Dr. Christopher Joseph Devine, President, Devine Guidance International
Devine Guidance

A Misbranded Bed; is that Even Possible?

By Dr. Christopher Joseph Devine

…limited to: Failure to adequately develop, maintain and implement written MDR procedures, as required by 21 CFR 803.17. For example, after reviewing your firm’s MDR procedure titled “QP-21-01-AH, Global Adverse…

…limited to: Failure to adequately develop, maintain and implement written MDR procedures, as required by 21 CFR 803.17. For example, after reviewing your firm’s MDR procedure titled “QP-21-01-AH, Global Adverse…

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What Changes Should Manufacturers Expect From FDA?

…through. They are starting to look more at product quality and performing risk-based inspections based on the data than they have through MDR’s, complaints, and CAPA. Electronic audits are also…

…through. They are starting to look more at product quality and performing risk-based inspections based on the data than they have through MDR’s, complaints, and CAPA. Electronic audits are also…

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Dr. Christopher Joseph Devine, President, Devine Guidance International
Devine Guidance

Use Complaints to Fix Problems!

By Dr. Christopher Joseph Devine

…Moreover, regardless of whether a complaint will warrant a MDR, all complaints must be “INVESTIGATED” as in determining the root cause of the problem the resulted in a complaint. If…

…Moreover, regardless of whether a complaint will warrant a MDR, all complaints must be “INVESTIGATED” as in determining the root cause of the problem the resulted in a complaint. If…

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Dr. Christopher Joseph Devine, President, Devine Guidance International
Devine Guidance

Failing to File MDRs will Result in a Warning Letter

By Dr. Christopher Joseph Devine

…written MDR procedures, as required by 21 CFR 803.17. For example, after reviewing your firm’s MDR procedure titled: MDR Procedure titled U.S. Medical Device Reporting, SOP-300024 Rev: 06 and Flow…

…written MDR procedures, as required by 21 CFR 803.17. For example, after reviewing your firm’s MDR procedure titled: MDR Procedure titled U.S. Medical Device Reporting, SOP-300024 Rev: 06 and Flow…

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Dr. Christopher Joseph Devine, President, Devine Guidance International
Devine Guidance

Finally, eMDRs

By Dr. Christopher Joseph Devine

…individual MDRs or batches of MDRs. Note: It is Dr. D’s opinion; depending on the size of the batched of MDRs, this option may quickly garner agency attention. Additionally, FDA…

…individual MDRs or batches of MDRs. Note: It is Dr. D’s opinion; depending on the size of the batched of MDRs, this option may quickly garner agency attention. Additionally, FDA…

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Dr. Christopher Joseph Devine, President, Devine Guidance International
Devine Guidance

Complaint Files – Stop the Complaining

By Dr. Christopher Joseph Devine

…addresses§820.198;” however, do not stop there. The complaint procedure also needs to link to Medical Device Reports (MDR) and the need to file MDRs within five or 30-days. In fact,…

…addresses§820.198;” however, do not stop there. The complaint procedure also needs to link to Medical Device Reports (MDR) and the need to file MDRs within five or 30-days. In fact,…

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Devine Guidance

Accurate DHRs are Never Optional

By Dr. Christopher Joseph Devine

…recognize the importance of the DHR, try managing your organization’s complaint management system, performing a complaint investigation, filing an MDR, or even attempting to manage a RECALL (Dr. D’s favorite…

…recognize the importance of the DHR, try managing your organization’s complaint management system, performing a complaint investigation, filing an MDR, or even attempting to manage a RECALL (Dr. D’s favorite…

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Devine Guidance

SCAR – A Favorite Acronym

By Dr. Christopher Joseph Devine

…Reports (MDR’s – another valuable acronym) or even worse a product RECALL, Dr. D’s favorite six-letter word, then 5-working days is not an unreasonable request. The doctor’s best advice is…

…Reports (MDR’s – another valuable acronym) or even worse a product RECALL, Dr. D’s favorite six-letter word, then 5-working days is not an unreasonable request. The doctor’s best advice is…

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Dr. Christopher Joseph Devine, President, Devine Guidance International
Devine Guidance

Responding to a Warning Letter

By Dr. Christopher Joseph Devine

…U.S.C. 360i, and 21 CFR 803 – Medical Device Reporting (MDR) regulation. For example, when requested procedures for MDR reportable events were not provided. You should take prompt action to…

…U.S.C. 360i, and 21 CFR 803 – Medical Device Reporting (MDR) regulation. For example, when requested procedures for MDR reportable events were not provided. You should take prompt action to…

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