C & M Oxyfill LLC

Recipient: C & M Oxyfill LLC.
Product: Compressed Oxygen USP
Date: 5/26/05

Failure to routinely calibrate, inspect, or check automatic, mechanical, or electronic equipment according to a written program designed to assure proper performance [21 CFR 211.68(a)]. Specifically, your firm has not performed any equipment qualification on the “mobile” cryogenic pumping system which transfills your Compressed Oxygen, USP, drug product. The qualification of this system is especially crucial, because the system’s manufacturer (a contract firm named _____ states in its documentation, it typically manufactures stationary pumping systems and “does not vouch for the operation of an Oxygen filling system in a portable trailer configuration.” _____ also states C & M Oxyfill requested they fabricate and install this mobile cryogenic pumping system according to C&M Oxyfill’s layout and design.

FDA District: New Orleans District Office

About the author

Amy enjoys researching and writing about developments in medical technology and how that intersects with US law. She received her J.D. from the University of Florida Levin College of Law in 2020 and now works as a Regulatory Associate for SoftwareCPR®, a general-purpose regulatory consulting firm that is recognized globally for their expertise with standards and national regulations pertaining to medical device, mobile medical app, and HealthIT software.

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