Regulatory Open Forum

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  • 1.  Retention samples for medical devices

    Posted 15-Nov-2021 10:51
    Does anybody knows if there are official FDA requirements for retain samples for Medical Devices like for the pharmaceutical industry?

    Thanks in advance!



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    Malin Kylberg
    Director QA & RA
    Skutskär
    Sweden
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  • 2.  RE: Retention samples for medical devices

    Posted 16-Nov-2021 09:39
    Good day Malin,

    There is no specific requirement for retention of samples for medical devices; you will often find this type of information more related to pharmaceutical products (GMP).  This is left up to each medical device manufacturer based on type of device, though there are some guidance documents from different regulators which talk around this.  Manufacturers can determine this need: depending on the medical device a retain sample per lot/batch would be made for future complaint investigation or future evaluation such as needed for design activities or manufacturing review.  Working for a few companies we would take a small statistical sample of units from a lot/batch of product which would be maintained based on the shelf life or expiration date.  This does take physical space as well and needs to be managed.  I worked for an IVD company where we maintained retain samples for planned shelf life extension activities (real time aging), complaint investigation, and also evaluation of samples at defined periods of time within the expiration date for our own data analysis.  The closest regulatory requirement probably you would find is ISO 13485 Section 7.1(d) where (planning) evidence of realization of processes and results are maintained.  Of course there is quite an interpretation and stretch applied to retention samples, but unfortunately I have seen audit observations for not retaining samples before.  Also note under EU MDR, as an example, Notified Bodies may request samples of product so it would be helpful to have some samples available (US FDA can do this as well).

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 3.  RE: Retention samples for medical devices

    Posted 16-Nov-2021 10:12
    Dear Richard,

    This was very useful answer and guidance on the requirements and intresting that the guidance for retention samples is so different for Medical Device and Pharmaceuticals.
    Kind regards,
    Malin 


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    Malin Kylberg
    Director QA & Regulatory Compliance
    OssDsign
    Uppsala
    Sweden
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  • 4.  RE: Retention samples for medical devices

    Posted 17-Nov-2021 09:11
    It's not required in medical device like it is in pharma; you may choose to do so for risk mitigation purposes - stability, complaint investigations, etc. 

    Also consider customer requirements; some may require you to retain samples.

    Cred: Sr. QA manager at a plant producing both devices and OTC drugs.

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    Joshua Lust
    RiskMitigated.com
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  • 5.  RE: Retention samples for medical devices

    Posted 17-Nov-2021 09:20

     

     

     

    Just one small qualification that for GLP testing of medical devices you should consider the applicable requirements for retained samples.  See 21 CFR 58.

     

    Best regards,

     

    Ted

     

     

     






  • 6.  RE: Retention samples for medical devices

    Posted 18-Nov-2021 03:31
    Thanks Ted for your input on extra considerations needed for GLP studies!

    Kind regards,
    Malin

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    Malin Kylberg
    Director QA & Regulatory Compliance
    OssDsign
    Uppsala
    Sweden
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  • 7.  RE: Retention samples for medical devices

    Posted 18-Nov-2021 03:30
    Thanks Joshua for your guidance!

    We are then on track with how we are acting on retention samples.

    Have a nice day!

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    Malin Kylberg
    Director QA & Regulatory Compliance
    OssDsign
    Uppsala
    Sweden
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  • 8.  RE: Retention samples for medical devices

    Posted 18-Nov-2021 10:45
    We retain samples from each DHR. The main reason is to handle complaints. A user makes a complaint about the product we shipped 18 months ago? Let's pull those samples and test them and make investigations easier to justify.

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    Edward Panek
    VP, QA/RA
    Med Device
    USN Veteran
    Research into Neural Nets - https://www.twitch.tv/edosani
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  • 9.  RE: Retention samples for medical devices

    Posted 19-Nov-2021 02:26
    Thanks for your response Ed!

    This is also the way we will handle the retention samples.

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    Malin Kylberg
    Director QA & Regulatory Compliance
    OssDsign
    Uppsala
    Sweden
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