Where the inspection and testing process involves removal of the item from the premises where the event occurred, the chain of custody must be preserved. This involves documenting every event in which possession of the item is taken by another party. For example, if the expert delivers the item to an outside testing service, then stores it at the expert’s office, and then returns it to the facility that owns it, each step must be recorded. The person releasing the item and the person receiving the item must both sign a document that indicates the description and identification of the item, the date and time it was released into custody of the individual receiving it, and the purpose for the transfer of custody. Such information is necessary for both tracking the item, to ensure it is not lost, and to be able to determine all of the parties who have been involved in handling the item in the event of damage or unauthorized repair. The final phase of the investigative process is the information-gathering phase. This involves the research necessary to determine whether the event in question has been observed and reported before, or is a unique event. There are a variety of resources available to the investigator for this information. The Manufacturers and Users Device Experience (MAUDE) system, which is the FDA Center for Devices and Radiological
Health’s medical device reporting database, is an excellent starting point. In addition, access to the Health Devices user reporting system provides a great deal of information on events that do not meet the reporting criteria for health care facilities and manufacturers under the Safe Medical Devices Act. MedLine searches for articles and abstracts relating to problems with the subject device are additional sources of information. If it is not feasible to perform this research in-house, a local database-search firm can provide these services. In using such firms, it is important that all of the search criteria be well defined and that all of the possible search parameters be provided to the service. There have been many incidents of information not being retrieved because the search firm was not given appropriate criteria, thus resulting in a search that failed to reveal information that was immediately available if the proper search criteria had been entered. In addition to researching external information sources, a basic part of the investigational process is reviewing internal documentation. Such documentation includes the operating policies and procedures of the facility, product literature, manufacturer processing and service instructions, professional processing and sterilization guidelines appropriate to the devices’ manufacturer warnings, and the medical records and event reports relating to the incident being investigated. Care must be taken to gather all information and staff opinions before starting to formulate conclusions about the event. It is important that the investigator review all information available before forming opinions. Credibility of the investigator can be severely compromised if new information is revealed that significantly contradicts opinions and conclusions expressed by the investigator.