URGENT FIELD SAFETY NOTICE FLEXMEDICS PATIENT PACKS - BFARM

 
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FlexMedics, Inc.

Rev 1: September 2018
        FSN Ref:1833132-01/24/2021-001-R               FSCA Ref: 1833132-01/12/2021-001-R

Date:24:JAN:2021

                               Urgent Field Safety Notice
                               FlexMedics Patient Packs

TO WHOM IT MAY CONCERN (Place Holder for Customer Name)

    Contact details of local representative (name, e-mail, telephone, address etc.)*

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FlexMedics, Inc.
Rev 1: September 2018
        FSN Ref:1833132-01/24/2021-001-R                      FSCA Ref: 1833132-01/12/2021-001-R

                              Urgent Field Safety Notice (FSN)
                                 FlexMedics Patient Packs
                                  Risk addressed by FSN

                                    1. Information on Affected Devices*
    1         1. Device Type(s)*
    .
        Non-sterile elastic, orthodontic bands. Orthodontic elastics, also referred to as rubber
        bands, are small stretchy loops of rubber that help move teeth into proper alignment
        during orthodontic treatment.
    1       2. Commercial name(s)
    .   FlexMedics Patient Packs
    1       3. Unique Device Identifier(s) (UDI-DI)
    .   N/A
    1       4. Primary clinical purpose of device(s)*
    .   Their purpose is to create additional force for tooth movement in any of the three
        dimensions that is more difficult using braces alone
    1       5. Device Model/Catalogue/part number(s)*
    .   AMD18, AMD36, AMD56, AMH14, AMH18, AMH36, AML36, AML56, LFH14, LFH36, LFM14,
        LFM36
    1       6. Software version
    .   N/A
    1       7. Affected serial or lot number range
    .   802028, 803093, 811672, 811673, 813659, 813660, 813664, 813666, 813669, 822714, 822716,
        822724, 827154, 827161, 827172, 827173, 830878, 832605, 835151, 835158
    1       8. Associated devices
    .   N/A

                        2 Reason for Field Safety Corrective Action (FSCA)*
    2         1. Description of the product problem*
    .   While both released product and labelling are accurate, a change was made that resulted in the
        color scheme of the FlexMedics Patient Packs product to be updated which was not intended and
        could result in consumer confusion and/or patient discomfort. The color scheme for FlexMedics
        Patient Packs elastic bands which might be used to differentiate sizes of product by different
        colors was inadvertently changed. This recall does not affect any other batches/lots/versions of
        FlexMedics Patient Packs or any other FlexMedics products. This version has been
        manufactured since 9-OCT-2020.
    2         2. Hazard giving rise to the FSCA*
    .   FlexMedics does not expect device failures; instead, there is an opportunity for misuse of the
        device if the label is not read. If the band is too small and still applied, the band could break. If
        the band is too small, the treatment may be more aggressive. It is important to note that elastic
        band force decreases quickly over time. Both circumstances could result in temporary patient
        discomfort.
    2      3. Probability of problem arising
    .   The probability of a problem arising is “Not likely that use will cause any adverse events”
    2      4. Predicted risk to patient/users
    .   The predicted risk to patients/users is minimal.
           5. Further information to help characterise the problem

1
Rev 1: September 2018
        FSN Ref:1833132-01/24/2021-001-R                     FSCA Ref: 1833132-01/12/2021-001-R

    2    Use of incorrect size or force value of elastic band is not likely to lead to Death,
    .    Permanent Impairment or injury or impairment which might require substantial
         professional intervention/treatment.
    2        6. Background on Issue
    .    FlexMedics became aware of the issue through 3 complaints (21-01-005, 20-12-057, and 20-12-
         038). The complaints came from three different distributors in December of 2020. The complaints
         described the incorrect color and addition of a new letter on the patient pack. No injuries or death
         have been reported. All the label information written on the patient pack is correct, including part
         number, elastic band size and force value. However, the color of the written text is inconsistent
         with what we have manufactured in the past. The letter is also not appropriately associated to force
         values, but instead also refers to band size.
    2       7. Other information relevant to FSCA
    .    N/A

                                    3. Type of Action to mitigate the risk*
    3. 1. Action To Be Taken by the User*

             ☐Identify Device☐Quarantine Device ☐ Return Device                Destroy Device

             ☐On-site device modification/inspection

             ☐Follow patient management recommendations

             ☐Take note of amendment/reinforcement of Instructions For Use (IFU)

             ☐ Other               ☐ None

    3.   2. By when should the
            action be completed?             As soon as possible, within the next 30 days.

    3.   3. Particular considerations for:Choose an item.

             Is follow-up of patients or review of patients’previous results recommended?
             Patient follow-up is not recommended by the manufacturer. However, while both released
             product and labelling are accurate, the change was made that resulted in the color scheme
             of the FlexMedics Patient Packs product to be updated which was not intended and could
             result in consumer confusion and/or patient discomfort. Doctors should assess whether the
             minimal risk to patients could have been realized by applying the incorrect product.

    3.   4. Is customer Reply Required? *                                           No
         (If yes, form attached specifying deadline for return)
    3. 5. Action Being Taken by the Manufacturer

             ☐Product Removal ☐On-site device modification/inspection
             ☐Software upgrade☐ IFU or labelling change
            Other              ☐ None

             FlexMedics top management intends to replace product with material representative of
             customer expected color scheme as of 19-JAN-2021.

2
Rev 1: September 2018
        FSN Ref:1833132-01/24/2021-001-R                FSCA Ref: 1833132-01/12/2021-001-R

    3    6. By when should the               As requested by customers
            action be completed?
    3.   7. Is the FSN required to be communicated to the patient             No
            /lay user?
    3    8. If yes, has manufacturer provided additional information suitable for the patient/lay
            user in a patient/lay or non-professional user information letter/sheet?
            Choose an item.Choose an item.

3
Rev 1: September 2018
        FSN Ref:1833132-01/24/2021-001-R                     FSCA Ref: 1833132-01/12/2021-001-R

                                                 4. General Information*
    4.   1. FSN Type*                                     New

    4.   2. For updated FSN, reference          Provide reference and date of previous FSN if
            number and date of previous         relevant
            FSN
    4.   3. For Updated FSN, key new information as follows:
             Summarise any key difference in devices affected and/or action to be taken.

    4.   4. Further advice or information           No
            already expected in follow-up
            FSN?*
         5. If follow-up FSN expected, what is the further advice expected to relate to:
    4
             Eg patient management, device modifications etc

         6. Anticipated timescale for follow-             For provision of updated advice.
    4       up FSN
    4.   7. Manufacturer information
         (For contact details of local representative refer to page 1 of this FSN)
               a. Company Name                         FlexMedics, Inc
               b. Address                              2165 Earlywood Drive, Franklin, IN 46131, USA
               c. Website address                      ghorthodontics.com
    4.   8. The Competent (Regulatory) Authority of your country has been informed about this
             communication to customers.*

    4.   9. List of attachments/appendices:           N/A
    4.   10. Name/Signature

                               Transmission of this Field Safety Notice
         This notice needs to be passed on all those who need to be aware within your organisation or to
         any organisation where the potentially affected devices have been transferred. (As appropriate)

         Please transfer this notice to other organisations on which this action has an impact. (As
         appropriate)

         Please maintain awareness on this notice and resulting action for an appropriate period to ensure
         effectiveness of the corrective action.

         Please report all device-related incidents to the manufacturer, distributor or local representative,
         and the national Competent Authority if appropriate, as this provides important feedback..*

Note: Fields indicated by * are considered necessary for all FSNs. Others are optional.

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