FDA Warning Letter Reveals Compliance Lapses in Renovo’s Reprocessing of Medical Devices

Renovo, a company specializing in the cleaning and reprocessing of medical devices, was issued a warning letter by the Food and Drug Administration (FDA) in October. This letter highlighted serious concerns regarding Renovo’s practice of supplying reprocessed medical devices without obtaining 510(k) clearance, a necessary regulatory requirement. The FDA accused Renovo of providing reprocessed models that were beyond the range of its 510(k) clearances, failing to evaluate how cleaning and re-sterilization of these additional models could impact their performance and reliability. The FDA’s scrutiny focused on Renovo’s reprocessing of various medical devices used in procedures such as soft tissue ablation. Renovo holds multiple 510(k) clearances permitting the reprocessing of devices like Depuy Mitek Ablation Wands and Ethicon Bladeless Trocars. The FDA pointed out instances where Renovo reprocessed models not covered by its clearances. For example, with Arthrocare Ablation Wands, Renovo reprocessed devices with different designs from those included in the 510(k), which presented challenges for cleaning and re-sterilization, raising concerns about their safety and effectiveness.

The warning letter outlined violations across multiple 510(k) clearances, with Renovo accused of adding models not covered in the original clearances without assessing how these changes might impact device performance. The FDA identified breaches of good manufacturing practices, notably concerning air particulate sampling. Inspectors found that Renovo hadn’t established control procedures for air particulate levels in its reprocessing facility, posing potential risks to product quality and patient safety. Renovo submitted a response addressing the air particulate testing issues in June 2023. While the FDA deemed this response “adequate,” it emphasized the need for a follow-up inspection to ensure that Renovo had implemented effective corrective measures. This outlines the importance of prompt and thorough corrective actions to address regulatory concerns raised by the FDA.

The warning letter to Renovo mentions specific instances where the company’s practices violated regulatory requirements, providing an overview of the issues identified during the FDA’s inspection. The FDA pointed out that Renovo’s new models had different designs, including smaller diameter shafts, lumens, and tip elements, compared to the original models covered by the 510(k) clearances. This deviation presented a more challenging scenario for cleaning and re-sterilization, raising questions about the safety and effectiveness of the reprocessed devices. The warning letter also outlined Renovo’s failure to adequately evaluate how cleaning and re-sterilization of these additional OEM models with different designs could affect performance specifications and reliability. This lack of evaluation suggests a disregard for the potential implications on device functionality, which is necessary for ensuring patient safety and achieving regulatory compliance. By not conducting thorough assessments, Renovo overlooked important steps in the reprocessing process, potentially compromising the quality and efficacy of the reprocessed devices.

The FDA’s warning letter to Renovo outlines the importance of adhering to regulatory requirements in the reprocessing of medical devices. Renovo’s failure to obtain appropriate clearances and adequately evaluate the impact of reprocessing on device performance has raised serious concerns regarding patient safety and product effectiveness. Renovo must take prompt corrective actions to address the FDA’s findings and ensure compliance with regulatory standards to uphold the safety and quality of reprocessed medical devices.