QS Violations in Talon Inspection

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A 3/11-3/28 FDA inspection at Talon, an S&S Technology company, in Houston, TX, found Quality System Regulations violations, including several repeated from a 2011 inspection, in the firm’s manufacturing of Class 1 and 2 medical equipment, healthcare supplies, and radiation products used for general and plastic surgery. An 8/2 Warning Letter says specific violations were: 

  •          failing to document corrective and preventive action activities and/or results;
  •          failing to establish procedures for design change;
  •          failing to adequately establish procedures to control product that does not conform to specified requirements;
  •          failing to adequately maintain a device history record;
  •          failing to document acceptance or rejection of incoming product;
  •          failing to establish procedures or instructions for performing servicing activities and verifying that servicing meets specified requirements;
  •          failing to adequately establish records of acceptable suppliers, contractors, and consultants;
  •          failing to have management with executive responsibility review the suitability and effectiveness of the quality system at defined intervals and with sufficient frequency;
  •          failing to perform quality audits at defined intervals and at sufficient frequency to determine whether the quality system activities and results comply with quality system procedures;
  •          failing to adequately establish procedures for training and identifying training needs; and
  •          failing to adequately maintain records of changes to documents.

The letter says several of the observations were repeated from a 2011 inspection. And it says that the firm’s responses to the 2019 inspection observations were all inadequate.

The FDA investigator also observed that Talon manufactures software-controlled medication cabinets and carts used for security and convenient access to medications and medical supplies. It says the software should be registered and listed under the appropriate regulation.

The letter further says that the software literature asserts that the software has been FDA approved. But, it says, the agency was unable to locate any information demonstrating that the firm has listed its MedKey Lite software with FDA.

Talon was told to take prompt action to correct the violations addressed in the letter and to respond with a list of specific steps taken to correct the violations and prevent their recurrence, with documentation of each step and a timetable for completion.

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