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TGA Guidance on Uniform Recall Procedure for Therapeutic Goods: Steps 8-10 | TGA

The new article provides additional details regarding the subsequent steps of the recall process, including the development of an action strategy, drafting a communication strategy to be followed when conducting a recall, and also the matters related to interactions with the authority, such as the noes associated with the submission of the relevant notification and an assessment to be conducted by the TGA

TGA Guidance on Clinical Evidence for Implantable Pulse Generator Systems: Overview

Table of content

The Therapeutic Goods Administration (TGA), an Australian regulating authority in healthcare products, has published a guidance document dedicated to uniform recall procedures for therapeutic goods (URPTG).

The document describes in detail the relevant procedures and also provides additional clarifications and recommendations the parties involved should follow in order to ensure compliance with the existing legal framework.

The authority also reserves the right to change the guidance and provision thereof, should such changes be reasonably necessary to reflect corresponding amendments to the underlying legislation.

Step 8: Implementing the Action

Upon obtaining agreement for a recall or determining that a recall action is unnecessary, sponsors must promptly initiate their communication and recall strategies.
This includes sending a customer letter within two business days of receiving the TGA’s “Agreement Letter” and notifying the Australian Competition and Consumer Commission (ACCC) if the goods are also considered “consumer goods”.

The recovery of affected goods involves establishing collection points, arranging for their secure disposal or rectification, and ensuring adherence to relevant legislation. For mandatory recalls, TGA may require specific recovery steps.

FDA on assessing credibility of computational modelling2

Customer Follow-Up

According to the guidance, effective customer follow-up is crucial to confirm receipt and adhere to instructions provided in the customer letter.
This follow-up varies with the recall’s risk and class, potentially involving multiple contact attempts through various channels if initial efforts do not elicit a response.

Root Cause Analysis

Concurrently with the recall process, a root cause analysis is conducted, typically by the manufacturer. This analysis is vitally important for understanding the issues leading to the recall and forms the basis of the final progress report reviewed in Step 10.

Step 9: Reporting on the Recall Action

Under applicable regulations, sponsors must submit follow-up reports using templates provided by the TGA or available on their website.
These reports, including interim and closeout reports, are essential for evaluating the recall’s effectiveness.

The TGA Agreement Letter outlines these reports’ timing, with additional requirements for high-risk or delayed actions.
The closeout report, in particular, must detail the root cause analysis, corrective and preventive actions (CAPAs), and evidence of the recall’s effectiveness.

Step 10: Reviewing the Recall

The TGA reviews interim and closeout reports to verify action completion, consistency, effective implementation of recall actions, and ongoing compliance with regulatory standards.
This review assesses the adequacy of the investigation, the identification of root causes, and the CAPAs implemented to prevent future recurrences.

Outcomes of this review may include satisfactory completion, requests for additional information, or further action to ensure recall effectiveness.
This could lead to manufacturer inspections or adjustments to product registrations based on the findings.

Outcomes and Compliance

Successful recalls conclude with a close-out letter from the TGA, affirming satisfactory action and potential implications for future manufacturer inspections or regulatory reviews.

In cases where the recall’s effectiveness or the nature of remedial actions raises concerns, additional information or actions may be requested to resolve outstanding issues.
Identifying systemic problems could prompt immediate inspections or regulatory adjustments to ensure public safety and compliance.

Conclusion

The present TGA guidance describes in detail the main steps of a recall process to ensure continued safety and proper performance of medical devices and other healthcare products allowed for marketing and use in Australia.
In particular, the guidance addresses the aspects related to the approach to be followed when conducting a recall and the matters associated with reporting and closure procedures.

The document highlights the key points to be taken into consideration by manufacturers and other parties involved when conducting a recall and communicating crucial safety-related information to the affected parties.

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