A four-day FDA inspection of Curasan’s manufacturing facility in Frankfurt, Germany revealed a lack of manufacturing and adverse event reporting procedures.

At the time of the agency’s visit last May, the firm lacked documented design validation in the design history file — completed in July 2009 — for its Osbone Dental device. It also had failed to establish a procedure for the manufacturing of its IngeniOs HA-Synthetic Bone Particles, according to an FDA warning letter.

The firm’s July 2017 response to these GMP violations, first noted as Form 483 observations, described corrections such as revising documentation and personal training. But it did not specify whether the effectiveness of the corrective actions had been verified, and did not include reviews of all existing products and potential adverse events.

The FDA also flagged nonconformities in the firm’s complaint handling procedures. Curasan had failed to establish a requirement for evaluating complaints to determine whether they should be reported to the FDA under the medical device reporting regulations.