Regulatory Open Forum

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  • 1.  Device servicing and Part 806

    Posted 14-Feb-2017 17:28
    I am curious as to other's experience with this issue.  In regard to many electro-mechanical devices or capital equipment, unscheduled servicing may be required to resolve a problem with a specific device.  This servicing may involve replacement of a component or assembly.  The service event affects only a single device in order to get the device operational.  Would you consider this to be routine servicing (21CFR 806.2(k))? If not. would you evaluate each service event for 806 reportability?  Would you report (or maintain the necessary documentation for) individual service events under part 806?  Keep in mind that some products with a huge install base have thousands of service events each year. I am interested in your perspectives.  Thanks in advance.

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    Peter Ohanian RAC
    Principal Consultant
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  • 2.  RE: Device servicing and Part 806

    Posted 15-Feb-2017 08:58
    In my opinion, you definitely have to assess for 806 reportability and document why the service was made. If the service was unscheduled then it does not seem like a routine service. The work may be routine, but not the reason for it.

    Even if this particular service did not trigger 806 reportability, you have to keep records for trending, which you have to periodically evaluate for increased rates of failure, problems you have previously not seen, or for any changes to the device's risk profile (e.g. higher probability that could push the risk to unacceptable level, a new hazard or an even in the sequence of events not previously identified, etc.).
    This is not an exhaustive list, just a few examples.

    Many companies get in trouble with the FDA for not documenting and evaluating their service records, especially the "routine" ones.

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    Michael Zagorski RAC
    Pittsburgh PA
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  • 3.  RE: Device servicing and Part 806

    Posted 15-Feb-2017 09:16
    And don't forget about evaluation for MDR's.  Lots of warning letters on this topic.  Complaints, MDR, Service and 806 all need to be thought about.

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    Rick Muller RAC
    Technical Director
    Celestica Healthcare
    Aurora CO
    United States
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  • 4.  RE: Device servicing and Part 806

    Posted 15-Feb-2017 10:29

    There are a number of issues here, so let me break them out.

     

    There are typically two kinds of maintenance – preventive and corrective. Corrective maintenance is not scheduled and is what I infer you mean by “unscheduled servicing”. Technically, under 806.2(d), this is a correction – a repair made at the equipment’s location.

     

    The second question is whether the correction is reportable. Determine if the repair was made to reduce a risk to health or to remedy a violation of the act, see 806.10(a). If so then it is reportable unless it falls under one of the four exceptions: improve quality, market withdrawal, routine servicing, or stock recovery.

     

    The third question is where to keep the records. All servicing records must be created and maintained following 820.200. If you don’t report under an exemption, create the records required by 806.20. The data elements in the two records are different, so you would need both.

     

    Under 820.200(b), analyze the service records using appropriate statistical methodology in accordance with §820.100. If you find a high overall failure rate, then you have to remedy the problem. The replacements become reportable. They are not routine servicing and, because the device does not meet its performance requirements the failures are a violation of the act.

     

    See the guidance document, Distinguishing Medical Device Recalls from Medical Device Enhancements.



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    Dan O'Leary
    Swanzey NH
    United States
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  • 5.  RE: Device servicing and Part 806

    Posted 15-Feb-2017 11:17
    Thanks Dan.  I appreciate the response.  To clarify, are you indicating that corrective maintenance performed on a single device, lets say to replace a display that will not power on, should be evaluated for part 806 reportability? I agree that this is not "routine servicing" and is technically a correction.  Do you think that this is what FDA really intended with part 806?  I can understand if there is a trend of failures of this nature that a corrective action should be considered.  However, do one-off device failures requiring corrective maintenance also require part 806 documentation?  This is truly a game changer for equipment manufacturers!

    BTW, I strongly endorse that every service event be evaluated for MDR reportability as well as complaint determination.  Most corrective maintenance events are most likely also a complaint.  From my experience, failure trends and need for potential field corrective action is best driven through the complaint and CAPA process.

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    Peter Ohanian RAC
    Principal Consultant
    Halloran Consulting Group
    Windham NH
    United States
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  • 6.  RE: Device servicing and Part 806

    Posted 15-Feb-2017 14:02

    Should corrective maintenance performed on a single device be evaluated for reportability?

    A strict reading of the regulation would say yes, but I’ve never seen it done, nor seen a Warning Letter. The reportability criteria (reduce risk to health or correct a violation) are seldom met. In addition, I would suggest that these kinds of failures are “routine servicing” because they fall under “normal wear and tear”. (I would like to avoid the discussion of electronic parts that don’t have a wear-out failure mode.)

     

    In my view, the practical intent of Part 806 is to keep FDA informed of device problems and fixes, not maintenance that doesn’t change the device. Many of the Warning Letters are “You sent a letter to your customers informing them of a problem that you intend to fix, but you didn’t inform FDA.”



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    Dan O'Leary
    Swanzey NH
    United States
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  • 7.  RE: Device servicing and Part 806

    Posted 16-Feb-2017 09:51
    If such items are MDR reportable, we generally cover this by including on the MDR. Note that 806 has a mention of "unless previously reported under section 803." For one-off events that are MDR reportable, this seems to be the simplest way to manage and I suspect is aligned with the original intent of that exception in 806.

    For non-MDR reportable events it is a bit trickier. Generally you can cover by procedures - in either your Correction & Removals or Serivce procedure (or both) describe how these are evaluated and where the relevant records described in 806 are kept (often actually in your service system records). It usually has proven to be acceptable to FDA inspectors if you do so.

    g-

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    Ginger Glaser RAC
    Vice-President, Quality and Regulatory Affairs
    Maplewood MN
    United States
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