Multiple Violations at WAVi Co.
A 3/23-3/29 FDA inspection at WAVi Co. in Denver, CO, found that the firm manufactures and distributes the “WAVi Desktop,” intended to collect, analyze, and clinically interpret data to aid in the assessment or diagnosis of patients with a variety of potential neurological conditions. A 10/20 Warning Letter says the device is adulterated because the firm does not have an approved PMA or an approved application for an IDE in effect. The device also is misbranded, the letter says, because the firm introduced or delivered it for introduction into interstate commerce without submitting a required premarket notification to FDA.
The letter says company officials said during the inspection that the WAVi Desktop is for research use only. However, the company did not provide evidence of having an approved IDE for the device and did not provide any evidence to support a claim that it is IDE-exempt.
FDA says its review of the firm’s customer list indicates it is marketing to commercial firms as well as academic institutions and information on the company’s Web site supports the notion that the device is being marketed for more than research purposes.
The inspection also identified these Quality System Regulation violations:
- failing to perform validation of device software;
- failing to validate a process whose results cannot be fully verified by subsequent inspection and test;
- failing to adequately maintain device history records that include or refer to the acceptance records that demonstrate the device is manufactured following the device master record;
- failing to maintain device master records; and
- failing to establish procedures for, and conduct, quality audits.
WAVi was told to respond with a list of specific steps it has taken to address the violations and prevent their recurrence, with documentation of the corrections or corrective actions, and a timetable for completing the corrections.