QS, MDR Violations at Fresenius Kabi Facility

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An 8/15-9/7/2023 FDA inspection at the Fresenius Kabi USA facility in North Andover, MA, found Quality System and Medical Device Reporting violations in the facility’s work as a specification developer and manufacturer of the Ivenix Infusion System. A just-released 1/4 Warning Letter says the specific Quality System violations were:

  • failing to establish procedures for corrective and preventive action;
  • failing to establish and maintain procedures to control the device design to ensure that specified design requirements are met;
  • failing to establish procedures for validating the device design and failing to include software validation and risk analysis, where appropriate; and
  • failing to establish procedures for the identification, documentation, validation, or, where appropriate, verification, review, and approval of design changes before their implementation.

The Medical Device Reporting (MDR) violations were:

  • failing to report to FDA required information no later than 30 days after receiving or otherwise becoming aware of information, from any source, reasonably suggesting that a marketed device has malfunctioned and the device or a similar marketed device would be likely to cause or contribute to a death or serious injury; and
  • failing to adequately develop, maintain, and implement written MDR procedures.

The letter also says the firm’s Ivenix system is misbranded in that Fresenius failed or refused to furnish material or information about the device involving reports of corrections or removals.

FDA says the company’s responses to the inspection observations were inadequate or could not be evaluated. Fresenius Kabi was told to promptly address the violations and to respond with a list of specific actions it has taken to address the violations and prevent their recurrence, with documentation of the corrective actions and a schedule for completing them. FDA also proposes a 1/19 virtual regulatory meeting to discuss its concerns and have the firm comment on the status of its proposed corrections.

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