Complaint-Handling, MDR and Recall Management
All personnel who deal with customers, or who may receive a complaint call, must be trained in the proper routing/handling of complaints, Provide information about FDA's Medical Device Reporting (MDR) regulation and the Voluntary Reporting program called MedWatch,. This course will introduce you to Medical Device Reporting and to help you better understand the process and benefits of Voluntary Reporting and responsibilities, the latest Amendments to the MDR Regulation to Implement FDAMA Changes, To Recall or Not to Recall: Issues to consider regarding whether a Field Action is required, determine when a recall is required and how to manage a recall, who must report, when to report, what to report, where to report, recordkeeping requirements, FDA regulatory authority, references and guidance. Seminar attendees are encouraged to bring examples of their work from the functional area on the various topics as applicable for group discussion. We will review and discuss pain points, challenges and solutions
An effective complaint handling system is an extremely important part of any quality system. Manufacturers should understand that any complaint received on a product shall be evaluated and, if necessary, thoroughly investigated and analyzed, and corrective action shall be taken. The results of this evaluation should lead to a conclusion regarding whether the complaint was valid, what the root cause of the complaint was, and what action is necessary to prevent further occurrences. Complaints cannot be ignored. They are an excellent indicator of problems with the use, design, and/or manufacture of a product. A single complaint that is thoroughly investigated may lead a company to take remedial or corrective action. It may also take an ongoing analysis of numerous complaints before a trend is spotted that causes a company to initiate changes in their product, labeling, packaging or distribution. The regulatory expectations for both pharmaceuticals and medical devices will be emphasized as well as overview of best practices for timely and effective investigations. Trending is the only way a company can stay on top of emerging quality issues and address those that are most pressing.
Medical Device Reporting (MDR) is the mechanism for FDA to receive significant medical device adverse events from manufacturers, importers and user facilities, so they can be detected and corrected quickly. User Facilities (e.g., hospitals, nursing homes) are required to report suspected medical device related deaths to both the FDA and the manufacturers. User facilities report medical device related serious injuries only to the manufacturer. If the medical device manufacturer is unknown, the serious injury is reported by the facility to FDA. Health professionals within a user-facility should familiarize themselves with their institution procedures for reporting adverse events to the FDA.
The MDR process impacts device user facilities, manufacturers, importers, and distributors. If you are a device user facility, you must report deaths and serious injuries that a device has or may have caused or contributed to, establish and maintain adverse event files, and submit summary annual reports. 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. If you are a manufacturer, you must also submit specified follow-up.
Recall means the correction or removal of a device for human use where FDA finds that there is a reasonable probability that the device would cause serious, adverse health consequences or death. It is an action taken to address a problem with a medical device that violates FDA law. Recalls occur when a medical device is defective, when it could be a risk to health, or when it is both defective and a risk to health.
A medical device recall does not always mean that you must stop using the product or return it to the company. A recall sometimes means that the medical device needs to be checked, adjusted, or fixed. If an implanted device (for example, a pacemaker or an artificial hip) is recalled, it does not always have to be removed. When an implanted device has the potential to fail unexpectedly, companies often tell doctors to contact their patients to discuss the risk of removing the device compared to the risk of leaving it in place. FDA classifies medical device recalls into three categories, representing the potential risk to public health: Class I, II, and III.
Why you should attend:
Understand that although FDA does not specify a standard complaint handling system, the requirements do specify certain actions that shall be included in any system
Grasp and comprehend the definitions and elements of the regulatory requirements for Complaint Handling, Medical Device Reporting and handling of Recalls
All personnel who deal with customers, or who may receive a complaint call, must be trained in the proper routing/handling of complaints
Provide information about FDA´s Medical Device Reporting MDR) regulation and the Voluntary Reporting program called MedWatch
Introduce you Medical Device Reporting and to help you better understand the process and benefits of Voluntary Reporting and responsibilities
Latest Amendments to the MDR Regulation to Implement FDAMA Changes
To Recall or Not to Recall: Issues to consider regarding whether a Field Action is required
Determine when a recall is required and how to manage a recall, who must report, when to report, what to report, where to report, recordkeeping requirements, FDA regulatory authority, references and guidance
Seminar attendees are encouraged to bring examples of their work from the functional area on the various topics as applicable for group discussion
Review and discuss pain points,challenges and solutions
Areas Covered in the Session:
Areas of special concentration will include:
Complaint evaluation and investigation
Data collection and trending
CAPA process for investigating complaints
Accelerate complaints recording, investigation, reporting, escalation/triggers and closure cycle as cases are automatically routed from one stage to the next
Gain enterprise-wide visibility into the complaints data and track the process with performance metrics, dashboards or other indicators
Improve communication and teamwork on complaints across departments and functional areas
Drive continuous improvement by tying corrective actions with complaints for a closed loop quality process
Improve management of the complaint lifecycle with real-time trending and escalation of customer complaints
Understand the History of MDR Regulation
What types of Reports does the FDA receive and who must submit Mandatory Reports to the FDA?
Who can submit Voluntary Reports to the FDA?
How Does the FDA Use Medical Device Reports?
What are the exemptions, variances, or alternative forms of adverse event reporting requirements?
Basics of a Recall: Initiation, Classification and Public Warning
Medical Device Recall Reporting
Recall Responsibilities & Requirements
Introduction to Medical Device Recalls: Industry Responsibilities
Recall Communication and Strategy
Monitoring and Auditing Recall Effectiveness
Guidance for Industry, Trends and FDA Inspection & Enforcement Statistics and Trends
Day 1 Schedule
What are the elements of an effective complaint management system?
How does risk management influence complaint handling decisions?
What are the responsibilities of other departments?
What is the best way to train customer contact employees?
What steps would the FDA expect to see the departments taking that sorts out potential MDRs, product complaints and other reportable events?
What and how do you perform trending?
What are examples of how companies trend and analyze service calls and product complaints?
Understand how and why CAPA is tied in to product complaint investigation
What is an appropriate complaint handling system in a risk-based post-market environment?
How do you audit a complaint handling system?
From your audits, how do you judge that your complaint handling system is effective?
Assignment of responsibility
Manufacturer should develop a method for maintaining records of complaints and investigations that: is functional and economical, meets company needs, and meets FDA requirements and expectations
Identify designated complaint handling unit
Instructions for documenting complaint information
Process for evaluating complaints
Process for investigating complaints
Identify and process MDR´s
How to process customer returns
Records and trend analysis
Examples of tools currently being used to conduct investigations
How far and in-depth do you go with your investigations
What are current FDA "hot" buttons and trends, benchmarks and best practices for investigations
How to become a "good" investigator and the emphasis on closed-loop investigations
Written Procedures: Designated Complaint Handling Unit, Training and Records
Recent Enforcement Actions
Medical Device Reporting
Introduction to Medical Device Reporting
What are the key terms, definitions and forms?
MDR procedures and processes
What are the requirements for developing, maintaining, and implementing written MDR procedures that apply to me?
How do you manage international reporting requirements under your complaint handling system?
Consider the relationship between MDRs and Risk Assessments
Exercise and Recap of Day 1
Exercise on Product Complaints/Complaint Handling
Day 2 Schedule
Medical Device Reporting
eMDR Electronic Medical Device Reporting
How to Report a Problem
Event Problem Codes and Manufacturer Evaluation Codes
MedWatch: Safety Information and AER Program
Completing Form FDA 3500A
What form should I use to submit reports of individual adverse events and where do I obtain these forms?
Where and how do I submit reports and additional information?
Does the information in my report constitute an admission that the device caused or contributed to the reportable event?
What are the requirements for developing, maintaining, and implementing written MDR procedures and maintain records/files that apply to me?
Requirements for Individual Adverse Event Reports
User Facility Reporting, Importer Reporting and Manufacturer Reporting Requirements
What happens in a medical device recall: Firm-initiated recall vs. mandatory recall
What information needs to be reported?
What types of records do companies need to keep?
Prior to notifying FDA, what steps should you have taken?
What are the dos and don´ts when informing FDA of a product problem?
Who should be involved in the decision process?
Who should be responsible for communicating with FDA?
What are the consequences of a recall?
What factors should you consider when determining whether or not to get your product back?
How do you prepare for a post recall inspection?
What customer and other outside communications are necessary?
What documentation should be prepared?
How should the product liability implications of recall communications be handled?
What is an effectiveness check?
Health Hazard Evaluations are conducted by FDA
How should you write your recall correspondence?
How do you determine that your recall is completed and what do you do to close your recall internally and with FDA?
Create and use a recall operational
Understand what is required for the recall strategy as expected by FDA
Depth of recall and using a viable, sustainable and effective strategy
Understand why the documentation and paper trail are so critical and termination of a recall
Discuss most recent recalls not only for devices but pharmaceuticals and why the numbers are alarming
Exercise and Recap of Day 2
Exercise - MDR and Recall
David R. Dills
Global Regulatory Affairs & Compliance Consultant