Dear Doctor Letters for Implantable Cardioverter Defibrillator Recalls: Content and Format Recommendations
This guidance provides recommendations for manufacturers on drafting and issuing Dear Doctor letters specifically for Implantable Cardioverter Defibrillators (ICDs) recalls. It focuses on maximizing the effectiveness of these communications through completeness, clarity, and readability to help physicians make appropriate decisions regarding patient care during recall situations.
Recommended Actions
- Develop a standardized template for Dear Doctor letters following the recommended format and content structure
- Establish a process for rapid communication development and distribution
- Create a dedicated webpage for posting Dear Doctor letters and updates
- Set up multiple communication channels for distributing the letters
- Implement a review process to ensure all critical information is included
- Establish a system for tracking affected devices and patient follow-up
- Create a protocol for handling returned explanted devices
- Develop patient communication materials that physicians can use
- Set up dedicated contact points for healthcare professional inquiries
- Establish a process for providing regular updates as new information becomes available
Key Considerations
Clinical testing
- Provide interrogation steps or clinical tests to identify devices that have failed or may fail
- Include recommended follow-up schedules for affected patients
Human Factors
- Present safety information in a consistent order
- Format letters for easy readability (large font, bold type, high contrast, subheadings)
- Avoid lengthy background information
- Keep communications concise (less than two pages when possible)
Labelling
- Include clear description of the problem and failure mode
- Provide detailed information about affected devices and scope of the issue
- Include company contact information and resources for additional information
Software
- Specify if failure mode can be corrected through reprogramming or software upgrades
- Explain if software fixes are permanent solutions or interim measures
Safety
- Report number of deaths and injuries related to device failure
- Include severity and likelihood of the problem
- Provide clear recommendations for patient treatment options
- Include instructions for device explantation when necessary
Other considerations
- Use multiple communication channels (email, fax, express mail, web)
- Avoid promotional statements about the company
- Focus on patient care rather than company liability
- Provide timely communications before media coverage
- Include instructions for returning explanted devices
Relevant Guidances
- Distinguishing Between Medical Device Recalls and Device Enhancements
- Public Warning and Notification of Recalls Under Part 7
- Product Recalls, Removals, and Corrections: Procedures and Best Practices
Original guidance
- Dear Doctor Letters for Implantable Cardioverter Defibrillator Recalls: Content and Format Recommendations
- HTML / PDF
- Issue date: 2007-07-19
- Last changed date: 2020-03-19
- Status: FINAL
- Official FDA topics: Medical Devices, Radiation-Emitting Products, Postmarket, Radiological Health
- ReguVirta summary file ID: 63376a496577d5ff88bfa89d3e4c8b00
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