1
A clear title, with “Urgent field safety notice” followed by the commercial name of the affected product, an FSCA-identifier (e.g., date) and the type of action.
2
Specific details to enable the affected product to be easily identified e.g. type of device, model name and number, batch/lot or serial numbers of affected devices and part or order number.
3
A factual statement explaining the reasons for the FSCA, including description of the device deficiency or malfunction, clarification of the potential hazard associated with the continued use of the device and the associated risk to the patient, user or other person and any possible risks to patients associated with previous use of affected devices.
4
Advice on actions to be taken by the user. Include as appropriate:
identifying and quarantining the device,
method of recovery, disposal or modification of device,
recommended review of patients previous results or patient follow up, e.g., implants, IVD,
timelines.
5
A request to pass the field safety notice to all those who need to be aware of it within the organization and to maintain awareness over an appropriate defined period.
6
If relevant, a request for the details of any affected devices that have been transferred to other organizations, to be given to the manufacturer and for a copy of the field safety notice to be passed on to the organization to which the device has been transferred.
7
If relevant, a request that the recipient of the field safety notice alerts other organizations to which incorrect test results from the use of the devices have been sent, for example failure of diagnostic tests.
8
Confirmation that the relevant national Competent Authorities have been advised of the FSCA.
9
Any comments and descriptions that attempt to play down the level of risk in an inappropriate manner or advertise products or services should be omitted.
10
Contact point for customers how and when to reach the designated person. An acknowledgment form for the receiver might also be included (especially useful for manufacturer’s control purposes).
3 Results
3.1 Number of Reports and FSCA
Between January 1, 2000 and December 31, 2013 BfArM received a total of 61,904 reports regarding medical devices. Of these 57,356, 28,715, 28,641, and 4,548 reports were related to medical devices in total (both, active and non-active), active medical devices, non-active medical devices, and IVD, respectively. Out of the 61,904 reports, 50,053 were received within the study period of January 1, 2005 and December 31, 2013, from which 45,938, 23,394, 22,544, and 4,115 were related to medical devices in total (both, active and non-active), active medical devices, non-active medical devices, and IVD, respectively. Comparison of the notifications reported to the BfArM in the years 2000, 2005, and 2013 underlines a strong increment of reports to this Competent Authority (3,387 in 2005 vs. 1,934 in 2000: +75.1 %, 8,252 in 2013 vs. 1,934 in 2000: +326.7 %, and 8,252 in 2013 vs. 3,387 in 2005: +143.6 %). A total of 6,465 FSCA were publicized since January 1, 2005 of which 4,912 were related to active and non-active medical devices and 1,553 to IVD, which also demonstrates a strong increase (1,077 in 2013 vs. 483 in 2005: +123.0 %) within the observation period (Table 2). Based on the inclusion criteria, only FSCA related to medical devices for use in pulmonology were analyzed in the present study. These were 41 FSCA mostly for active medical devices (6 nebulizers, 7 oxygen concentrators, 15 pulse oximeters, 4 lung function analyzers, and 9 devices serving for pleural drainage, treatment of lung emphysema, or bronchial stenosis).
Table 2
Number of notifications to the BfArM 2000–2013 and number of FSCA publicized by the BfArM 2005–2013
Year | Active medical devices, except IVD | Non-active medical devices, except IVD | All medical devices, except IVD | IVD | Total |
---|---|---|---|---|---|
Notifications | Notifications | Notifications (FSCA) | Notifications (FSCA) | Notifications (FSCA) | |
2000 | 926 | 987 | 1,913 (—-) | 21 (—-) | 1,934 (—-) |
2001 | 906 | 1,080 | 1,986 (—-) | 33 (—-) | 2,019 (—-) |
2002 | 995 | 1,213 | 2,208 (—-) | 58 (—-) | 2,266 (—-) |
2003 | 1,116 | 1,298 | 2,414 (—-) | 121 (—-) | 2,535 (—-) |
2004 | 1,378 | 1,519 | 2,897 (—-) | 200 (—-) | 3,097 (—-) |
2005 | 1,515 | 1,665 | 3,180 (348) | 207 (135) | 3,387 (483) |
2006 | 1,769 | 1,858 | 3,627 (391) | 235 (116) | 3,862 (507) |
2007 | 2,179 | 1,884 | 4,063 (388) | 583 (150) | 4,646 (538) |
2008 | 2,290 | 2,087 | 4,377 (533) | 506 (143) | 4,883 (676) |
2009 | 2,361 | 2,141 | 4,502 (615) | 392 (149) | 4,894 (764) |
2010 | 2,792 | 2,506 | 5,298 (544) | 482 (180) | 5,780 (724) |
2011 | 3,269 | 2,395 | 5,664 (666) | 474 (194) | 6,138 (860) |
2012 | 3,400 | 4,238 | 7,638 (646) | 573 (190) | 8,211 (836) |
2013 | 3,819 | 3,770 | 7,589 (781) | 663 (296) | 8,252 (1077) |
All | 28,715 from these 23,394 since begin 2005 | 28,641 from these 22,544 since begin 2005 | 57,356 from these 45,938 since begin 2005 (4,912 FSCA since begin 2005) | 4,548 from these 4,115 since begin 2005 (1,533 FSCA since begin 2005) | 61,904 from these 50,053 since begin 2005 (6,465 FSCA since begin 2005) |
3.2 Fulfillment of MEDDEV Criteria
German and English FSN were found in 36 and 35 cases, respectively (nebulizers 6/4, oxygen concentrators 5/6, pulse oximeters 15/13, lung function analyzers 2/3, and devices for pulmonary treatment 8/9) (Table 3). FSN were clearly characterized as such in 22/20 cases and names of the affected products were provided in 36/35 cases. Lot numbers were provided in 7/8 cases and other attributions for product identification was available in 26/24 cases, respectively. Detailed information regarding the FSCA and product malfunction was found in 27/33 and 36/35 cases, respectively. Product malfunction was due most frequently to a fault in construction and production of the product or an issue with the raw material and components of the product in 27/27 cases. Examples of these were issues in the power supply (mains adapter or battery, 5/5 cases), issues with overheating resulting in an increased fire hazard (5/5), and issues of sensor components (4/4 cases), likely as these components seem to be a fragile and sensitive part of the affected systems. In 3/2 cases a product deficiency could be excluded and the FSCA was made due to a revision of the standard specifications, preventive revision of instructions for use to implement further safety recognitions and preventive expansion of warning notices and protective measures in the instructions for use and in 1/1 case the manufacturer informed customers about product counterfeiting. A software error or an erroneous installation of software was reported in 2/2 cases and an invalid alerting was also reported in 2/2 cases of German and English FSN, respectively. In 1/1 case, a specific description of the product malfunction was impossible because the root-cause analysis was not finished at the time of the FSN.
Table 3
Compliance of the FSN to the criteria of Guideline MEDDEV 2.12-1 rev 8
German/English | |
---|---|
Number of FSCA | 41 |
Number of FSN | 36/35 |
FSN is clearly to identify as FSN for users | 22/20 |
Declaration of the product name in the FSN | 36/35 |
Declaration of the type of action | 27/26 |
Declaration of the Lot-No. < div class='tao-gold-member'>
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