Effective Complaint Handling, Medical Device Reporting and Recalls -- Avoiding Costly Errors: One and a Half-day In-person Seminar
Rita Hoffman, RAC, Managing Partner Regs & Recall Strategies, LLC and Former FDA CDRH Recall Branch Chief
San Diego, CA
Thursday, October 16, 2014 | Friday, October 17, 2014
San Antonio, TX
Thursday, November 6, 2014 | Friday, November 7, 2014
This interactive one and a half day course led by Ms. Rita Hoffman, Former FDA CDRH Recall Branch Chief, who has more than 36 years’ experience with the FDA will provide the participants tools to minimize risk of regulatory enforcement actions.
During the seminar, Ms. Hoffman will explain proper handling of complaints reportable or non-reportable, product complaint handling and documentation, how and when to file Medical Device Reports (MDR), effective and appropriate communication with the appropriate regulatory agencies in the event of a recall. She will also discuss how to conduct a correction and removal actions to avoid a recall crisis, including required recordkeeping, expectation from FDA and other regulatory agencies in the event of a recall and key factors in implementing and maintaining compliance with the regulations and real life experiences of FDA.
Medical Device Reporting (MDR) and recall compliance are critical to the continue survival of all device manufacturers. The FDA is continuing their efforts to issue numerous FDA Warning Letters and serious enforcement actions, including criminal & civil penalties levied on companies that failed to properly report events and take proper corrective and removal actions. The number of device companies having their recall classified as a Class 1 (most severe) recall has surged in the past three years. Additionally, product liability and financial risks are staggering when companies fail to properly report and take action when required. This course will provide an understanding of MDR & recall compliance and the interrelationship of Complaint Handling, CAPA, and Risk Management processes. It will be beneficial to all device manufacturers and is recommended for any individuals or teams that are involved in medical device reporting (MDR) and correction & removal processes, including recalls.
Seminar instructor Ms. Rita Hoffman is the former FDA CDRH Recall Branch Chief and has more than 36 years of FDA experience across the device, drug and veterinary industries.
- Understand how to comply with complicated Compliant Handling, MDR and Recall requirements.
- Firms MDR reporting and FDA's handling of reports.
- Company preparation in the event of a Recall, recall strategy, notification letter and communicating with the FDA.
- Minimize your risk of regulatory enforcement actions.
- Assist with the creation and maintenance of effective procedures for handling complaints, reportable events and recalls.
- Understand the relationship and interaction with other quality system elements as they relate to complaints and reportable events.
- Walk-through of case examples.
Who will Benefit:
This course will benefit anyone in the medical device industry that handles functions involving product complaints, recalls, medical device reporting.
- Regulatory Affairs
- Project Managers
- Regulatory Professional
- Risk Managers
- Complaint Handling Teams
- CAPA Teams
|Conference Day One (8:30 AM – 5:00 PM)
||Conference Day Two (8:30 AM – 12:00 PM)
- Registration Process: 8:30 AM - 9:00 AM
- Session Start: 9:00 AM
- Introduction to class (20 min)
- Complaint Handling and FDA Expectations (70 min)
- What is a complaint?
- Firms Responsibilities and Definitions
- Complaint Forms
- FDA Expectations for written procedures on complaint files
- Medical Device Reporting Procedures (MDR) (60 min)
- Understand the MDR regulation 21CFR 803
- Definitions 21 CFR 803.3
- MDR Procedures 21 CFR 803.17
- Types of MDR reports
- MDR reporting by firm, agents and exemptions
- MDR FDA Perspective (30 min)
- CDRH Mandatory vs. Voluntary Reporting
- What happens to an MDR report submitted to FDA
- Manufacturer and User Facility Device Experience (MAUDE)
- Medical Products Safety Network (MedSun)
- User Error Malfunction
- Identifying a Malfunction
- Malfunction --To report or not to report
- Serious injury triggers
- Person Qualified Makes Medical Judgment
- Recalls: Definitions and Legal Authority (45 min)
- What is a recall?
- Legal Authority (Chapter 7, 21CFR 806)
- Voluntary vs. Mandatory recalls
- Definitions – Corrections, Removals
- Reporting requirements for non-recall field actions
- Classification system – Classifying a Recall?
- What is different about Class 1 recall
- Being Recall Ready –Proactive Steps to Avoid Crisis (45 min)
- Internal Decision Making
- Early warning signs
- Assembling “The Team” – Assigning decision making authority
- Examples of Close-calls
- Guidelines and best practices for having contingency plan in place
- Evaluating Risk and Health Hazard Evaluation (HHE) (60 min)
- Analyzing adverse event and product quality reports
- Identifying trends, Data and factors to consider
- Assessing need to conduct HHE
- HHE Procedures
- Human Factors Issues
- Opening a CAPA to Determine Root Cause
- Developing effective Strategies and Communicating with FDA (80 min)
- Elements of a good Recall Strategy
- What does the FDA expect strategy to contain?
- Effective Notification Letter to minimize consequences
- Knowing when to contact FDA District
- Discussing Recall Strategy with FDA – Seeking input and support of your strategy to avoid common pitfalls
- Issuance of Press Release and communication with customers
- Silent Recalls vs. Product Enhancements (20 min)
- Device changing environment
- Product improvement (Repair or Modification)
- Decision 803 or 806
- Product Retrieval Issues, Effectiveness Checks and Status Reports (50 min)
- Receiving and accounting for returned products
- Supply chain challenges – distribution, wholesale, repackaging
- Global recall market
- Designing an efficient Effectiveness Checks
- Coordination and Discussion with FDA
- Evaluating recall effectiveness Data
- Developing and formatting status reports
- Termination of a Recall (15 min)
- Who, how and when does termination happen
- Exporting a Recalled Product
- Communication between firm and District Office
- Requesting formal closeout by FDA
- Mock Recall and Wrap-up (35 min)
Meet Your Instructor
||Rita Hoffman, RAC,
Managing Partner Regs & Recall Strategies, LLC and Former FDA CDRH Recall Branch Chief
Rita Hoffman, RAC. Managing Partner Regs & Recall Strategies, LLC .Ms. Hoffman has more than 36 years of FDA experience across the device, drug and veterinary industries. She has an intimate understanding of FDA regulatory and compliance issues from the perspective of both FDA and regulated industry. As an FDA compliance consultant, she provides clients with regulatory insight, advises on critical compliance deficiencies, performs compliance and new product audits, provides insight and guidance on recall strategies to the medical device industry, and advises on jurisdiction determinations for combination products.
Ms. Hoffman retired from the FDA in January 2011 as the Recall Branch Chief for the Center for Devices and Radiological Health (CDRH), where she was responsible for oversight and review for all medical device recalls. Ms. Hoffman held several positions including the Center for Drug Evaluation and Research (CDER) Jurisdiction Review Officer (providing guidance on drug/device product designation, combination products and co-packaging), Acting Associate Ombudsman, Small Business Liaison, and was a Policy Analyst for eight years in the Office of the Commissioner. She served as co-chair of RAPS’ Baltimore/Washington Metropolitan Area Chapter for 2-terms, and in 2008 was presented with the Special Recognition Award by RAPS.
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San Diego, CA (Venue to be announced shortly)
October 16-17, 2014
San Antonio, TX (Venue to be announced shortly)
November 6-7, 2014
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San Diego, CA, Local Attractions
San Antonio, TX, Local Attractions
San Diego Cabrillo National Monument
The first European to set foot in California was the Spanish explorer Juan Rodriguez Cabrillo, who stepped on shore near this spot in in 1542. He's the guy they made this statue to look like - and named the park after. We don't know if Cabrillo climbed all the way up to the top of this promontory or not, but people who make up here nowadays get some of the best views of San Diego, looking across the Bay and back toward downtown.
Sea Creatures at Birch Aquarium
Birch Aquarium is north of San Diego in La Jolla. It's not as big as some of the other aquariums in California or as flashy as the big sea-themed park down the road, but instead just right, filled with interesting exhibits and home to leafy sea dragons like the one above, creatures so improbably they look more like something from a children's book than from the ocean.
Legoland theme park takes its inspiration from Lego toys, those cute little bricks that snap together to build all kinds of fun things. It's one of several Legolands worldwide.
San Diego Zoo Safari Park
The San Diego Zoo's sister park offers a different kind of animal experience. Its name (Safari Park) is the clue and it indeed offers a more safari-like experience. Lots of large animals live in the same big, open areas here - predators kept away from prey, but otherwise much as they would in their natural habitat.
Coronado isn't really an island but a peninsula - a fact that doesn't get in the way of the name most people use for it. Whatever you call it, it's on a slender strip of land between the San Diego Bay and the Pacific Ocean, barely a few blocks wide. What it lacks in size it makes up for in fun, with a beach that's been named among the best in the country, a classic hotel and a compact, lively little downtown. Coronado's laid-back temperament makes a nice break from the busier parts of San Diego across the water.
Originally built for temporary use during the 1915-16 Panama-California Exposition in San Diego, Balboa Park boasts buildings beautiful enough to be considered attractions in themselves, especially if you're a photographer. They're surrounded by trees, lawns and fountains, but that's only the beginning.
In Spanish, La Jolla means "the jewel," an apt name for a pretty, Mediterranean-style seaside town - sitting on cliffs flanking the ocean.
La Jolla visitors like to shop and eat in the nice restaurants, some of them with lovely ocean views. There's a lot for the active visitor, too, including ocean kayaking, tide pool-hopping, surfing at Windansea Beach, biking or running along the waterfront.
Riverwalk San Antonio
Riverwalk San Antonio is a charming stretch of walking paths lined with shops, bars and restaurants that wind along the banks of the San Antonio River. Also known as Paseo del Río, the Riverwalk passes one story below downtown San Antonio, Texas and offers a splendid walking tour that includes the San Antonio Museum of Art, Rivercenter mall, HemisFair Park and much more.
SeaWorld San Antonio
SeaWorld San Antonio is a marine-life theme park that covers a sprawling 250 acres in the Westover Hills area of San Antonio, Texas. Park offers roller coasters, rides, shows, tours, attractions & family-friendly activities for thrill seekers & animal lovers. There are plenty of rides too, and Shamu's Happy Harbor with little kids rides like Pete's Pinwheel, Shamu Express and Jumpin' Jungle.
Six Flags Fiesta Texas
Six Flags Fiesta Texas is a theme park located on approximately 200 acres of land in San Antonio, Texas, USA. Six Flags Fiesta features six main theme areas to have fun: Crackaxle Canyon, Fiesta Bay Boardwalk, Los Festivales, Spassburg, Wiggles World and Rockville.
Natural Bridge Caverns
Experience one of the world's premier caverns, Natural Bridge Caverns. This beautiful and historical cavern system offers an experience that is high energy, educational, fun and family oriented. Whether you are a first timer, an avid caver or someone in between, Natural Bridge Caverns awaits with a once in a lifetime experience you'll never forget.
Tower of the Americas
Located in downtown San Antonio, the 750-foot-tall Tower of the Americas provides guests the most spectacular view of the Alamo City. Enjoy the gorgeous panorama from the Tower's revolving Chart House Restaurant, take in the scenery from the Observation Deck or experience the thrilling 4D Theater Ride.
San Antonio Zoo
The third largest zoo in the U.S., the San Antonio Zoo is one of the oldest as well. Today, more than 3,500 animals reside at the zoo, representing 600 special of animals on 56 acres. The zoo's annual attendance exceeds 1,000,000.
The Witte Museum is San Antonio's premiere museum of South Texas history, culture, and natural science. The permanent collection features historic artifacts and photographs, Texas art, textiles, the world-renowned Hertzberg Circus Collection, dinosaur bones, cave drawings, Texas wildlife dioramas and the four-story H-E-B Science Treehouse; in addition to nationally acclaimed traveling exhibits.