Regulatory Open Forum

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  • 1.  Complaints -accessory

    Posted 30-May-2018 02:27

    Hi,

     

    If there's been a complaint because of failure of an optional accessory ( not manufactured or distributed by us) used on our systems, who is responsible for the complaint handling ? If its determined as an adverse event who has the responsibility of reporting ? If the device has crossed its service life , then do it's complaints  need to be evaluated by the manufacturer ?

     

    Thanks & Regards,

     

    Rashmi Pillay
    Regulatory Affairs Associate


    Ellex 

    3-4 Second Avenue

    Mawson Lakes SA, 5095

     

    T + 61 8 7074 8105
    rpillay@ellex.com

    W ellex.com

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  • 2.  RE: Complaints -accessory

    Posted 31-May-2018 12:06
    Complaints need to be addressed by manufacturer or third party contracted site as per quality agreements that has been made. If its labeled to use with the optional accessories than only manufacturer knows or having knowledge of its application/use.

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    Gaurang Bhavsar, MS, RAC
    Manager, R&D and RA
    Sunrise Pharmaceutical, Inc.
    Rahway, NJ 07065
    USA
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  • 3.  RE: Complaints -accessory

    This message was posted by a user wishing to remain anonymous
    Posted 31-May-2018 16:14
    This message was posted by a user wishing to remain anonymous

    And if they were also distributing the accessory would that make any deference ?


  • 4.  RE: Complaints -accessory

    Posted 31-May-2018 15:14
    Edited by Vidya Jayaraman 31-May-2018 15:38
    I'm interested in knowing how you receive complaints on these optional devices, if you don't manufacturer or distribute them. Are you listed as the manufacturer/contact on the packaging?

    To answer your question - Does your IFU state use of this optional device? if it does- that ties it to the safety & performance of your own device and you must first report to the manufacturer know even though you don't distribute it.

    As per 21 CFR 803, "If you are a manufacturer or importer, you must report deaths and serious injuries that your device has or may have caused or contributed to, you must report certain device malfunctions, and you must establish and maintain adverse event files."
    Based on your complaint handling procedures, if the failure of the optional device contributed to failure/malfunction of your own device, you must also report to regulatory body and determine the need for MDR. Your investigations could be dependent on the investigations of the 510k/CE cert owner of the optional device.

    If the device was used within its service life but now has passed it, the owner of the 510k/CE cert would still have to investigate & if needed report. Retrospective reporting is not uncommon.

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    Vidyalakshmi Jayaraman
    RA Specialist
    Marlborough MA
    United States
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  • 5.  RE: Complaints -accessory

    Posted 04-Jun-2018 00:08
    ​Thanks for your response , yes the IFU mentions the optional accessory , not sure about the labelling 11 years ago, but currently we do mention ourselves as the distributor for such accessories once sourced from us.

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    RashmiAdelaideAustralia
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