Making Complaint Management an Effective Business Driver. Presented by: Richard J. DeRisio, M.S. Kinetic Concepts, Inc. Preliminary Findings Complaint Handling Survey. Sponsored by Compliance-Alliance www.compliance-alliance.com. Number of Employees.
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Richard J. DeRisio, M.S.
Kinetic Concepts, Inc.
Sponsored by Compliance-Alliance
The word “complaint” appears 82 times in the Quality System Preamble and Regulation
“Complaint means 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.”
[Compare ISO 13485:2003: §3.4: Customer Complaint: “…written, electronic or oral communication that alleges deficiencies related to identity, quality, durability, reliability, safety or performance of a medical device that has been placed on the market…”]
(a) Each manufacturer shall maintain complaint files. Each manufacturer shall establish and maintain procedures for receiving, reviewing, and evaluating complaints by a formally designated unit.
Such procedures shall ensure that:
(b) Each manufacturer shall review and evaluate all complaints to determine whether an investigation is necessary. When no investigation is made, the manufacturer shall maintain a record that includes the reason no investigation was made and the name of the individual responsible for the decision not to investigate.
[Compare ISO 13485:2003, §8.5 – Improvement: “If any customer complaint is not followed by corrective and/or preventive action, the reason shall be authorized (see 5.5.1) and recorded (see 4.2.4)”.]
Processing Steps upon Receipt of Complaint
(c) Any complaint involving the possible failure of a device, labeling, or packaging to meet any of its specifications shall be reviewed, evaluated, and investigated, unless such investigation has already been performed for a similar complaint and another investigation is not necessary.
Extent of the investigation is a function of risk potential
When Complaint Investigation is NOT Required:
(d) Any complaint that represents an event which must be reported to FDA under part 803 of this chapter 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 otherwise clearly identified. In addition to the information required by §820.198(e), records of investigation under this paragraph shall include a determination of:
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.
(e) When an investigation is made under this section, a record of the investigation shall be maintained by the formally designated unit identified in paragraph (a) of this section. The record of investigation shall include:
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.
Rationale for Closing a Complaint Without CAPA
Final Quality Assurance Review of the file
(f) When the manufacturer’s formally designated complaint unit is located at a site separate from the manufacturing establishment, the investigated complaint(s) and the record(s) of investigation shall be reasonably accessible to the manufacturing establishment.
(g) 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 either:
1)A location in the United States where the manufacturer’s records are regularly kept; or
2) The location of the initial distributor.
#14 - Service reports representing reportable adverse events are complaints
- FDA clarified definition of complaints to exclude input unrelated to quality, safety and effectiveness
- Service requests and internal expressions of dissatisfaction are addressed under CAPA, §820.100
(“Information generated in-house relating to quality problems should be documented and processed as part of this corrective and preventive action program.”)
#161 - CAPA is broader than complaints: includes product issues before and after distribution as well as process and quality system nonconformities
#190 - Distinction between complaint evaluations and investigations: these are not the same
- FDA definition of a good-faith follow-up for complaint information
Still a week to go… PerformanceComplaints Open/Closed
Dec ’04 – Feb ’05: Complaint process redesign period – few complaints closed.
May ’05 – Aug ’05: Campaign to increase complaint and service experience reporting from all sales, service and customer support personnel.
Increase in complaint input preceded increases in staff support requiring extra effort to close complaints in a timely manner.
Advantage: more detail regarding known failure modes; additional returned samples for analysis.
Complaint department’s tool for identifying root cause of open complaints.