the following prior RAPS Forum discussion:

    https://connect.raps.org/communities/community-home/digestviewer/viewthread?MessageKey=be8ce976-8a70-4e7c-a8c6-6562adc3505f&CommunityKey=5af348a7-851e-4594-b467-d4d0983b6d89&tab=digestviewer#bmbe8ce976-8a70-4e7c-a8c6-6562adc3505f

     

    To assure Melinda's primary question and our discussion about "correction" are not lost or diluted, may I suggest that we start a new discussion or add to prior discussions to talk further about CA vs. PA or general interpretations of 820.100?  That would provide for better Forum archiving and search ability for future visitors.

     

    By the way, on the subject of Melinda's original question about the different uses of the term "correction", I thought of another resource that would be very useful in reminding FDA investigators about the agency's long history of distinguishing the two aforementioned kinds of correction. Specifically, FDA's QSIT guide (the guideline for the inspection technique FDA investigators are generally supposed to use) also draws the aforesaid distinction between the two types of correction.  Specifically, the bottom of page 50 shows FDA (in the context of 820.100) utilizing the form of correction aligning with the ISO definition (i.e., the outer aspect of my Venn diagram) and seems to also show FDA trying to be cognizant of an organization's specific definition and usage of "correction".  In contrast, page 67 starts the section of the QSIT where FDA approaches "correction" in the context of 21 CFR 806.

    ------------------------------
    Kevin Randall, ASQ CQA, RAC (U.S., Canada, Europe)
    Principal Consultant
    ComplianceAcuity, Inc.
    Golden CO
    United States
    www.complianceacuity.com
    © Copyright 2018 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------