Hi Rashmi:
Who did the unauthorized repairs? The customer, your company, or someone else? That makes an impact on what is required. Additionally, do you make it clear that repairs are not allowed? If so, where do you make this statement (e.g. IFU). If you knew that repairs were happening in the past, what were your actions to mitigate? What is the design life of this device?
If you "got the devices back to the original design", this sounds like a correction to me. If you need them back at your company to conduct this, then it would be a correction and removal.
It's hard to answer your questions(s) without more detail.
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Michael Winter RAC
Sr. Director, Quality and Regulatory Affairs
Curbell Medical
Orchard Park NY
United States
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Original Message:
Sent: 07-Nov-2018 06:08
From: Rashmi Pillay
Subject: Unauthorised repair ,adverse event and recall
Hi,
This is with reference to some devices sold almost 14 years ago. 5 years ago , during servicing, the service technician conducted some unauthorised repair which probably led to an event 2 weeks ago (adverse event?) , no serious injury caused but could have the potential to cause one . In this case , there was no device fault , our investigation in the past have the evidence that no repair /changes were applicable to this design. Will this qualify as an adverse event ?
After 14 years it's difficult to trace which devices would have undergone such unauthorised repair.
Should we handle such cases as they come or do we need to get the status of devices sold during this time and get the service history?
Also if we got the devices back to its original design , would this amount to a recall ?
Thanks & Regards,
Rashmi Pillay
Regulatory Affairs Associate
Ellex
3-4 Second Avenue
Mawson Lakes SA, 5095
T + 61 8 7074 8105
E rpillay@ellex.com
W ellex.com
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