7 QS Issues at 3 Integra Facilities
FDA inspections at three Integra Lifesciences medical device facilities (Mansfield, MA, 3/12/2024-6/5/2024; Plainsboro, NJ, 4/9/2024-8/22/2024; and Princeton, NJ, 3/12/2024-8/22/2024) found Quality System Regulation violations in the firm’s manufacturing of neurological and neurosurgical medical devices. A just-released 12/19/2024 Warning Letter says specific violations were:
- failure to establish and maintain procedures to control product that does not conform to specified requirements, addressing the identification, documentation, evaluation, segregation, and disposition of nonconforming product, and determining the need for an investigation and notification of the person or persons responsible for the nonconformance;
- failure to establish and maintain procedures for acceptance activities, including inspections, tests, or other verification activities;
- failure to establish and maintain procedures for finished device acceptance to ensure that each production run, lot, or batch of finished devices meets acceptance criteria;
- failure to establish and maintain procedures for corrective and preventive action;
- failure to review and evaluate process changes and deviations and perform revalidation when changes or process observations occur;
- failure to establish and maintain procedures to prevent contamination of equipment or product by substances that could reasonably be expected to adversely affect product quality; and
- failure to validate with a high degree of assurance a process whose results cannot be fully verified by subsequent inspection and test.
The letter says FDA could not determine the adequacy of the firm’s responses to the inspection observations. Integra was told to take prompt action to address the violations and to respond with a list of specific actions it has taken to correct the violations and prevent their recurrence, with documentation of the corrections and a schedule for their completion.