This thread has gone quiet for a while, but it's a great discussion and I felt there were a couple other important notes to include for those of you regulated by the FDA. How you approach Complaints can have a lot of unintended consequences:
- Be careful not to overtly design your quality processes around what limited resources you have, as a) the requirements do not change based on economic factors, and b) you may end up with findings for both inadequacies in that process as well as 820.20(b)(2) for provision of resources (frying pan to fire!). You always must be able to say your process is designed in a way that meets the requirements, and that you have the appropriate resources to maintain control.
- No matter where you draw the line on calling something a complaint, you are required to assess all sources of quality data to identify existing or potential problems (820.100(a)(1)). Whether you're trying to eliminate noise so you can focus on "real" complaints or limit the effort needed to manage the workload, you must have sufficient evaluation and trending of the "other" data sources to support that you're not ignoring or hiding problems. Additionally, it's possible that by trying to segregate complaint data from "other" data you may not be able to see a growing trend across the two data sets, which can result in a much bigger workload when you find out it's broken.
Lastly, to echo many others: any allegation that your product or service isn't working as advertised is a complaint and must be handled per the requirements of 820.198 regardless whether you call it a "complaint" or any other term. How you process and bucket it is entirely up to you, but you must investigate and justify the actions you take. We log every call/email/interaction where the customer needs support, and if there's an allegation that the product didn't work correctly, it's a complaint. If there's an allegation that there's an unmitigated hazard or harm, it's likely also an MDR and must be reported to the FDA. Be sure you can readily pull both these labels out of any buckets you create to avoid being forced into a more burdensome approach by the FDA.