Production / post-production data not feeding back into the risk file.
Your CAPA system collects field complaints, but they don't update the risk evaluations they actually contradict.
"ISO 14971 §10.1 requires the manufacturer to establish a system to actively collect and review information about the medical device in the production and post-production phases, then evaluate whether that information could affect the previous risk management assessments."
SOP-CAPA-002 Rev 04 documents complaint intake and CAPA initiation. RM-PLAN-001 Rev 03 (risk management plan) defines the residual-risk thresholds. But no procedure links the two. Three CAPAs from the last 18 months reference field failure modes that, on review, would change the residual-risk acceptability for hazard H-12 (occlusion during use) — but the risk file has not been updated since Rev 03 (2024-08-12).