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21 CFR Part 806 Process Flow


                                                                Potential need for
                                                               correction or removal
                                                                     identified




         Does the situation involve a
        violation of the Federal Food,             N     Does the situation involve a “risk
      Drug, and Cosmetic Act or an FDA                  to health” under 21 CFR 806.2(j)?
N                 regulation?



                                                                            Y
                      Y



                                                               Is the potential action
                                                                                                       Under which subpart of
                                                             exempt from the reporting        Y
                                                                                                        21 CFR 806.1(b) is the
                                                              requirements under 21
                                                                                                       potential action exempt?
                                                                   CFR 806.1(b)?



                                                                     N



                                                                                                  Document this determination and
                                                                                                   identify the specific subpart [21
                                                                                                  CFR 806.1(b)(1), (2), (3), or (4)] in
                                                                                                             the _____ file
       Is the potential action reportable to           Evaluate 21 CFR Part 7 (Subparts
     FDA under 21 CFR 806.10 – i.e., is it     Y          A and C) and FDA’s Recall
      intended to reduce a “risk to health”               Guidance to help define the
    [806.10(a)(1)] or to remedy a violation             company’s “recall strategy” and
        that may present a “risk to health”                    communications
                 [806.10(a)(2)]?
                                                                                                                  End

                                                              Prepare a Report of
                                                             Correction or Removal
                                                             to FDA in accordance
                       N                                     with 21 CFR 806.10(c)


                                                                                                         Prepare a final status
    Document the determination that the
                                                                                                      update report and request
      potential action is not reportable
                                                        Submit the Report of Correction                for FDA to terminate the
    under 21 CFR 806.10 and generate
                                                         or Removal to FDA within 10                     correction or removal
    the records required under 21 CFR
                                                        business days of “initiating” the
                  806.20(b)
                                                                    action



                                                                                                           FDA decision to
                                                            Prepare a monthly (unless                       terminate the
                                                           otherwise specified by FDA)                       correction or
                     End                                   status update report to FDA                         removal




                                                                                                             The company
                                                                                                            receives FDA’s
                                                       Submit each status update report                   formal termination
                                                         to the appropriate FDA office                           letter




                                                                                                                  End
                                                       N          Have all of the        Y
                                                                identified actions
                                                                been completed?




                                               © 2012 EduQuest, Inc.

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21 cfr part 806 Process Flow for Device Recalls

  • 1. 21 CFR Part 806 Process Flow Potential need for correction or removal identified Does the situation involve a violation of the Federal Food, N Does the situation involve a “risk Drug, and Cosmetic Act or an FDA to health” under 21 CFR 806.2(j)? N regulation? Y Y Is the potential action Under which subpart of exempt from the reporting Y 21 CFR 806.1(b) is the requirements under 21 potential action exempt? CFR 806.1(b)? N Document this determination and identify the specific subpart [21 CFR 806.1(b)(1), (2), (3), or (4)] in the _____ file Is the potential action reportable to Evaluate 21 CFR Part 7 (Subparts FDA under 21 CFR 806.10 – i.e., is it Y A and C) and FDA’s Recall intended to reduce a “risk to health” Guidance to help define the [806.10(a)(1)] or to remedy a violation company’s “recall strategy” and that may present a “risk to health” communications [806.10(a)(2)]? End Prepare a Report of Correction or Removal to FDA in accordance N with 21 CFR 806.10(c) Prepare a final status Document the determination that the update report and request potential action is not reportable Submit the Report of Correction for FDA to terminate the under 21 CFR 806.10 and generate or Removal to FDA within 10 correction or removal the records required under 21 CFR business days of “initiating” the 806.20(b) action FDA decision to Prepare a monthly (unless terminate the otherwise specified by FDA) correction or End status update report to FDA removal The company receives FDA’s Submit each status update report formal termination to the appropriate FDA office letter End N Have all of the Y identified actions been completed? © 2012 EduQuest, Inc.