Executive Summary & Key Takeaways
## Medical Device Alert: PALMAZ GENESIS Peripheral Stent - Policy Analysis Report
**1. Executive Summary:**
This report analyzes a Medical Device Alert issued by the Central Drugs Standard Control Organization (CDSCO) on June 21, 2022, regarding the Cordis PALMAZ GENESIS Peripheral Stent on OPTA PRO .035 Delivery System. The alert stems from an increased complaint rate of stent dislodgement identified by Cordis for specific product sizes manufactured between October 2019 and April 2021. The core purpose of this alert is to inform healthcare professionals and other stakeholders about the potential risk of stent dislodgement and to highlight the ongoing investigation into the manufacturing-related factors that may contribute to the issue. The alert recommends awareness and careful examination of the device prior to use, but CDSCO states it has not received any complaints from the market on this issue.
**2. Introduction:**
This report aims to provide a comprehensive overview of the Medical Device Alert F.No. 29Misc.032021DC276, issued by the CDSCO on June 21, 2022, concerning the Cordis PALMAZ GENESIS Peripheral Stent. The analysis is based solely on the information provided within the alert document itself.
**3. Policy Overview:**
* This document appears to be a new Medical Device Alert and not an amendment to an existing policy.
* **Core Objective(s):** The primary objective of this alert is to disseminate information regarding a potential safety issue related to the PALMAZ GENESIS Peripheral Stent, specifically the increased risk of stent dislodgement. This aims to increase user awareness to reduce the risk of adverse events.
**4. Background and Rationale:**
* **Likely Problem/Issue:** The alert addresses a potential manufacturing quality issue that may have led to an increased risk of stent dislodgement during the deployment of the PALMAZ GENESIS Peripheral Stent on OPTA PRO .035 Delivery System. Cordis's complaint trending analysis indicated that devices manufactured during a specific timeframe (October 2019 to April 2021) exhibited an elevated complaint rate for this issue.
**5. Key Provisions / Changes:**
* This is a Medical Device Alert, so it does not contain provisions that establish new rules or mandates beyond the communication of safety-related information.
* The alert highlights the following key information:
* **Identification of Affected Products:** Specific catalog numbers and lot numbers of the PALMAZ GENESIS Peripheral Stent on OPTA PRO .035 Delivery System potentially affected.
* **Nature of the Problem:** An increased complaint rate for stent dislodgement prior to or during placement.
* **Potential Impacts:** Intraprocedural delays and complications such as unplanned percutaneous or surgical intervention, or GI tract trauma or perforation due to stent movement.
* **Investigation Status:** Cordis has initiated a supplier corrective action (CAMIA02719) to investigate and determine corrective actions.
* **Interim Actions:** Stop shipments of the two product codes were implemented (EVENT202204717 and EVENT202204738), and the production of these codes was also stopped until corrective actions are implemented.
**6. Target Audience and Stakeholders:**
Based on the text, the primary target audience and stakeholders include:
* Healthcare professionals, especially interventional cardiologists and vascular surgeons, who use the PALMAZ GENESIS Peripheral Stent on OPTA PRO .035 Delivery System.
* Hospitals and medical facilities that stock and utilize these devices.
* Cardinal Health Medical Products India Pvt. Ltd., the distributor of the product in India.
* Cordis Cashel, Ireland, the legal manufacturer.
* Confluent Medical Technology, Inc Costa Rica, S.R.L., the external manufacturer.
* CDSCO.
**7. Implementation Aspects (Inferred):**
* **Responsible Agency/Bodies:** CDSCO (issuing the alert), Cordis Cashel (manufacturer, conducting the investigation), Cardinal Health Medical Products India Pvt. Ltd. (distributor).
* **Timelines/Procedures:** The alert itself does not specify new procedures or timelines for implementation beyond the information and awareness it aims to create. The corrective actions and investigation are ongoing under Cordis's internal processes. The alert references distributed product risk assessment that was released on 18.05.2022.
**8. Expected Outcomes / Impact of Changes:**
* The likely intended outcome of this alert is to increase awareness among healthcare professionals about the potential risk of stent dislodgement associated with the affected PALMAZ GENESIS Peripheral Stent. This increased awareness should lead to more careful device examination and potentially modified procedural techniques, mitigating the risk of adverse events. The alert also serves to inform hospitals and clinics that they may have affected product that needs to be carefully tracked and handled. It will also trigger more vigilance on new complaints in the Indian market.
**9. Conclusion:**
The CDSCO Medical Device Alert regarding the PALMAZ GENESIS Peripheral Stent on OPTA PRO .035 Delivery System highlights a potential safety concern related to stent dislodgement. While no deaths or serious long-term health sequelae have been reported, the potential for intraprocedural delays and complications necessitates vigilance and adherence to the manufacturer's recommendations for device handling. The alert underscores the importance of post-market surveillance and prompt communication of potential safety issues in medical devices.
Key Entities Referenced
PALMAZ GENESIS Peripheral Stent on OPTA PRO .035 Delivery System : A medical device used in the treatment of atherosclerotic disease of peripheral arteries below the aortic arch. This is the subject of the medical device alert.
Cordis : The manufacturer of the PALMAZ GENESIS Peripheral Stent on OPTA PRO .035 Delivery System.
Cordis Cashel, Ireland : The location of a Cordis facility involved in the Distributed Product Risk Assessment Form.
Cardinal Health Medical Products India Pvt. Ltd., Bhiwandi, DistThane, TalBhiwandi14 Thane Z5, Thane, Maharashtra : The Indian branch of Cardinal Health, the distributor of the affected medical device.
Confluent Medical Technology, Inc : External manufacturer of PALMAZ GENESIS Peripheral Stent on OPTA PRO .035 Delivery System.
Costa Rica, S.R.L., Co. Tipperary Coyol Free Zone, Building B25 Ireland El Coyol, Alajuela, Costa Rica : Business Unit Site Legal Manufacturer External Manufacturer of PALMAZ GENESIS Peripheral Stent on OPTA PRO .035 Delivery System
Distributed Product Risk Assessment Form : A document released by Cordis assessing the risk associated with the stent dislodgement issue.
Medical Devices and Diagnostics Division : A division of Central Drugs Standard Control Organization Directorate General of Health Services Ministry of Health and Family Welfare Government of India
See Full Document Text
Central Drugs Standard Control Organization
Directorate General of Health Services
Ministry of Health and Family Welfare
Government of India
(Medical Devices and Diagnostics Division)
Email: ddcimd-cdsco@nic.in
Food & Drugs Administration Bhawan,
Kotla Road, New Delhi.
F.No. 29/Misc./03/2021-DC(276) Date: 21 June 2022
MEDICAL DEVICE ALERT
PALMAZ GENESIS® Peripheral Stent on OPTA® PRO .035”
Delivery System (PG2990PPX-82178943, PG2990PPX-82211305,
PG3990PPS-82182764, PG3990PPX-82212989, PG3990PPX-
82218097)
The Cordis PALMAZ GENESIS® Peripheral Stent on OPTA® PRO .035
Delivery System is intended for use in the treatment of atherosclerotic disease
of peripheral arteries below the aortic arch.
Cordis released Distributed Product Risk Assessment Form dated 18.05.2022
indicating increased complaint rate for stent dislodgement
Cordis noted an increased trend in complaints for stent dislodgement and
associated failure modes related to two specific sizes of the PALMAZ
GENESIS® Stent on OPTA® PRO .035 Delivery System that were produced
during a particular timeframe (October 2019 to April 2021). Identified through
complaint trending analysis which consists of evaluating complaints based on
key demographics used to identify potential commonalities. In this case there
were manufacturing months with elevated complaint rates which upon further
analysis identified the noted time period and product sizes to have an
elevated rate when compared to the surrounding months. The potential
impacts of stent dislodgement include an intra-procedural delay as the device
is exchanged for another or may result in complications such as: unplanned
percutaneous or surgical intervention, GI tract trauma or perforation. The
recall is being undertaken due to stent dislodgement prior to or during
placement and does not affect PALMAZ GENESIS stents that have been
successfully deployed. To date, there have been no deaths or serious long
Page 1 of 2term health sequelae, such as strokes, in the use of these involved complaint
devices.
e User interaction with the affected device/component: Balloon expandable
stents are intended to be used as a scaffolding within a lesion or stricture to
help maintain patency and improve the flow of blood and other body fluids.
The Palmaz family of stents are intended for use in the peripheral vascular
and the stent is delivered to the target on a balloon catheter called a stent
delivery system.
e Immediate and long Range Health Consequences: If movement of the
Stent is detected before or during the procedure, the device can be
exchanged resulting in an intra-procedural delay. If the stent is loose or
inaccurately crimped on the balloon the stent may not be placed where
intended in the target vessel. This may result in the need for additional stents
to complete the procedure. In the event that none of these percutaneous
methods are visible or successful the stent may be removed surgically.
Therefore, the severity of the potential harm of a stent that dislodges from the
stent delivery system is Critical.
e Indirect Health Consequences: None
Important Note: CDSCO have not received any complaints from the market on
this issue.
M/s Cordis Cashel, Ireland has released Distributed Product Risk Assessment
Form dated 18.05.2022 which is attached herewith this alert.
M/s Cardinal Health Medical Products India Pvt. Ltd.,
Bldg No. A3, Unit No. E, Babosa Ind Park, Mumbai Nashik Highway NH3,
Saravali Village, Bhiwandi,
Dist-Thane, Tal-Bhiwandi-14 (Thane Z5),
Thane, Maharashtra (India)-421302
www.cardinalhealth.com
Tel :022-42389278
Fax :022-42019191
Page 2 of 2Record
Record (Non-PPE}
100603990 | Rev:1
Stent Dislodgement Released: 18 May 2022
CO: 100603985
Cordis
Distributed Product Risk Assessment Form
DPRA 100603990
Section 1: Background
Product Name(s) and Marketing Status
PALMAZ® GENESISTM on OPTATM Pro
Catalog Number(s)
US and Canada:
PG2990BPS
PG2990BPX
PG3990BPS
PG3990BPX
Other Countries:
PG2990PPS
PG2990PPX
PG3990PPS
PG3990PPX
Note: Each size consists of 4 catalog codes with the only difference being the delivery shaft length and the
labeling for the 2 different markets.
Lot Number(s)
82178943 82178944 82180267 82182764 82184215 82184806 82185924 82191321
82191527 82191727 82193089 82193097 82195965 82206059 82208524 82208532
82208537 82211296 82211305 82212821 82212989 82218097 82218087 82208528
Business Unit/ Site
Legal Manufacturer External Manufacturer
Cordis Cashel Confluent Medical Technology, Inc
Cahir Road, Cashel Costa Rica, S.R.L.,
Co. Tipperary Coyol Free Zone, Building B25
Ireland El Coyol, Alajuela, Costa Rica
Mus M Europe EU M Europe Non-EU [ Japan
PM Asia Pacific M LatinAmerica Canada T Australia
& High Severity Event
Complaint rate exceeds threshold (significant trend)
TTM Nonconformance potentially affecting distributed product
[ Manufacturing or design confirmed Malfunction
© Other:
Description Of The Product Issue Under Review : Increased complaint rate for stent dislodgement
Date this DPRA was initiated: 4/13/2022
Date issue was first discovered: 4/13/2022 Decision to initiate DPRA to determine risk
How issue was first discovered: Increase in complaints for SDS Stent dislodgment
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Stent Dislodgement
Cordis.
An increase in complaints of Palmaz Genesis stent dislodgment and associated failure modes was identified
for the manufacturing time period of October 2019 thru April 2021.
In March 2021, the issue was escalated by the Product Safety Clinician to the Cordis EM team and
Confluent. An investigation by Confluent (COMP-00026) concluded that there was no evidence to show
that the customer complaints were related to manufacturing deficiencies.
In February 2022. the Product Safety Clinician escalated concerns of stent dislodgment to an action item
via Monthly Complaint Review Meeting.
In March 2022, Product Safety Clinician presented data that identified an increase in complaints for 2021.
Additional review requested to be conducted by EM Manufacturing team.
In April 2022, the decision was made to initiate a risk assessment to further capture the investigation, assess
the risk to the patient and escalate accordingly. As part of that investigation, an assessment of the complaint
data was pefromed to determine if any trends could be identified. A total of 105 complaints were identified
for the time period Jan 2017 to Feb 2022 and further analyzed. 42 events implied a strong correlation
between the failure and procedural/handling factors (force applied. off label use, etc.). Of the remaining 63
events Palmaz Genesis on Opta Pro (table below) was identified to have a rate above the expected
occurrence per the SDS family risk management documents and was the driver of the identified increase in
complaints.
ie Lane Complaint
prods | Rate%
IPG _OPTA 0.07
IBLUE_AVIATOR [0.01
IBLUE_SLALOM _ 0.01
PG_AMIIA 0.00
IPG SLALOM _[0.00
[Total 0.04
The complaint data for PG on Opta Pro was further analyzed and revealed the start of the increase in
complaint rates was for lots linked to a manufacturing timeperiod starting in October 2019 and continuing
through to April 2021.
orn
080
0.70
0.60
oso
0.40
0.30
0.20
0.10
eo P FF2 F2C 2 PFPETPS SSKFS KPDF SDM 2 As
mamma Complaint Qty —===Complaint Rate
wena
bd v &
The data was further refined to focus on products manufactured between Oct 2019 and Aprl 2021. The data
F-11021 Rev 25, Distributed Product Risk Assessment Form Page 2of 14
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Record (Non-PPE)
Stent Dislodgement
Cordis.
revealed that the 2990 and 3990 product sizes were the main contributer to the increase in complaints
Stent/Balloon Size Complaint Count Rate of total Distributed
2990 10 0.021
3990 8 0.017
2980 3 0.006
2590 1 0.002
2910 1 0.002
3910 3 0.006
2510 I 0.002
5980 1 0.002
2480 1 0.002
2960 1 0.002
2970 1 0.002
5990 1 0.002
Design or Manufacturing Factors Related to Issue
Manufacturing Factors That May Contribute To Product Risk: The following manufacturing processes
and failure modes have been identified in the pFMEA (owned by Confluent) as potential causes for stent
dislodgement. As part of the investigation, these processes are being assessed to determine root cause. To
date, all processes are operating as intended and product is conforming. The investigation is ongoing.
Process name/ potential Failure Mode Potential Causes) Process Defect
Incorrect mandrel Procedure not followed Incorrect mandrel
Incorrect protective tube Operator Error Handling/ procedure not followed Incorrect protective tube
Precmeine incortect time Operator Error Handling/ procedure not followed incorrect time
Incorrect closing pressure Operator Error Handling/ procedure not followed Incorrect closing pressure
Incorrect mandrel Operator Error Handling/ procedure not followed Incorrect mandrel
Incorrect protective tube Operator Error Handling/ procedure not followed Incorrect protective tube
Crimpeie Incorrect Time Operator Error Handling/ procedure not followed Incorrect Time
Incorrect closing pressure Operator Error Handling/ procedure not followed Incorrect closing pressure
fe Incorrect protective tube Operator Error Handling/ procedure not followed Incorrect protective tube
esting
Incorrect Die Incorrect set up/ setup procedure not followed _ Incorrect Die
Incorrect Pressure Incorrect set up/ setup procedure not followed —_ Incorrect Pressure
Plasma treatment Incorrect time Incorrect set up/ setup procedure not followed Incorrect time
Incorrect potency Incorrect set up/ setup procedure not followed _ Incorrect potency
Design Factors That Might Contribute To The Product Risk: No design factors have been identified to
contribute to the product risk.
Root Cause: Cordis has initiated a supplier corrective action, CA-MIA-02719 to investigate and determine
corrective actions. This investigation consisted of a review of DHR’s, training records, scrap rates and
nonconformances with a focus on the processes that secure the stent to the balloon of the catheter. Process
walk-throughs have been conducted along with a review
100603990 | Rev:1
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CO: 100603985
of the stent retention testing used as an input for
F-11021 Rev 25, Distributed Product Risk Assessment Form Page 3of 14
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Record
Record (Non-PPE} Released: 18 May 2022
Stent Dislodgement CO: 100603985
Cordis
lot release as well as any significant events that occurred around the start of the increase in complaint lots
linked to a manufacturing month starting in October 2019 and returning to expected levels before April of
2021. It was noted that in April 2021. the following was done: 1) an awareness training was conducted to
heighten operator awareness of the procedures related to stent crimping and nesting and 2) maintenance
was performed on equipment related to stent crimping and nesting to evaluate equipment performance. This
correlates with the end of the noted increase in the complaint lots per manufacturing month and aligns with
the timeperiod in question of October 2019 to April of 2021.
Investigations focused on the stent securing process has not identified a root cause thus far and the
investigation is continuing via CA-MIA-02719.
The process FMEA pFMEA-10069 Rev A was reviewed. All known potential causes have been captured.
Reference Section 3 for review of harms and severities.
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Product Range Impact
Total Number of devices in distribution: At the time of this assessment:
Catalog Code_| Sum of Qty Distributed | Sum of Qty in Cordis Control
PG2990BPS 282 3
PG2990BPX 207 0
PG2990PPS 191 0
PG2990PPX 368 42
PG3990BPS 406 0
PG3990BPX 203 28
PG3990PPS 514 0
PG3990PPX 323 23
Grand Total 2494 96
Number of devices subject to review: All quantities listed above are subject to this review
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Record (Non-PPE) Released: 18 May 2022
Stent Dislodgement CO: 100603985
Cordis
Other Product Impact: No other product ranges in other marketed countries or product lines are
Interim Product Containment Actions
The impacted lots were identified by analyzing the complaint data. The catalog codes 2990 and 3990 for
lots manufactured between Oct 2019 and April 2021 have an increased complaint rate. Two stop shipments
were implemented ref EVENT-2022-04717 and EVENT-2022-04738. Production of these two product
codes was also stopped until corrective/interim actions are implemented via sCAPA-MIA-02719.
Internal Nonconformance Rate
N/A This DPRA was triggered by complaints.
TTM Occasional (5% to < 10%)
I Remote (3% to < 5%)
TF Improbable (< 3%)
¥ Not Applicable
sCAPA-MIA-02719
EVENT-2022-04717
EVENT-2022-04738
aFMEA 100170787 Rev 4
100170784 aHL Rev. 4
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Stent Dislodgement CO: 100603985
Cordis
Section 2: Compliance Evaluation
(Completed by QA Dir r or designee)
mpliance / Regulatory
r Product distributed without required regulatory approval (e.g.. PMA, IDE, IND)
or contrary to legal process (e.g., injunction, seizure, consent decree)
T Confirmed or suspected counterfeit product, product tampering or sabotage
I Entire lot does not meet label claims (e.g., identity, sterility, potency. stability)
Violation of investigational product or clinical trial regulations: advertising and
Rae promotional regulations; or product labeling regulations
Required | I~ Confirmed or potential damage to environment, facility or equipment
F Entire lot meets label claims, but does not meet product or process specifications
Entire lot meets label claims and product/process specifications, but product
TTM design may be deficient, or processes used to manufacture the lot may not meet
GMP requirements
T Other:
Product does not meet label claims (e.g., identity, sterili y, potency. stability) -
Isolated event or issue is not part of a systemic issue
Product meets label claims, but does not meet product or process specifications -
Isolated event or issue is not part of a systemic issue
Product meets label claims and product/process specifications, but product design may
RMB Decision | ¥ be deficient, or processes used to manufacture the product may not meet GMP
by QA requirements
Director or
Designee co Product or lot meets label claims and product/process specifications, but the complaint
or malfunction rate exceeds expectations
Product or lot meets label claims and product/process specifications, and the
complaint and malfunction rates are within expectations
fF Other:
M RMB review needed
TTM RMB review not needed because:
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Only the native file to be usedRecord 100603990 | Rev:1
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Stent Dislodgement CO: 100603985
Cordis
Product description and intended use:
A PALMAZ stent placement is a procedure used to treat peripheral vascular conditions. There are a
multitude of medical devices that are used or can be used to treat these conditions. For the current situation
mentioned above, most of such products used in a catheterization procedure are affected. Such product
families affected are PALMAZ Mounted Stents. Product descriptions and the indications for use can be
found in each product lines respective instructions for use.
Description of potential hazard(s) and harm(s), and any immediate and/or long range health
Immediate and Long Range Health Consequences: If movement of the stent is detected before or
during the procedure, the device can be exchanged resulting in an intra-procedural delay.
If the stent is loose or inaccurately crimped on the balloon the stent may not be placed where intended in
the target vessel. This may result in the need for additional stents to complete the procedure. It may also
cause the stent to become dislodged from the stent delivery system in the body, away from the target
lesion. If the stent remains on the guidewire it may be recaptured with a smaller balloon placed within the
stent to withdraw it or deploy it where it is, or a buddy guidewire may be used to entangle with the stent
wire and thus recapture it. However, if the stent is no longer on the guidewire it may be snared by using a
snare device to lasso it. If that is not possible then the stent may be jailed against the wall of the vessel
using another stent to prevent embolization of the stent to a smaller vessel or organ where it could obstruct
flow. It is possible that embolization could result in peripheral ischemia. This may result in permanent
impairment or damage to a body structure
In the event that none of these percutaneous methods are viable or successful the stent may be removed
surgically.
Therefore, the severity of the potential harm of a stent that dislodges from the stent delivery system is
Critical.
Indirect Health Consequences: None
The IFU (PALMAZ GENESIS® Peripheral Stent on OPTA® PRO .035" Delivery System 1539296 rev11)
warns “Prior to stenting, the PALMAZ GENESIS® Peripheral Stent on OPTA® PRO .035" Delivery
System should be examined to verify functionality and integrity. Do not attempt to remove or readjust the
stent on the delivery system. Inspect the crimped stent for adherence to the balloon and centered placement
in relation to the balloon marker bands. Do not reposition the stent or hand crimp.”
If Device Failure Occurs Can It Be Recognized By The User: Offset, loosely crimped and/or dislodged
stents can be recognized by the user.
Segment of the Population Most at Ri
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Cordi
and competitor roducts are available on the market with the same indications for use.
HN/A
Number Of Complaints: The Cordis complaint database was queried for all complaints related to
29x90 and 39x90 Palmaz Genesis on Opta Pro for stent-dislodged. premature deployment, inaccurate
placement and stent-offset/out of position manufactured between October 2019 and April 2019.
5 Complaint MFG Category
Complaint # Create Date Event Country Catalog Lot Month fecry Patient Outcome
No patient injury
CASE-2020- UNITED STENT-
00119575-1 Jul-20 STATES PG2990BPX | 82185924 | Feb-20 DISLODGED eae
No patient injury
CASE-2020- STENT- ‘i
00119680-1 Jul-20 NETHERLANDS | PG3990PPS | 82178944 | Oct-19 | K1) GoGED —
No patient injury
CASE-2021- UNITED STENT- (unknown
00138854-1 fee STATES PG2S90BPX | 82185924 | Feb-20 | Hi OnGeD | where/when stent
dislodged)
CASE-2021 STENT- No patient injury
paiasnce Jan-21 CHINA PG2990PPX | 82178943 | Oct-19 | OFFSET/OUT | (occurred during
OF POSITION prep)
CASE-2021- UNITED STENT- Expanded at
oo1as7or-1 | Mer? STATES PE3990BPX | 82208524 | Dec-20 | pistopGeD | unintended location
No patient injury
CASE-2021- UNITED STENT- ‘i
00148677-1 Mar-21 STATES PG3990BPX | 82208524 | Dec-20 DISLODGED Ce
CASE-2021- STENT- No patient injury
Apr-21 CHINA PG2990PPX | 82191727 | Apr-20 LOOSE (occurred during
00149907-1 CRIMP. prep)
CASE-2021- UNITED STENT- Expanded at
00152266-1 Ape STATES PG3990BPS | 82193089 | Jun-20 | oistopGeD | unintended location
STENT- No patient injury
cae May-21 a
100603990 | Rev:1
Released: 18 May 2022
CO: 100603985
ee PG2990BPS | 82184806 | Jan-20 | OFFSET/OUT | (removed with stent
OF POSITION delivery system)
STENT-
DISLODGED; No patient injury
CAE e028 May-21 UNITED PG2990BPX | 82185924 | Feb-20 STENT- (removed with stent
00153684-1 STATES .
STRUT delivery system)
UPLIFT
CASE-2021- STENT- aa in sheath removed
00154015-1 May-21 CHINA PG2990PPX | 82191727 | Apr-20 DISLODGED with'sheath
No patient injury
CASE-2021- UNITED STENT- ‘
soiseio7d Jun-21 SATES PG2990BPS | 82208532 | Nov-20 | pie oncen iW
CASE-2021- STENT- aa in sheath removed
00161752-1 Aug-21 CHINA PG2990PPX | 82191727 | Apr-20 DISLODGED with sheath
No patient injury
CASE-2021- UNITED STENT- 5
00165957-1 Sep-21 STATES PG2990BPS | 82184806 | Jan-20 DISLODGED a"
No patient injury
CASE-2021- STENT-
00167025-2 Oct-21 FRANCE PG3990PPS | 82208537 | Nov-20 DISLODGED foe as
CASE-2021- UNITED STENT- No patient injury
00167416-2 Geuat STATES PGZQO0BES | Be2bese2 | Nov'20: | -pistopGeo (removed with
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Stent Dislodgement CO: 100603985
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sheath)
STENT-
CRIMPING
DIFFICULTY,
STENT No patient injury
SASES2022- Nov-21 jell PG2990BPX | 82208528 | Nov-20 | DIS STL EO ND TG-E D; (occurred during
00169983-1 STATES prep) and off-label
PREMATURE | Oe had crammed
pepLoymen | YS° imped)
T, STENT-
STRUT
UPLIFT
No patient injury
CASE-2022- UNITED STENT-
oor7eagaa | Feb-22 rares pessa0BPx | 82208524 | Dec-20 | no oncen local ne
CASE-2022-
Sent No patient injury
poisavekr | (Feb22 BRAZIL pe2agorpx | 2211305 | Jan-21 | pcrorcen ll
The overall rate for this subset is 19/2494 units distributed x 100 = 0.76%, Occasional.
Hazard Occ rrence Rate
Si N/A - Refer to Hazard Occurrence Rate for Cordis Santa Clara below
Expected per FMEA Mounted SDS aFMEA Complaint Rate
100170787 Rev 4
DO Frequent (10% or >)
TD Frequent (10% or >)
TTM Probable (1% to < 10%)
[ Probable (1% to < 10%)
FTM Occasional (0.02% to < 1%)
M Occasional (0.02% to < 1%)
Remote (0.002% to < 0.02%)
TM Remote (0.002% to < 0.02%)
TTM Improbable (< 0.002%)
[ Improbable (< 0.002%)
T Not Applicable
Expected per FMEA Complaint Rate
F Very High > 1%) D Very High > 1%)
TO High (0.5% to < 1%) E High (0.5% to < 1%)
[7 Moderate (0.1% to < 0.5%) T Moderate (0.1% to < 0.5%)
T Low (< 0.1%) D Low (< 0.1%)
[7 Not Applicable
F-11021 Rev 25, Distributed Product Risk Assessment Form Page Sof 14
Only the native file to be usedRecord 100603990 | Rev:1
Record (Non-PPE)} Released: 18 May 2022
Stent Dislodgement CO: 100603985
Cordis.
Health Risk Assessment
Using the following definitions list any reasonable and foreseeable Harm and determine the levels of
severity and likelihood:
Severity of Potential Harm
SLS Life-threatening (death has or could occur) (Cordis Severity level: Critical [4] or Cordis Santa
Clara Severity level: Critical [4])
SL4 Results in permanent impairment of body function or permanent damage to a body structure.
(Cordis Severity level: Severe [3] or Santa Clara Severity level: Critical [4])
SL3 Necessitates medical or surgical treatment to preclude permanent injury. (Cordis Severity Level:
Severe [3] or Santa Clara Severity level: Serious [3])
SL2 Temporary or reversible (a medical condition which would likely resolve itself and where medical
treatment is optional).(Cordis Severity level: Moderate[2] or Cordis Santa Clara Severity level:
Moderate [2])
SLI Limited (transient, minor impairment, no medical treatment required). (Cordis Severity level:
Limited [1] or Cordis Santa Clara Severity level: Minor [1])
SLO No adverse health consequences (Cordis Severity level: Negligible [0] or Cordis Santa Clara,
LikelihoSeovde roitfy H laevrelm: Minor [1])
L4 The product problem, when it exists, will always or almost always result in the identified harm.
L3 The product problem has resulted, or can be reasonably expected to result, in the identified harm
under normal circumstances at least some of the time.
12 The product problem has been known to result in the identified harm (documented or reported in
clinical practice), but only occasionally and/or under unusual circumstances.
Li The product problem has never been known to result in the identified harm, and it is not reasonable
to expect that it ever would.
Likelihood Likelihood
Harm Severity (General (Population at
Population) Greatest Risk)
Intraprocedural Delay SLI L4 L4
Damage to Healthy Intima SL2 L3 L3
Additional Intervention SsL2 13 3
(percutaneous)
Peripheral Vasospasm (peripheral) SL2 L3 L3.
Indication Ischemia (peripheral) SL2 L2 L2
Perforation (peripheral) SL3 L2 L2
Additional Intervention (surgical) SL3 L3 L3
Dissection (peripheral) SL3 L2 L2
Thrombosis (peripheral) SL3 r2 L2
Additional | GI Tract Trauma SL 13 L3
harms r/t
eee GI Tract Perforation SLS 12 12
ndication
Applicable FMEA document and revision number: The Confluent process FMEA pFMEA-10069 Rev A was
reviewed. However, the harms associated with the Biliary indication are not included. An update is required to
add these to the pPMEA. A Change Task will be created in MyCordisPLM to track the required update to
closure.
F-11021 Rev 25, Distributed Product Risk Assessment Form Page lof 14
Only the native file to be usedRecord 100603990 | Rev:1
Record (Non-PPE} Released: 18 May 2022
Stent Dislodgement CO: 100603985
1244 Losartan & Pra
1224P ptrnoetoercetcitve 8 PPE
Pre | tbe ‘
1231P Creng a|e ad 8 PPEW
13s41P pInocsorererc t & ‘Operator Erkroir Handing! 2 PPE
4321P _ | Protective 8 Sesto eee 2 PREM
eal Theoret Seog
1331P | and = 8 Selo 2 PPM
1344P cay | dTopseoinnegc t 8 Incorrectb ea tSetup’here 2 PPE
Icorect Tnconen Sean?
1381P 8 saber shen 2 PREM
incoree Eror
tana @ | Spee Es Rann 2 ment
sate aincorrect 2 | Specter Errrror Harting 2 Prem
cree TU hncorect Emer
1431 Te | Spear aoe ence 2 PEW
incoree a=
1441P. dosing a | Operator’ —- Apctarad 2 PPEM
Incorrect Operator 1S11P (orm é E‘rnrootr Hfoalie ndiingy 2 PPE
, ‘heared
1824P Incorrect ie 6 bechy fon 2 | PPeWw
1641 Iocoect 8 ‘Incorrecto at ae 2 8 | PhPeEe yP u | MESO tftnoorect
1621P Pas gel 8 incorrectD : ab steaed 2 6 6 tPesPt,E Wi /f Pub W-09010 t Incorrect time
Incomect Incorrect set up setup PREW Put incorrect
saaie @ = 2 e oo | PR | wcoo10 '
The Cordis Mounted SDS aFMEA 100170787 Rev 4 and Mounted SDS_ 100170784 aHL Rev. 4 were
reviewed. Per CMO. necrosis would not occur. Additional assessment required (literature search) followed by
review IFUs and Risk Management documents to remove necrosis. Change Tasks will be created in
MyCordisPLM to track these items to closure.
F-11021 Rev 25, Distributed Product Risk Assessment Form Page llof 14
Only the native file to be usedRecord 100603990 | Rev:1
Record (Non-PPE} Released: 18 May 2022
Stent Dislodgement CO: 100603985
Cordis.
Lstot AFMEA Hazards
General Risk |Ver tiCcoanttoronl Risk]
0 Step 102 | Proved eS! | 9g | Hazard Description | Hazadous | potentat Harm |S CPoateuntsiaet |, | Risk Level Meares _jOce ‘Stuaton(s) Vi Sameto f |fOa]° } bbeeftoerse |, Zonal | Measunes —_| ig) fRiisekr Level
* | tation | eee
fa 23 Stent la OF fia jICiauu ton: _Speaeni rus. [|iimFeU sa| [ALAP
Should Parking |not
rleuswisstuaante | fot liendt'eansd
fe be fet a risk
jt any leone
fre la
during reas
either ure,
lincure outa
laccess of make
Vemeval Is the
lorthe juser
bseivery aware
lystem lor
peor to licks
Istent No
on, te f4ur
system tial
lshould be fions |
removes lcan
be
haken|
i .
3
3
3
3
4
Applicable Hazard List:
Hoa [Stent Oislodgement 1 7 7 wap «taza
1 1 ns13
2 1 534
2 7 623
2 7 Kes
2 1 raz
3 1 i723
3 1 732
3 7 243
3 7
3 r
7 7
F-11021 Rev 25, Distributed Product Risk Assessment Form Page 12of 14
Only the native file to be usedRecord 100603990 | Rev:
Record (Non-PPE) Released: 18 May 2022
Stent Dislodgement CO: 100603985
Cordis
Likelihood\ LI L3
L2 L4
Severity
SLS TTM RMB required 7 RMB required I~ RMB required T~ RMB required
RMB decision by
Medical Director
SL4 T or Designee T RMB required 7 RMB required F RMB required
(requires review
by QA Director)
RMB decision by
Medical Director
SL3 1a) 9c Desens: M RMB required RMB required TTM RMB required
(requires review
by QA Director)
RMB decision by
RMB decision by Medical Director
SL2 TTM RMB not required | ¥ Medical Director or Designee TTM RMB required
or designee (requires review
by QA Director)
RMB decision by
ps RMB decision by : A
SLi IT RMB not required | 7 RMB not required FF Medical Director y resi Director or
: lesignee
or designee
SLO [= RMB not required rr RMB not required
TE RMB not required [ RMB not required
RMB Recommendation By Medical Director or designee
[ RMB not required (As per Escalation Recomendation table above)
RMB review needed
T RMB review not needed because:
F-11021 Rey 25, Distributed Product Risk Assessment Form Page I3of 14
Only the native file to be usedRecord 100603990 | Rev:1
Record (Non-PPE} Released: 18 May 2022
Stent Dislodgement CO: 100603985
Cordis.
Section 4: Decision Outcomes
RMB Decision
PM RMB required by Compliance evaluation in section 2
M RMB required by Health Risk Assessment Escalation in section 3
r RMB required if product does not meet label claims (section 2) and severity of the potential harm is
SL2, SL3, SL4 or SL5 (Cordis Severity level 2-4).
RMB required if product does not meet product or process specifications (section 2) and severity of
the potential harm is SL2, SL3, SL4 or SL5 (Cordis Severity Level 2-4).
T RMB not required, review by QA Director (section 3)
T RMB not required (none of the conditions above met)
N/A Issue escalated to RMB. The CAPA decision will be made by RMB and documented in the
meeting minutes.
Note: sCAPA-MIA-02719 has been issued to Confluent Medical Technologies.
TTM CAPA needed - record CAPA number, if available:
T CAPA not needed because:
1 CAPA decision deferred pending the following data:
Risk Management or Labeling Updates
N/A issue escalated to RMB. If updates to risk documents or labeling updates are required. the
Miv decision will be made by RMB and documented in the meeting minutes.
TF No Risk Document or Labeling updates needed because:
fF Risk Documents or Labeling updates needed. List documents to be updated:
Other Decisions or Comments
N/A
F-11021 Rev 25, Distributed Product Risk Assessment Form Page I4of 14
Only the native file to be used