CAPA Officer
CAPA system management for medical device quality management.
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We received a complaint from a hospital customer — our infusion pump software showed an incorrect drug dosage calculation in 3 patient cases. No adverse events reported, but we need to open a CAPA. What does the CAPA need to include under ISO 13485?
CAPA Initiation — Infusion Pump Dosage Calculation Error
Under ISO 13485:2016 §8.5.2 (Corrective Action), your CAPA must include:
1. Problem Description
- Device: [Model/SW version]
- Complaint reference: [NCR number]
- Description: Incorrect dosage calculation displayed in 3 patient cases at [Customer]
- Potential patient impact: Risk of under/overdose — classify as Serious Injury potential under MDR Article 2(65)
- Regulatory reportable? Assess against MDR 2017/745 Art. 87 — if SW failure could have caused serious patient deterioration, report within 15 days
2. Immediate Containment Actions
- Notify affected customer(s) with interim workaround instructions
- Identify all devices/SW versions with this build in field (traceability review)
- Issue Field Safety Notice if containment requires action by users
- Quarantine affected SW version from further distribution
3. Root Cause Analysis (required by §8.5.2) Use Ishikawa + 5 Whys. Categories to investigate:
- Software requirements specification (was the calculation logic specified correctly?)
- Verification testing (was this calculation tested? with what inputs?)
- Validation (did clinical use-case testing cover edge cases?)
4. Corrective Action Plan
| Action | Owner | Target Date |
|---|---|---|
| Root cause confirmed via code review | SW Engineering Lead | Day +5 |
| Software patch developed + unit tested | Dev Team | Day +15 |
| Verification testing of fix | QA | Day +22 |
| Clinical validation of updated calculation | Clinical Affairs | Day +30 |
| SW update distributed to field | Regulatory/QA | Day +45 |
5. Effectiveness Check Define: "CAPA is effective when zero recurrence of dosage calculation errors is reported in 90-day post-deployment monitoring period."
6. Cross-References
- Link to original complaint record
- Link to risk management file (ISO 14971) — update risk assessment for this hazard
- Link to design history file (DHF) — update SW requirements and test cases
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