FDA Medical Device Update

US Food and Drug Administration New England District

Position at NWE-DO

 Supervisory Investigator (May 2002)  Monitor for Medical Device Program  MDUFMA Coordinator

What is a Program Monitor?

Work for the District is in ~87 different program areas – examples:

    Foods – – – – – – Imported cheese Domestic Fisheries Infant formula Juice processing Pesticides …Many more Interstate Travel Dietary Supplements Blood banks       Clinical Investigators Drug process inspections New Animal Drug inspections BSE (mad cow) Medical devices (Domestic and foreign) Mammography facilities

Program Monitoring

 All 87 programs are split among the 7 supervisors.  Each has 12-14 programs for which s/he is the monitor

Investigations Branch Staffing

Position

Consumer Safety Officers Consumer Safety Inspectors Supervisory CSOs

2006 2004

64 85 7 7 7 8

NWE-DO OEI

Total firms 12/2006 12/2004 8857 Device firms 3004 Class II and III firms 556 8365 2781 535

New England District

Domestic Inventory

CFSAN CBER CDER CVM CDRH CBER 3% CFSAN 48% CDER 12% CVM 2% CDRH 35%

~50% of 8857 firms are food firms

Program monitor role

      Identify the firms to be inspected or investigated Verify that assignments are created Assure the work is done and properly reported Try to keep OEI up-to-date Summarize accomplishments for management Be the Point of Contact for that program

Device Program – firm selection

 CDRH guidance  Workplan – Budget – Staffing  Inspectional History

CDRH Device Inspection Guidance

 Inspect 20% of Registered Domestic Class II and Class III Medical Device Manufacturers, i.e., 1,030. (NWE-DO: 98)  Inspect 7% of Registered Foreign Class II and Class III Medical Device Manufacturers, i.e. 168 inspections.

 Conduct CDRH BIMO Inspections, i.e., 278 inspections.

CDRH Device Inspection Guidance

     For Cause MDUFMA – PMA/GMP inspections and other pre market inspections including BIMO Follow-Up to Violative Inspections High/Significant Risk Class III and II Manufacturers Special Emphasis – – Focus on Firms with Repeated Violative Inspections Focus on Risk-Based Center Initiated Inspection Assignments

Risk-based Work Plan Initiative

  CDRH “Call for Proposals”. The Call process incorporates involvement from both Center and Field sources focusing on risks, hazards, justified concerns, and output from various databases to achieve those devices and eventual individual manufacturers, which indicate need for Agency inspectional resources. This is a directed inspection request with specific inspectional guidance in addition to GMP inspection.

FY’07 Device Workplan

Level I Level II Compliance f/u For Cause High Risk Domestic Foreign AP

TOTAL

FY2007 65 43 2 7 7 15 2

141

FY2006 84 53 8 9 -- 17 9

180

NWE-DO Staff

 Staff with devices as primary program = 12  Staff with devices as second program = 9

Training activities

 10 CSOs to Basic Medical Device   2 CSOs to process validation 1 CSO to industrial sterilization  1 level II certification audit  2 level II certified  1 auditor certified  1 AP auditor certified

Pre-announcement of Inspection

 Most inspections are pre-announced  NOT pre-announced: – f/u to Compliance action (W/L, etc.) – f/u to Complaint or informant – f/u to observe promised corrections (VAI)

FY’06 District accomplishments

QS/GMP Inspectional Accomplishments

Domestic Foreign Total # OPS Planned # OPS Accomplished 129 146 15 14 144 160

FY’06 Compliance actions

 4 NWE-DO Medical Device firms had EI classified as OAI with Warning letter recommended – 3 Warning letters issued

Summary of FY’06 Recalls

 Total recalls in NWE-DO = 212  Total CDRH recalls in NWE-DO = 145 – Class 1: 15 – Class 2: 116 – Class 3: 14

Summary of Consumer Complaints (separate from MedWatch)

 FY’05 - 13 Consumer Complaints regarding Medical Devices  – 5 resulted in for-cause inspections FY’06 - 13 Consumer Complaints regarding Medical Devices – 3 resulted in for-cause inspections

Summary of for- cause Inspections FY’05 +’06

         f/u to verify corrections - 15 f/u to consumer complaint - 9 – Inside informants – 7 Recall f/u – 8 CDRH Risk Based assignment - 6 f/u to violative EI @ another firm - 6 f/u to injury report – 2 Trade complaints – 2 Shipment of products not approved for US mkt – 1 Request of a State - 1

Summary of 483s

 62/129 FY’06 device inspections had a 483 issued – i.e. in 48% of Medical Device inspections – vs. 47% of all product inspections in NWE-DO

Other FY’06 NWE-DO Medical Device accomplishments

        3 Pre-Market Approval inspections 7 Post-Market Audit inspections 3 Non-clinical studies 6 IRBs (2 U/L) 5 Sponsor/Monitor/CRO (1 W/L) 7 Clinical Investigators 50 Mammography 52 Import Field Exams

Other FY’06 NWE-DO Medical Device accomplishments

 2 AP inspections including one level 3 audit – Candidate failed the audit, but then corrected and passed  2 NWE-DO firms approved for use of third party inspectors under the AP program

Contact Info

 William S. Boivin  781-596-7783 (phone)  781-596-7896 (fax)  [email protected]