Organ Recovery Systems Receives FDA Warning Letter

April 20, 2017

 

Dear Mr. Kravitz:

On January 17 through February 10, 2017, the U.S. Food and Drug Administration (FDA) conducted an inspection of your facility, located in Itasca, Illinois and determined that your firm is a specifications developer and manufacturer of class II medical devices that include Kidney Perfusion Solutions, Static Preservation Solutions, a Kidney Transporter and disposable perfusion kits. The SPS-1 Static Preservation Solution^® is intended for the flushing and cold storage of kidney, liver, and pancreas organs at the time of organ removal from the donor in preparation for storage, transportation and eventual transplantation into a recipient. Under section 201(h) of the Federal Food, Drug, and Cosmetic Act (the Act), 21 U.S.C. § 321(h), these products are devices because they are intended for use in the diagnosis of disease or other conditions or in the cure, mitigation, treatment, or prevention of disease, or to affect the structure or any function of the body.

This inspection revealed that your devices are adulterated within the meaning of section 501(h) of the Act, 21 U.S.C. § 351(h), in that the methods used in, or the facilities or controls used for their manufacture, packing, storage, or installation are not in conformity with the current good manufacturing practice requirements of the Quality System Regulation found at Title 21, Code of Federal Regulations (CFR), Part 820.  You may find the Act and FDA’s regulations through links in FDA’s home page at www.fda.gov.

Our investigators issued the Form FDA-483, Inspectional Observations, to you at the conclusion of the inspection on February 10, 2017.  We received a response, dated March 1, 2017, from, David C. Kravitz, President and CEO, concerning our investigator’s observations, noted on the Form FDA- 483 that was issued to your firm. We address this response below, in relation to each of the noted violations. These violations include, but are not limited to, the following:

1. The results of design validation, including identification of the design, method(s), the date and the individual(s) performing validation, were not adequately documented in the design history file, as required by 21 CFR 820.30(g).

Specifically, your firm did not perform a design validation of SPS-1 (UW Solution) Static Preservation Solution under defined operating conditions using initial production units or their equivalents.

1. You have relied on a public domain formulation of the product and cited publicly available journal articles for verification/validation activities. For example, (b)(4) SPS-1 Design & Manufacturing History (b)(4) states, “The University of Wisconsin organ preservation solution [“UW Solution”] marketed by Organ Recovery Systems, Inc. (“ORS”) as Static Preservation Solution (“SPS-1″) is a complex solution developed over a 15-year span at the University of Wisconsin.”

We reviewed your response and find it inadequate. FDA believes that the formulation alone does not constitute the entire device design. The design validation contained in your firm’s SPS-1 Design & Manufacturing History, (b)(4) CFR 820.30 (g). The design validation must be performed to ensure the proper overall design control and design transfer. is inadequate and does not meet the requirements set forth in 21

1. Your Solutions Shipping Validation Study (b)(4) is inadequate for the Static Preservation Solution SPS-1. The study was performed to verify that current packaging/shipping methods provide adequate protection and that anticipated (b)(4) variations during transport do not affect the ability of the product to meet functional specifications. The evaluation of the returned bags of solution consisted of (b)(4) inspection for (b)(4). The study was approved without taking adequate measures to evaluate the (b)(4) analysis of the solution. In addition, the (b)(4) inspection cannot adequately evaluate for functional specifications (b)(4) of the solution.

We reviewed your response to this violation and find it is not adequate. With respect to your firm’s response regarding Solutions Shipping Validation Study (b)(4)states that it was designed to evaluate the potential of shipping damage and to validate the process and procedures needed to ship SPS-1 using (b)(4) carriers without compromising the product. FDA disagrees that the (b)(4) inspection and (b)(4) testing conducted in the validation study demonstrated the adequacy of the shipping process adopted by your firm. Specifically, your firm has not provided adequate evidence to support that (b)(4) inspection alone can identify container integrity defects. The same holds true for the (b)(4) testing performed by (b)(4) to ensure there are no leaks in the Static Preservation Solution (“SPS-1”) container. In addition, FDA believes that the Shipping Validation Study (b)(4) should consider functional specification of the product post-shipment. The (b)(4) examination is not sufficient to support functionality of the device alone.

2. Procedures to ensure that all purchased or otherwise received product and services conform to specified requirements have not been adequately established, as required by 21 CFR 820.50
3. Your firm has not verified the (b)(4) validation process used for the manufacturing of SPS-1 (1L and 2L) and KPS-1 (1L) bags. In the calendar year of 2016, (b)(4) bags for the filling of organ preservation solution were (b)(4).

We reviewed your response to this violation and find it is not adequate. Your firm’s response states that (b)(4). Your firm has not provided evidence that the container closure integrity can be verified by (b)(4) examination.

1. Your firm has not verified the (b)(4) validation used for the sterilization of SPS-1 (1L and 2L) and KPS-1 (1L) bags. In the calendar year of 2016, your (b)(4) bags for the production of organ preservation solution.

Your firm’s response is inadequate as there was no evidence provided to support that the various SPS-1 and KPS-1 bags meet specifications for (b)(4) and sterility.

3. Procedures for control and distribution of finished devices have not been established, as required by 21 CFR 820.160(a).

Specifically, your firm has not adequately established the storage temperature requirements for SPS-1. The following inconsistencies exist:

1. The Device Master Record identifies a storage requirement at (b)(4).
2. The SPS-1 Stability Study ((b)(4)) identifies a storage requirement at (b)(4).
3. The Quality Agreement between Organ Recovery Systems, Inc. & (b)(4) identifies a storage requirement at (b)(4).
4. The (b)(4) Management SOP for your firm identifies a storage requirement at (b)(4).

Your firm’s response is inadequate in that it does not identify the storage requirements that were cleared for the device. Your firm’s response did not provide revised documents for our review nor did it address any potential impact for long-term storage of product above the +25C.

4. A process whose results cannot be fully verified by subsequent inspection and test has not been validated according to established procedures as required by 21 CFR 820.75(a).

Specifically, your firm monitors product storage temperature (including SPS-1 and KPS-1) by using (b)(4)at (b)(4) warehouse. The system is designed to provide your firm with (b)(4). This process has not been validated.

Your firm’s response is inadequate as it did not state what is being done in the meantime in lieu of having a validation for the (b)(4) Your firm’s response does not address if the conflicting storage requirements identified in observation 3 affected the finished product.  environmental warehouse controls. During the inspection, it was noted that an (b)(4) periodic temperature excursion at the (b)(4) exceeded the established storage condition of (b)(4).

5. Procedures for corrective and preventive action have not been adequately established, as required by 21 CFR 820.100(a).

Specifically, (b)(4) Corrective and Preventive Actions (b)(4) does not include adequate requirements to correct identified quality problems. Your firm identified inadequate sealing process validation was identified at the SPS-1 and KPS-1(b)(4) on 05/05/2015. (b)(4). The implemented validation was not reviewed nor approved by you until 06/21/2016; your firm continued to distribute product during this time. Additionally, you did not verify or validate that the sealing validation implemented by (b)(4) was effective and did not adversely affect the finished device.

Your firm’s response is inadequate as it does not address the observation to ensure CAPA procedures are adequately established to correct identified quality problems. Your firm’s response states that the final seal is (b)(4) inspected for leaks/seal failures and any noted failures are documented in (b)(4) at (b)(4). According to your firm’s response, (b)(4) uses (b)(4) inspection for the (b)(4) inspection. Your firm has not provided evidence that this process has been qualified to ensure inspection (b)(4) can identify all potential defects consistently. Your firm claims that the Instructions for Use (IFU), which physically accompanies each shipment of the product is a sufficient control to ensure leaking product is discarded before use. According to your firm’s response, the IFU directs the user to “Check each bag for leaks by squeezing the container firmly. If a leak is found, discard solution container”. This is not a mitigation step for not having a validated sealing of the SPS-1 and KPS-1 bag after filling to ensure container closure integrity of a sterile medical device.

6. A device Master Record has not been adequately maintained, as required by 21 CFR 820.181.

Specifically your firm’s Device Master Record Index DMR-000002 for the SPS-1 preservation solution does not include or refer to the location of, the following information:

1. Device specifications including appropriate drawings, composition, formulation, and component specifications;
2. Production process specifications including the appropriate equipment specifications, production methods, production procedures, and production environment specifications;
3. Quality assurance procedures and specifications including acceptance criteria and the quality assurance equipment to be used;
4. Packaging and labeling specifications, including methods and processes used.

Your firm should take prompt action to correct the violations addressed in this letter. Failure to promptly correct these violations may result in regulatory action being initiated by the FDA without further notice. These actions include, but are not limited to, seizure, injunction, and civil money penalties. Also, federal agencies may be advised of the issuance of Warning Letters about devices so that they may take this information into account when considering the award of contracts. Additionally, premarket approval applications for Class III devices to which the Quality System regulation violations are reasonably related will not be approved until the violations have been corrected. Requests for Certificates to Foreign Governments will not be granted until the violations related to the subject devices have been corrected.

Finally, you should know that this letter is not intended to be an all-inclusive list of the violations at your firm’s facility. It is your firm’s responsibility to ensure compliance with applicable laws and regulations administered by FDA. The specific violations noted in this letter and in the Inspectional Observations, FDA 483, issued at the close of the inspection may be symptomatic of serious problems in your firm’s manufacturing and quality management systems. Your firm should investigate and determine the causes of the violations, and take prompt actions to correct the violations and bring the products into compliance.

Please notify this office in writing within fifteen (15) business days from the date you receive this letter of the specific steps your firm has taken to correct the noted violations, as well as an explanation of how your firm plans to prevent these violations, or similar violations, from occurring again. Include documentation of the corrections and/or corrective actions (including any systemic corrective actions) that your firm has taken. If your firm’s planned corrections and/or corrective actions will occur over time, please include a timetable for implementation of those activities. If corrections and/or corrective actions cannot be completed within fifteen business days, state the reason for the delay and the time within which these activities will be completed. Your firm’s response should be comprehensive and address all violations included in this Warning Letter.

Refer to the Unique Identification Number (CMS Case #519572) when replying. If you have any questions about the content of this letter, please contact Mr. Padilla via email at Rafael.padilla@fda.hhs.gov or by phone at (312) 596-4212.

Sincerely,

/S/

Williams R. Weissinger

District Director