QS Violations Seen in Lymol Medical Inspection
A 2/3-2/12 FDA inspection at Lymol Medical, Woburn, MA, found Quality System Regulation violations in the firm’s manufacturing of Elite X Class rigid bronchoscope systems and Premier S Class silicone stents. A just-released 4/7 Warning Letter says specific violations were:
- failing to validate according to established procedures a process whose results cannot be fully verified by subsequent inspection and tests;
- failing to establish and maintain procedures for the identification, documentation, validation or, where appropriate, verification, review, and approval of design changes before their implementation;
- failing to establish and maintain documented procedures for acceptance activities including inspections, tests, or other verification activities to verify that the specified requirements for the product are met;
- failing to evaluate complaints to determine whether the complaint represents an event that is required to be reported to FDA under the Medical Device Reporting regulation;
- failing to evaluate and investigate any complaint involving the possible failure of a device, labeling, or packaging to meet any of its specifications, unless such investigation has already been performed for a similar complaint and another investigation is not necessary;
- failing to establish and maintain purchasing documents (includes an agreement) that clearly describe or reference the specified requirements, including quality requirements, for purchased or otherwise received products and services;
- failing to develop, conduct, control, and monitor production processes to ensure that a device conforms to its specifications; and
- failing to establish and maintain procedures to ensure that device history records for each batch, lot, or unit are maintained to demonstrate that the device is manufactured following the device master record, including the dates of manufacture, the quantity manufactured, the quantity released for distribution, acceptance records, primary identification label and labeling used for each production unit, and any unique device identifier or universal product code and any other device identification(s) and control number(s) used.
Lymol was told to take prompt action to correct the violations addressed in the letter and was told to respond with a list of specific steps it has taken to correct the violations and prevent a recurrence of the same or similar violations, with documentation of each step and a timetable for implementation of the steps.