FDA WARNING_LETTER - BioMedix Vascular Solutions, Inc. - August 06, 2008
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During an FDA inspection from June 17 to August 6, 2008, BioMedix Vascular Solutions, Inc., manufacturer of the PADnet+ noninvasive cardiovascular blood flow monitoring system, was found to be in violation of Current Good Manufacturing Practice (CGMP) requirements of the Quality System (QS) regulation (21 CFR Part 820). The device is considered adulterated under section 501(h) of the Act.
Key violations include: 1. **Failure of management with executive responsibility** to ensure a fully implemented and maintained quality system (21 CFR 820.20), specifically regarding inadequate complaint handling, insufficient management reviews, un-implemented CAPA procedures, and infrequent internal quality audits. 2. **Failure to investigate complaints** involving possible device failures (21 CFR 820.198(c)), with examples cited for inaccurate measurements, incorrect data storage, irregular pressure recording, cuff inflation issues, and non-functioning devices. 3. **Failure to implement corrective and preventive action (CAPA) procedures** (21 CFR 820.100(a)), with numerous CPARs (Corrective Preventive Action Reports) not completed by due dates, not reviewed by executive management, lacking root cause investigations, and not verifying effectiveness. 4. **Failure to conduct quality audits at sufficient regular intervals** (21 CFR 820
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