Characterization of US Food and Drug Administration Class I Recalls from 2018 to 2022 for Moderate- and High-Risk Medical Devices: A Cross-Sectional Study

Abstract

Maryam Mooghali,1,2 Joseph S Ross,1– 4 Kushal T Kadakia,5 Sanket S Dhruva6,7 1Department of Internal Medicine, Yale School of Medicine, New Haven, CT, USA; 2Yale Collaboration for Regulatory Rigor, Integrity, and Transparency (CRRIT), Yale School of Medicine, New Haven, CT, USA; 3Department of Health Policy and Management, Yale School of Public Health, New Haven, CT, USA; 4Center for Outcomes Research and Evaluation, Yale-New Haven Health System, New Haven, CT, USA; 5Harvard Medical School, Boston, MA, USA; 6Department of Medicine, UCSF School of Medicine, San Francisco, CA, USA; 7San Francisco Veterans Affairs Health Care System, San Francisco, CA, USACorrespondence: Maryam Mooghali, Yale Center for Outcomes Research and Evaluation (CORE), 195 Church Street, New Haven, CT, 06510, USA, Tel [phone], Email [email protected]: Medical device recalls are initiated in response to safety concerns. Class I (highest severity) recalls imply a reasonable likelihood of serious adverse events or death associated with device use. Recalled devices must be identified, assessed, and corrected or removed, upon which a recall can be terminated.Objective: To characterize Class I medical device recalls and corresponding recalled devices.Methods: This was a cross-sectional study of Class I recalls posted on the Food and Drug Administration’s annual log from January 1, 2018 to June 30, 2022 for moderate-risk and high-risk medical devices. Devices were categorized by therapeutic use, need for implantation, and life-sustaining designation; recalls were categorized by reason, status, and time elapsed.Results: There were 189 unique Class I medical device recalls, including 151 (79.9%) for moderate-risk and 34 (18.0%) for high-risk devices. Sixty-five (34.4%) recalls were for cardiovascular devices, 36 (19.0%) for implanted devices, and 37 (19.6%) for life-sustaining devices. The median number of device units recalled in the US per recall notice was 4620 (interquartile range [IQR], 578– 42,591), with 11 (5.8%) recalls associated with more than 1 million device units. Overall, 125 (66.1%) devices had multiple recalls, with a median of 4 (IQR, 3– 11) recalls issued per recalled device. As of September 15, 2022, 50 (26.5%) recalls were terminated, with a median of 24 (IQR, 17.3– 30.8) months elapsed between recall initiation and termination. Recalls were terminated more commonly among devices recalled once compared to those recalled multiple times (36.2% vs 19.2%; p=0.02) and for recalls that recommended discontinuing further use of affected devices compared to those that recommended device assessment and/or education of affected population (31.8% vs 18.2%; p=0.04).Conclusion: High-severity medical device recalls are common and affect millions of device units annually in the US. Recall termination takes a significant amount of time, putting patients at risk for serious safety concerns.Keywords: medical devices recalls, device safety, Food and Drug Administration

Keywords

• medical devices recalls
• device safety
• food and drug administration