FSCAs & Recalls
What is an FSCA?
A Field Safety Corrective Action (FSCA) is an action taken by a manufacturer to reduce a risk of death or serious deterioration in the state of health associated with a medical device that is already on the market. FSCAs may include:
- Device recalls (return to manufacturer)
- Device modifications or upgrades
- Labelling or instructions changes
- Advisory notices to users or healthcare professionals
When an FSCA is required
An FSCA should be initiated when the manufacturer becomes aware of a safety issue that requires action to reduce risk to patients, users, or other persons. This may result from:
- Adverse event reports received from the market
- Internal quality system findings
- Post-market clinical data or literature
- Regulatory authority instructions
Notifying Roszdravnadzor
Before executing an FSCA in Russia, the manufacturer (or RUS REP) must notify Roszdravnadzor. The notification should include:
- Description of the safety issue
- Affected devices (model, lot numbers, registration certificate number)
- Proposed corrective action
- Timeline for execution
- Field Safety Notice (FSN) intended for users and healthcare facilities
Field Safety Notices (FSNs)
A Field Safety Notice (FSN) is the written communication sent to users, healthcare facilities, and distributors informing them of the safety issue and the corrective action required. FSNs must be:
- In Russian (for distribution in Russia)
- Clear and actionable
- Sent to all known affected users
RZN-initiated safety actions
Roszdravnadzor has the authority to order mandatory recalls or safety actions where it determines a device presents an unacceptable risk and the manufacturer has not taken appropriate action. RZN can also suspend or cancel a Registration Certificate in serious cases.
Roszdravnadzor: roszdravnadzor.gov.ru