If the FDA Called Today, Could You Find Every Unit?

Iman Jordan

Iman Jordan

Finance records an expired implant on a consignment shelf as a write-off. A regulator calls it evidence you can’t say where your product is. In 2024, Class I medical device recalls hit their highest level in fifteen years.

Recalls at a fifteen-year high, and manufacturers couldn't say where their devices went

In 2024, medical device recalls hit a four-year high, more than a thousand separate events. Class I recalls, the class reserved for a reasonable probability of death or serious injury, reached their highest level in fifteen years. Reviewing the recall process over that same period, a federal watchdog found manufacturers were failing to produce the list of where their product went.*

Somewhere in your network, right now, there's an implant sitting on a shelf in a hospital that your team hasn't seen in ages. It expired last month. Nobody knows it's there.

You have a tidy name for it: a write-off. When someone eventually stumbles upon it in a physical count, the value comes off the books; everyone sighs, and moves on. That's the comfortable version of this story, and it's the one a lot of companies tell themselves.

The risk of expired inventory reaching a patient

Now tell the other version.

The count doesn't find it first. A case does.  

The surgery schedule is packed and this implant on the shelf is the: right size, right system, packaging intact. Nobody scrutinizes the small date printed on the label, because nobody has a reason to. The system says inventory is inventory. It ends up in a patient.

Now the write-off has a body attached to it: a patient who received a device that should have been pulled from circulation, a surgeon who has to be told, a quality team that now owns an investigation, and a regulator who is going to ask the one question you cannot answer: how did you not know it was there and expired?

The expired implant isn't a liability on your balance sheet. It's a liability with a pulse.

You might be telling yourself that in the real world, nobody would ever use it.  

That’s wishful thinking. The reality is that there is no way to ensure nobody will use it, if you don’t know it’s there.  

So think of every expired unit as a landmine you buried in your own supply chain. Each one, with no expiry alert and no chain of custody, is a small charge sitting in the field, harmless right up until the moment someone steps on it. You don't know how many you've laid. You don't know where they are. And your only detection system is the hope that a physical count finds each one before a case does. That isn't a compliance program. It's a coin flip with a patient on the other side.

One unit you can’t see, three problems

On paper, expiry is a numbers problem. In practice, it's far more dangerous. Treating it as a margin problem understates it by an order of magnitude.

Look at the same expired unit through three lenses.

  1. As a financial event, it’s the cheapest version of itself, and even that costs more than the write-off suggests. Depending on the device and your validations, the unit may be recoverable, but recovering it means reverse logistics, inspection, and a quality review. If it isn’t recoverable, that’s replacement cost on top.
  2. As an operational event, it’s worse. Withdrawing expiring stock is ordinary quality control, and teams plan those withdrawals constantly. The problem is the residue: for all that effort, low visibility leaves some units in the field anyway. And when a recall lands, most of which have nothing to do with expiration, that same gap runs under a deadline and a spotlight. Identify every affected unit, trace where each one went, notify accounts, pull stock. A recall is brutal precisely when your visibility is weakest, because it’s nothing but a chain-of-custody exercise.
  3. As a regulatory and patient-safety event, it's the one that ends careers. An expired device with no traceability is exactly what an FDA inquiry pulls the thread on, and “we didn't have a formalized way to track it” is the worst answer you can offer in that room. Behind all of it sits the outcome nobody wants to face: a negative patient result that could have been reasonably avoided, and the legal discovery that follows. Your finance dashboard won't flag this, but an auditor will. A plaintiff's attorney will.

This isn't hypothetical, and what’s worse, it’s not even rare: Medical device recalls hit a four-year high in 2024. With more than a thousand separate recall events, Class I recalls (reserved for a reasonable probability of serious injury or death) reached their highest level in fifteen years, according to Sedgwick's U.S. Recall Index, and they are the smallest share of a much larger volume.

A recall, once it starts, becomes a records exercise almost immediately. FDA's recall rules (21 CFR 806) require the company to hand over the expiration dates and a full list of every consignee, with the quantities and dates shipped to each. The 2025 GAO review of the recall process found that one reason recalls drag on is manufacturers failing to provide exactly that information up front, which is a bureaucratic way of saying they cannot reliably say where their own product went. That is a chain-of-custody failure, and it is on the record.

In every one of those scenarios, your exposure comes down to a single thing: whether you can prove where the product was and when. Call chain of custody “paperwork” if you like, but it is the whole difference between “we caught it, here's the record, here's who we notified” and “we're not sure.” One of those is a controlled process. The other is a headline. Both trace back to the same thing buried in your write-off line.

Inventory visibility provides the sharpest advantage

The solution doesn't require anything supernatural or even complicated. It just requires visibility. With real-time field tracking, an aging unit never just appears close to or past its expiry date, it remains always visible with a realtime ticker accessible for all, so there’s ample time to rotate it to a busier account or pull it back before it can ever become a hazard. The potential write-off becomes a redeployment. The landmine gets defused before anyone steps on it. And when a recall or an audit does come, the answer is already sitting there, assembled.

Movemedical is a comprehensive field inventory automation platform, purpose-built for exactly this: tracking all field inventory down to the piece, serialized or not, everywhere, in real time including expirations. Every unit carries a full chain of custody: where it is, how it got there, and who handled it along the way.

So picture getting the call. The FDA is on the line with one question: do you know where every unit is? Without a system, that question starts a scramble that can run for weeks. With Movemedical, you answer it before the call ends. No guesswork means happy FDA.

Companies running Movemedical are not answering for the problem. They're ahead of it.

Your Counting Method Is the Actual Exposure

Knowing where every unit is doesn’t start with a platform migration. It starts with something you haven’t measured: how many at-risk units are sitting in your network right now processes are in play for managing your field inventory, what workarounds are currently in play for mitigating those visibility and traceability gaps, and what they’re costing you today.

A Field Inventory Management Value Assessment examines how counting gets done: how often, by whom, and with what tooling. It identifies where in your channel the visibility gaps open, which of those gaps put expiring stock most at risk, and what the workarounds cost in rep time and recoverable value. You get an executive-ready business case scoped to your operations, not industry averages. No new hardware. No signed contract.

Request your FIM Value Assessment

Sources

Sedgwick, 2025 U.S. State of the Nation Recall Index (15 Year High)

24x7mag, Medical Device Recalls Reach Highest Level in Four Years

U.S. FDA, Recalls, Corrections and Removals (Devices), 21 CFR 806

U.S. Government Accountability Office, Medical Device Recalls (GAO-26-107619), 2025

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FAQs
FAQs

Frequently
Asked Questions

What happens if an expired medical device is used in a surgery?

It becomes a patient-safety event. The manufacturer typically faces a quality investigation, notification obligations, potential recall activity, and FDA scrutiny of how the unit remained in circulation past its expiration date. Legal discovery commonly follows.

What does the FDA require during a medical device recall?

Under 21 CFR 806, a company must report the device's expiration dates and provide a full list of every consignee, including the quantities and dates shipped to each. In practice this makes a recall a chain-of-custody exercise conducted under a deadline.

How common are medical device recalls?

More common than most teams assume. Sedgwick's U.S. Recall Index recorded medical device recalls at a four-year high in 2024, with more than a thousand separate recall events, and Class I recalls at their highest level in fifteen years. Class I is the rarest category. Most recalls are Class II and III, driven by packaging, labeling, or correction notices. They are less severe per event and far more frequent, and because they are rarely treated as emergencies, they are often where chain of custody breaks down.

Why are expired implants on consignment shelves so hard to find?

Consigned inventory sits inside hospitals rather than in a manufacturer's warehouse, often at accounts a rep visits infrequently. Without real-time tracking and expiry alerting, the only detection method is a periodic physical count, which means a unit can sit expired for months before anyone looks at it.

What is chain of custody in medical device field inventory?

It is a continuous record of where a unit has been, when it moved, and who handled it, from shipment through use or return. It is the evidence that answers a regulator's questions during a recall or inquiry, and its absence is what turns a routine recall into a prolonged one.

Can expired field inventory be recovered before it becomes a write-off?

Yes, if it is visible early enough. Real-time field tracking surfaces an aging unit months before its expiration date, which leaves time to rotate it to a higher-volume account or pull it back while it still carries value.

How do manufacturers prove where every unit is during an FDA inquiry?

By producing a complete, auditable record on demand rather than reconstructing one after the fact. Movemedical, a purpose-built field inventory management platform, lets manufacturers account for every unit and its full chain of custody — where it is, how it got there, and who handled it — without assembling the answer manually.

What is an FIM Value Assessment, and what do we get out of it?

It's a scoped, no-commitment financial diagnostic built on your own operational data — not industry averages. We identify the highest-impact business unit or region, quantify the specific financial friction (write-offs, expiry, billing delays, carrying costs), and deliver a board-ready executive brief with a 3-year financial model. If the numbers don't justify action, we'll tell you that directly.

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