Complaint Handling System
MDR Reportable Complaints
File Accessibility and Location
DEVICE FAILURE ANALYSIS
FEEDBACK FOR QA SYSTEM
MEDICAL DEVICE REPORTING
Who Must Report
When to Report
Individual Adverse Event Reports
Written MDR Procedures
MDR Event Files
How to Maintain MDR Event Files
ADDITIONAL MDR GUIDANCE
Reports of Removals and Corrections
Complaint Processing Procedure and Forms
Section 820.3(b) of the Quality Systems regulation defines a complaint as "any written, electronic, or oral communication that alleges deficiencies related to the identity, quality, durability, reliability, safety, effectiveness, or performance of a device after it is released for distribution." All medical device manufacturers are subject to the complaint requirements in 21 CFR Part 820, Quality System regulation and to the reporting requirements in 21 CFR Part 803, Medical Device Reporting (MDR) regulation. A complaint is any indication of the failure of a device to meet customer or user expectations for quality or to meet performance specifications. A complaint may be lodged against any finished device that had been released for distribution. Any complaint involving the possible failure of a device, labeling, or packaging to meet any of its specifications is subject to the provisions of 21 CFR 820.198, Complaint Files.
The sources of oral and written complaints are numerous. A manufacturer can receive this information via telephone, facsimile, written correspondence, sales representatives, service representatives, scientific articles, and FDA or internal analyses. Information will also be submitted by health care professionals, lay users, consumers, user facilities and distributors on the MedWatch Forms FDA 3500 and FDA 3500A.
Manufacturers are required to review, evaluate, and, when appropriate, investigate complaints, establish and maintain written procedures describing the process used to perform these activities, and designate a responsible individual or entity to perform these tasks. Complaints concerning death, serious injury or malfunctions, as defined in the MDR regulation, shall be reported to FDA as discussed later. Manufacturers of any class of medical devices are never exempted from the Quality System regulation complaint requirements (820.198) nor the general record requirements (820.180) which permit FDA review and copying of these records. Complaint file requirements are necessary to make certain manufacturers have adequate quality systems for investigating complaints and taking corrective action. Access to complaint files, device-related death and injury reports, and complaints about device defects enables FDA to determine if a manufacturer's quality system and corrective actions are adequate.
Manufacturers can identify problems with device component, labeling and packaging quality by several methods. To meet all GMP requirements these identification methods should include a review and evaluation of all complaints, failed devices, and service or repair requests. Complaints and service or repair requests are important sources of feedback information for a quality system. Finished devices that are returned for service or repair may meet the complaint requirements identified in section 820.198; therefore, these service or repair requests shall be evaluated to determine if they are complaints. Service or repair data shall be reviewed [820.200(b)&(e)] to identify systematic problems and problems that may qualify as complaints. When these problems are identified they should be processed as complaints according to the requirements in 820.198.
Complaint data, in conjunction with product audits, QA systems audits, operational analyses, inspection and test data, etc., is used by the quality assurance organization to:
- identify poor performance in the overall quality system, particularly faulty design of devices, and faulty manufacturing processes;
- aid in implementing solutions to these quality problems;
- verify confidence in, and improve the performance of the quality system;
- improve the safety and performance of devices;
- reduce medical device reporting;
- reduce costs and improve production schedules;
- reduce employee confusion;
- improve customer relations by reducing the frequency of problems, complaints, and recalls; and,
- assure compliance with device regulations and consensus standards.
Complaint Handling System
An effective complaint handling system is an extremely important part of any quality system. Even manufacturers who have not received complaints should be prepared to receive and process them. Manufacturers should understand that any complaint received on a product shall be evaluated and, if necessary, thoroughly investigated and analyzed, and corrective actions shall be taken. The results of this evaluation should lead to a conclusion regarding whether the complaint was valid, what the cause of the complaint was, and what action is necessary to prevent further occurrences. Complaints cannot be ignored. They are an excellent indicator of problems with the use, design, and/or manufacture of a product. A single complaint that is thoroughly investigated may lead a company to take remedial or corrective action. It may also take an ongoing analysis of numerous complaints before a trend is spotted that causes a company to initiate changes in their product, labeling, packaging or distribution.
Using written procedures for handling complaints increases confidence that all complaints will be handled properly. Written procedures should be provided to employees to facilitate communication, maintain consistency, and reduce quality problems. Written procedures for the receiving, reviewing and evaluating of complaints by a formally designated unit shall be established and maintained in accordance with 820.198, Complaint Files, and 820.40, Document Controls, respectively. The procedures should include the need for complaints to be evaluated in accordance with 820.100, Corrective and Preventive Action.
The complaint files shall be maintained in accordance with the general record keeping requirements of 820.180. All complaint files are to be retained for a period of time equivalent to the design and expected life of the device, but in no case less than 2 years from the date of release for commercial distribution bythe manufacturer. The written procedure should specify: authority; responsibilities; and the process to follow in receiving, reviewing, and investigating complaints. However, for very small manufacturers where division of work is minimal, and authorities and responsibilities are obvious, the GMP requirements as detailed in 820.198 in conjunction with appropriate forms may be sufficient as a protocol for handling complaints.
Although FDA does not specify a standard complaint handling system, the GMP requirements do specify certain actions that shall be included in any system. Manufacturers shall:
- document, review, evaluate, and file all complaints;
- formally designate a unit or individual to perform these activities;
- determine if an investigation is necessary;
- record the reason if no investigation is made;
- assign responsibility for deciding when not to investigate; and,
- determine if the complaint requires an MDR report.
Manufacturers shall formally assign responsibility for maintaining complaint files and conducting complaint investigations to individuals or an organizational unit. Under 820.25(b) it is the manufacturer's responsibility to ensure that personnel are properly trained to adequately perform their duties. These employees shall have the proper education and training to process complaints. Any difficulty noted in employees performing required tasks for proper complaint handling may be an indication that additional training is needed. Training shall be documented.
The person(s) assigned to review complaints should have a thorough knowledge of the product line in order to make an informed, reasonable decision as to the severity and significance of a complaint and to decide whether an investigation is necessary. If it is decided that an investigation is not necessary, a record shall be made of the rationale used to arrive at this decision. The record must identify the individual responsible for making this decision.
Executive management should ensure that adequate resources are provided, including trained personnel, to the designated complaint handling unit within the company. The activities of the unit should be assessed on a regular basis, and corrections made if necessary.
MDR Reportable Complaints
Section 820.198(c) specifically requires that any complaint involving the possible failure of a device, labeling, or packaging to meet its performance specifications shall be reviewed, evaluated, and investigated unless such investigation has already been performed for a similar complaint and another investigation is not necessary. Also, section 820.198(d) further specifies that any complaint that requires an MDR report shall be promptly reviewed, evaluated, and investigated by a designated individual(s), and shall be maintained in a separate portion of the complaint files or clearly identified. However, if maintained separately a manufacturer should duplicate these serious complaints in the regular complaint file to assure that any analysis performed by product is inclusive of all complaints. Analysis by appropriate statistical methodology where necessary is a means of identifying quality problems. A single event, of course, may also be an indicator of a quality problem.
FDA does not specify a standard method for recording or retrieving complaint information. Each manufacturer should develop a method for maintaining records of complaints and investigations that: is functional and economical, meets company needs, and meets requirements of the Quality System regulation. A two sided form is suggested when using hard copy to record complaints. One side may be used to record complaint information such as:
- sequential number of the complaint;
- origin of the complaint;
- customer information;
- product information;
- any corrective actions already taken;
- details of the complaint;
- and dates, signatures, assignments, etc.
The other side may be used to record:
- corrective action with respect to the product and to the customer;
- and dates, signatures, etc.
A typical form is exhibited at the end of this chapter. The completed form should be stored in the complaint file which may be a physical or electronic file.
The designated unit or person(s) responsible for maintaining the complaint file(s) shall prepare a written record of any investigations. This record shall include [820.198(e)]:
(1) The name of the device;
(2) The date the complaint was received;
(3) Any device identification(s) and control number(s) used;
(4) The name, address, and phone number of the complainant;
(5) The nature and details of the complaint;
(6) The dates and results of the investigation;
(7) Any corrective action taken; and
(8) Any reply to the complainant.
Also, the investigation record of any complaint that is being reported to FDA in an MDR report shall include a determination of [820.198(e)]:
(1) Whether the device failed to meet specifications;
(2) Whether the device was being used for treatment or diagnosis; and
(3) The relationship, if any, of the device to the reported incident or adverse event.
Section 820.198(e) requires the record of investigation to include any reply to the complainant. Manufacturers should send a reply to each complainant as a courtesy, but more important to prevent further misuse, injury or other adverse situations from recurring. However, because of the nature of the complaint, there may be cases where a reply is not necessary. In such cases, the record should state that no reply was made and the reason for not replying. When the problem was caused by misuse, it is very important to advise the user to help prevent further misuse. Also, the manufacturer should determine if inadequate labeling may have lead to misuse.
File Accessibility and Location
The GMP requirement states in 820.180 that "All records required by this part shall be maintained at the manufacturing establishment or other location that is reasonably accessible to responsible officials of the manufacturer and to employees of the Food and Drug Administration designated to perform inspections." "All records" includes complaint files and records of investigations. For complaint processing, responsible officials are general managers, complaint processors, QA managers, R&D and process engineers, and others who receive, process, investigate, and correct problems associated with complaints. Complaint files shall be reasonably accessible to FDA for review and copying. FDA has clear authority under Section 704(e) of the Food, Drug, and Cosmetic Act to inspect and copy all records required under section 519 of this Act.
The GMP requirement states that complaint files must be handled by a formally designated complaint unit. If the unit or individual(s) designated as responsible for investigating complaints is located away from the actual manufacturing site, the investigated complaint(s) and the record(s) of investigation shall be reasonably accessible to the manufacturing site. If a manufacturer's formally designated complaint unit is located outside of the United States, records required by this section shall be reasonably accessible in the United States at a location in the United States where the manufacturer's records are regularly kept or at the location of the original distributor.
When devices are produced for a manufacturer by a contract manufacturer, the manufacturer should forward to the contractor copies of complaints and investigations that pertain to operations performed by the contractor. The contractor should maintain a complaint file and process complaints as discussed herein for the primary manufacturer.
Relabelers, importers, and others who distribute under their own name should forward complaints to the actual manufacturers, including foreign manufacturers, who are usually in the best position to resolve complaints on their own products.
Certain manufacturers products may be used both as a medical device and for non-medical uses, for example lasers and motors. The complaints received from non-medical users do not necessarily have to be included in complaint files. However, if the non-medical product fails to meet specifications, then that report should be in the manufacturer's complaint file. This action would help assure compliance with 820.100, which requires identifying, recommending, or providing solutions for quality problems and verifying implementation of such solutions. The person receiving such complaints shall be trained [820.25(b)] to identify complaints that also affect those units used as medical devices.
To facilitate detection of failure or defect trends, complaint files should be arranged in a manner that permits correlating present and past complaints for a particular product or product line. Thus, files are usually organized according to product or product lines. Manufacturers who do not organize complaint files by product or product line may have to search several files to find similar complaints or indications to identify problem trends. Complaints may be maintained in a computer file so that complaint data on a specific device or type of complaint can be readily accessed and analyzed. As appropriate, complaint analysis or their summaries should be included in the management review and the quality system [820.20(c)].
Manufacturers should process and analyze failed devices per 820.100. Section 820.100(a)(1) states that returned product is subject to corrective action. Failure analysis must be conducted by appropriately trained and experienced personnel [820.25(b)]. They should use a written procedure to assure that the process of device handling and analysis will not compromise the determination of the cause of the device failure. The failure investigation and analysis should determine the actual failure mechanism to the objective level necessary to correct the problem. When systematic failure has been diagnosed and corrective action established, a manufacturer need not analyze all additional devices that are returned with the same symptoms.
If a failure is determined to be related to safety and effectiveness, the deficiency should be determined, corrected and documented. If an investigation verifies a particular device deficiency and that this deficiency may exist in other products, the investigation should extend to determining its effect on other medical products.
Any corrective or preventive action taken shall be done following the requirements in 820.100.
The more comprehensive a quality system is, the lower the probability of complaints occurring. However, in order for a quality assurance system to be dynamic or self correcting, data on quality problems from all sources should be fed back into the system. Complaints are a valuable source of data that can point to corrective actions.
Feedback data should flow into all operations that could be affected by the data and should be used to aid in device and process design evaluation and/or redesign, and to aid in improving the overall quality system program.
Regardless of the size of the formal quality system, the feedback data path in any company should be the same, that is, the data should flow into all affected operations even if some of these are not covered by the formal quality system or by FDA regulations.
Complaints that shall be processed according to the GMP requirements may be received from:
- customers by letter, credit memo, returned goods form, or phone;
- a manufacturer's representative, or other employees;
- the MedWatch voluntary reporting program;
- a service or repair request;
- journal articles; or
- the FDA.
Complaints from any source shall be equally addressed by and be processed according to the company complaint policy and procedure. The company should make certain that market, sales, engineering, manufacturing, regulatory, installation, and service personnel are trained to properly identify and report complaints. These employees shall be made aware of this requirement according to section 820.25(b).
In addition to the GMP requirements covering complaint handling and failure investigations, device manufacturers shall also comply with the Medical Device Reporting (MDR) regulation, 21 CFR Part 803.
Who Must Report
The MDR regulation requires that all manufacturers of medical devices notify FDA when they become aware of a death or serious injury that may have been caused or contributed to by one of their marketed devices and/or any malfunction of one of their devices which, if it were to recur, would be likely to cause or contribute to a death or serious injury. These are the same complaints that the Quality System regulation requires a manufacturer to place in a separate portion of the complaint file or otherwise clearly identify [820.198(d)]. The MDR regulation is intended to supplement the Quality System regulation -- it is not meant to replace the GMP complaint and failure investigation requirements.
When to Report
There are specific time limits within which the MDR reports shall be made. Any report of a device-related death, serious injury and malfunction shall be submitted within 30 calendar days from becoming aware of an MDR reportable event. To meet these requirements, manufacturers shall have an information handling system to assure that data are screened to determine what shall be reported to FDA. This system shall also be able to follow up this information quickly and accurately in order to comply with the MDR regulation. Manufacturers which have a good system for processing complaint and failure investigations such as described in this chapter will have the organization and data processing capabilities to meet the MDR requirements.
Manufacturers of medical devices are required to report a device related death, serious injury or malfunction to FDA using FDA Form 3500A, within 30 calendar days after becoming aware of the event. However, if the event necessitates remedial action to prevent an unreasonable risk of substantial harm to public health, then a report shall be submitted within 5 work days. Reports shall also be submitted when FDA notifies a manufacturer that 5-day reports involving a particular type of medical device or type of event are required.
The reporting process starts when an MDR reportable event is first recognized. Manufacturers are responsible for making sure their employees know how to recognize what may be reportable. Manufacturers should also emphasize that any employee may learn of an adverse event during a phone call, a sales visit, a professional conference, from correspondence received or from service/warranty orders.
Individual Adverse Event Reports
There are two types of individual adverse event reports that may be submitted by manufacturers. The 5 work day and 30 calendar day reports.
The 5-day report (803.53) is for MDR reportable event(s) that require a remedial action to prevent an unreasonable risk of substantial harm to the public health or where FDA has specified that a 5-day report is needed. This situation may be identified by the manufacturer or FDA:
- If the manufacturer identifies the event and initiates a remedial action to prevent an unreasonable risk of substantial harm to the public health, a 5-day report is submitted instead of the 30-day report. Information not available within the five days should be provided in a supplemental report.
- If FDA identifies the event, the manufacturer will receive a written request directing them to file a 5-day report for all subsequent events of the same nature that involve similar devices for a specified time period. The FDA identification may be a result of its review of 30-day reports, inspection reports, user facility reports, etc.
The 5-day period of reporting starts the day after any employee, who is a person with management or supervisory responsibilities over persons with regulatory, scientific, or technical responsibilities, or a person whose duties relate to the collection and reporting of adverse events, becomes aware that a reportable MDR event or events, from any information, including any analysis, necessitate remedial action to prevent an unreasonable risk of substantial harm to the public health.
The MDR regulation defines remedial action as any action other than routine maintenance or servicing of a device where such action is necessary to prevent recurrence of a reportable event.
Not all remedial actions need to be submitted as 5-day reports. Only remedial actions that are necessary to prevent an unreasonable risk of substantial harm to the public health shall be submitted. If a remedial action is taken, but it is not done to prevent an unreasonable risk of substantial harm to the public health a 5-day report is not required. A 30-day report, however, may be required.
The discovery that a remedial action is necessary may be a direct result of one or more MDR reportable events occurring, or may be discovered through the performance of internal analyses using appropriate statistical or other acceptable methodologies for processing data.
Actions taken to fix a single device involved in the MDR reportable event are not remedial actions.
A 30-day report is required once a manufacturer receives or otherwise becomes aware of information that reasonably suggests that a device they have marketed:
(1) has or may have caused or contributed to a death or serious injury; or
(2) has malfunctioned and such device or similar device marketed by the manufacturer would be likely to cause or contribute to a death or serious injury, if the malfunction were to recur.
The 30-day period for reporting starts the day after receipt by any employee of information that reasonably suggests that an MDR reportable event has occurred. FDA expects manufacturers to train their employees to recognize that they have received information on an adverse event and to know to whom in the company to forward this information for an MDR evaluation.
A manufacturer is NOT required to file an MDR report:
- when it determines that a device related event did not occur, or
- when it determines that the device was made by another manufacturer.
For the latter instance, the regulation requires the manufacturer to forward whatever information they have to FDA with a cover letter explaining that they did not manufacture the device so that FDA can send it on to the correct manufacturer. In this case, a 3500A should not be completed. Manufacturers may also voluntarily send a copy of this information to the manufacturer they identify as being the actual manufacturer.
Written MDR Procedures
In addition to having general complaint handling procedures, the MDR regulation (803.17) requires manufacturers to develop, maintain and implement written MDR procedures that at a minimum:
A. Set up internal systems for:
- timely and effective identification, communication, and evaluation of any events that may be MDR reportable;
- a standardized review process/procedure for determining when an event meets the criteria for reporting under the MDR regulation; and
- timely transmission of a complete MDR report to FDA.
B. Set up documentation and recordkeeping for:
- information that was evaluated to determine if an event was MDR reportable;
- all MDR reports and information submitted to FDA;
- any information that was evaluated when preparing the annual certification report; and
- systems that ensure access to information that facilitates timely follow up and inspection by FDA.
The MDR procedures should be either incorporated in the overall complaint handling procedure or be a companion to it. In either case these MDR procedures shall be clearly identified. If a companion procedure, it shall be incorporated by reference in the overall procedure. This will assure that all complaints are properly evaluated for MDR reporting.
Each manufacturer has certain discretion to determine the level of detail and depth of information that their written MDR procedures contain. FDA suggests that manufacturers provide policy and interpretation information regarding "typical" adverse events or product problems that may be MDR reportable. FDA also suggests that the procedures describe the investigation protocol that will be followed, e.g., two or three or four attempts will be made to contact the reporter either by phone, FAX or letter before an investigation is closed; that the complaint records will contain a concise but thorough description of the adverse event or product problem, that the complaint records will be legible, etc.
MDR Event Files
Each event that requires a determination regarding its MDR reportability shall be documented in an MDR event file (MEF) (803.18). This MEF will be one of the bases for establishing compliance with the requirements of the MDR regulation. Files are to be accessible to FDA personnel for review and evaluation, be as complete as possible, and are to clearly document MDR related actions and decisions. The following information should be in the MEF to assure that it complies with the MDR requirements:
a) The original or a copy of the initial record complaint/event. This record should include the available information needed to complete the Form FDA 3500A. The record may be documentation of a telephone call, a letter or facsimile, a service report, documents related to a lawsuit, a voluntary FDA 3500 received from a health care professional or consumer, or mandatory FDA 3500A received from a User Facility and/or a Distributor, etc.
b) Copies of any records documenting the manufacturer's attempts to follow-up and obtain missing or additional information about the event. When information cannot be obtained an explanation shall be made part of the file.
c) Copies of any test reports, laboratory reports, service records and reports, records of investigation, etc.
d) Copies of all documentation involving the final assessment of the event, any deliberations and/or decision making processes used to determine whether an MDR report was or was not needed. When applicable, the final assessment should indicate what action, if any, the manufacturer has taken to assure that the cause of the event is corrected or otherwise mitigated.
e) Copies of all FDA 3500A forms submitted to FDA, when applicable. This includes a copy of any FDA 3500A forms received from User Facilities and Distributors.
f) Documents verifying that the event has been evaluated in accordance with the applicable requirements of the QS regulation, sections 820.100 and 820.198.
g) References to any other relevant documents or information used during assessment.
How To Maintain MDR Event Files
The MEF can be written or electronic files. They may make reference to other information that was used during the investigational process, in lieu of copying and maintaining duplicates in the file. Any referenced material is to be made available to FDA personnel for review, copying and verification.
Each MEF shall be retained for a period of two (2) years from the date of the event or a period of time equivalent to the expected life of the device, whichever is greater. Each MEF file shall be maintained for this period of time even if the device is no longer sold/distributed by the manufacturer.
The MEF may be maintained as part of the complaint file required by 21 CFR Section 820.198, however, the MEF files shall be prominently identified.
Manufacturers should refer to the guidance document entitled, "Medical Device Reporting for Manufacturers," for further information on how to comply with this requirement.
There is also a Web page devoted to MDR issues.
REPORTS OF REMOVALS AND CORRECTIONS
At the time of completion of this manual, FDA has not published a final rule implementing its authority under section 519(f) of the Act to require reports of removals and corrections. It is important to note, however, that the agency published a proposal to implement this authority at 59 FR 13828 (March 23, 1994). A final rule based on the proposed rule may require reporting different from or in addition to that required by the Quality System and MDR regualtions.
Exhibits are described below which follow in the order described.
Complaint Processing Procedure and Forms
This sample procedure is used to establish and help implement a system for processing routine complaints for devices. The customer complaint form mentioned in the sample procedure is essentially the same as the form, "customer/device complaints," in the next exhibit. Nowadays the complaint log shown on sheet 3 of 5 is easily maintained on a computer.
An example of a complaint recording form follows the complaint processing procedure.
The form titled "Customer Complaint" can be used to record most complaints.
If it matches a manufacturer's needs, the complaint form may be used as is. Also, it may be modified to meet specific needs. If the form is modified or a new one is developed, a manufacturer should make sure the resulting form is consistent with the GMP requirements and consistent with any complaint handling policy and/or procedures being used at the manufacturer.
A copy of the MedWatch 3500A is included at the end of this chapter. This form may be photocopied for submitting reports.
The MedWatch 3500A is also available from the Web page devoted to MDR issues.
*** SAMPLE PROCEDURE ***
|C O M P A N Y L O G O||Sheet 1 of 5|
|Title Complaint Processing Procedure||SOP Number|
|Prepared by||Date Prepared|
PURPOSE: To establish and implement a procedure and forms for recording customer complaints, analysis, response, and corrective action.
POLICY: It is the policy of our company that all complaints regarding safety, performance, or quality of our products or services will be subject to management review and/or investigation and will result in prompt response and corrective action where indicated.
SCOPE / DEFINITION: This policy is applicable to and must be complied with by all personnel who receive a customer complaint, including personnel in Sales and other departments.
A "complaint" is any indication of the failure of a device to meet customer or user expectations for quality or to meet performance specifications. Thus, any written, oral, or returned goods expression of dissatisfaction relative to the identity, quality, durability, reliability, safety, effectiveness, or performance of any device manufactured by this manufacturer would be considered a complaint.
Types of complaints intended to be covered by this policy are as follows:
1. PRODUCT PERFORMANCE: the product in some way does not perform to user's expectation or to any level of performance conveyed to the customer by printed labeling or verbally by company employees.
2. PRODUCT SAFETY: all safety complaints are covered by this procedure.
3. PRODUCT RELIABILITY: failure rate or need for service adjustments greater than user expectation, i.e. beyond the tolerable level of expected wear or malfunction.
4. PRODUCT APPEARANCE: visual defects inconsistent with the user's expectations for a medical device.
5. GENERAL COMPLAINTS: order or shipping error, delayed or unacceptable response to problems, unfulfilled promises, etc.
6. MDR REPORTABLE COMPLAINTS: all complaints involving device-related deaths, serious injuries and malfunctions. (See Policy/Procedure No. XXX for handling of MDR reports.)
FORMS USED: Customer/Device Complaint and Analysis and Complaint Log
PROCEDURE: Upon receipt of a customer complaint, the recipient completes side one of a CUSTOMER/DEVICE COMPLAINT form and, if the complaint is written, attaches the complaint letter to the form. The recipient then gives the form, with any attachments, by the next day to the Manager of Quality Assurance.
*** SAMPLE PROCEDURE Sheet 2 of 5
IMPORTANT COMPANY POLICY: Where a complaint requires immediate corrective action or response to a customer, the complaint recipient must either take the required action or communicate with the proper person to take the required action. It is the responsibility of the recipient of any complaint to see that the customer receives a response -- nothing in the following procedure relieves him or her of this responsibility.
1. Assigns a sequential complaint number and enters the complaint into the Complaint Log.
2. Determines and notes on the complaint form the person to whom the complaint is to be assigned for investigation and/or corrective action and the date a response is required from the assignee.
3. Notes any specific instructions to the assignee.
4. Distributes a copy to appropriate Department(s) as checked on side 1 of the complaint form.
5. Makes 2 copies of all sides of the inprocess form and attachments, and distributes:
Original to the Assignee.
One copy to the "UNDER INVESTIGATION" complaint folder.
1. Performs the investigation and/or corrective actions and records the results on the form; and attaches any investigation records. If no investigation was done the reason why must be recorded and the name of the approving official documented.
2. Returns the original of the inprocess form to QA.
1. Records on the Analysis side:
If no action is taken, the reason for inaction should be recorded on the analysis form.
Any additional corrective action taken or directed by QA.
Whether an MDR report was submitted to the FDA.
The nature and date of any response made to the originator or the customer. If this response is written, a copy of the letter or FAX is attached to the analysis form.
The final disposition of the complaint.
QA signature and date.
2. Records the final disposition of the complaint on the complaint log.
3. Files the completed form in the appropriate complaint file for the type of device involved; and discards the copy previously filed in the "UNDER INVESTIGATION" complaint folder.
- Distributes the complaint log monthly to Staff and specifically involved departments. This log should include a trend analysis of complaints for the month correlated with trends noted in previous months.
*** SAMPLE RECORD ***
|COMPLAINT LOG||Sheet 3 of 5||MONTH , 19|
*** SAMPLE RECORD*** Sheet 4 of 5 of Procedure No. _________________
CUSTOMER COMPLAINT (Side 1) SEQUENTIAL NO. __________________________
Device Name _______________________________________ Model Number __________________
Catalog Number ____________________________________ Lot Number _______________________
Name of Complainant ________________________________ Phone No. ________________________
Complainant Address __________________________________________________________________
Complaint Received by _________________________________________________________________
Title ______________________________________________ Date Received ____________________
By: Q Visit Q Phone Q Letter Q Sales Q Credit Memo Q Other _________________________________
Q Sterility __________________________________________________________________________
Q Particulate Matter Type ________________ Location ____________________________________
Q Defect ________________________________________________________________
Q Packaging _______________________________________________________________
Q Labeling ________________________________________________________________
Q Patient Death ___________________________________________________________
Q Patient Injury ____________________________________________________________
Q Product Malfunction ________________________________________________________
Q Other (specify) ___________________________________________________________
Comments/Description of Event ________________________________________________
ATTACHMENTS Q Implicated Sample Q Associated Sample Q Letter
Received By QA Mgr ________________________________ Date ________________________________
Assigned To _______________________________________ Response Due ________________________
Distribution: Q Quality Control Q Engineering Q Production Q QA Q Sales Q Service
*** SAMPLE RECORD*** Sheet 5 of 5 of Procedure No. _________________
CUSTOMER ANALYSIS (Side 2) SEQUENTIAL NO. __________________________
Device Name ____________________________________ Model Number __________________________
Catalog Number __________ Lot Number ____________ Date of Complaint Report ___________________
Name of Complainant _____________________________________________________________________
Nature of Complaint ______________________________________________________________________
Date(s) Evaluation Performed______________________________________________________________________
Q Copy of evaluation attached
Q Device Defective Q Device Failed to Meet Specifications Q Improper Use
Q Shipping Damage Q Repair Request
Q Other(specify) _______________________________________________________________________________
ACTION/REPLY TO COMPLAINANT
- None. Reason for no action ______________________________________________________
Q Recalled. FDA phoned on - Date ______________ Spoke to ___________________________
Q Complaint Committee Informed on - Date ___________________ Q MDR Filed on - Date __________________
Q Referred to _________________________________ for Further Investigation or Correction
Q Replaced Q Repaired Q Credited Q Letter Sent Q Sales Follow Up
Q Reason for No Reply __________________________________________________________________________
FINAL DISPOSITION ___________________________________________________________________________
Reviewed by: Quality Assurance _____________________________________ Date ______________________-
If requested: Engineering __________________________________________ Date _______________
Production ______________________________________________________ Date ________________