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Plague Doctor’s Scary Guide – Available for Pre-Order

The “Plague Doctor’s Scary Guide to Remarkable Remote Quality Audits” by Matthew C. Walker and Robert V. Packard is now available for pre-order from Amazon ($5 pre-order discount until August 28, 2020).

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Book Description for “Plague Doctor’s Scary Guide to Remarkable Remote Quality Audits”

Remote quality audits can be remarkable. Remote audits don’t have to be an 8-hour Zoom meeting marathon that causes deep vein thrombosis. You don’t need a box of adult diapers either. We can teach you a better way.

Unfortunately, today on-site quality audits have become scary adventures into a plague-infested world. Most people describe auditing as more boring than Ferris Bueller’s homeroom teacher. Your top management deeply disdains participating in quality audits, and most CEOs cannot be bothered to show up for an opening meeting unless an FDA inspector is present. Today we are faced with a global viral pandemic that has transformed on-site auditing from a necessary evil to a potentially dangerous job that is positively scary.

Ok, maybe I’m just being dramatic. Maybe it is not so “scary” to hop on a plane to conduct an on-site audit. After all, how many people really die in conference rooms, excluding death from boredom? 

Maybe you always wanted to conduct quality audits remotely to eliminate the cost of travel expenses. Remote audits are especially attractive for supplier audits on the other side of the world. After all, who looks forward to a 14-hour direct flight from JFK to Seoul.

The biggest challenge in changing your audit process from an on-site audit to a remote audit, is that you need to convince top management, your certification body, and the next FDA inspector that remote quality audits are just as effective as an on-site audit.

Quality audits can be a remarkable value-added activity, but I don’t think you will learn how by reading the almighty 645-page tome on value-added auditing that was written by another indie author published on Amazon. You need to stop using the element approach, and learn to conduct audits using the process approach instead. You also need to make better use of the subject-matter experts in your company. They can help you audit a specific process if you teach them how, but they are not joining you on that 14-hour flight. You need to start using remote auditing techniques to get engineers involved in the auditing of areas they know better than you do.

It might not be possible to convince a design engineer to learn to be an effective lead auditor, but you can teach them to an effective audit team member for 90-minutes. Your design engineer can be an audit team member from the safety of their home at 8pm on a Tuesday night when it’s 9am in Seoul on Wednesday morning. Let us teach you and the other engineers in your company how to conduct effective remote quality audits, and we will keep you safe.

I know, you say there is just one problem. How will you convince your boss? Well, you could mention the thousands of dollars you will save in travel costs. You could suggest using those 28 hours of flight time to do something more important than trying to sleep on the “Redeye” Korean Air flight. You could also say that it will be infinitely easier to coordinate five 90-minute Zoom meetings with your supplier than scheduling one full-day audit in Korea.

COVID19 has changed the world as we know it. Your approach to auditing must change with it, or people will literally die. Buy the book now, because I guarantee change will save you money, change will improve the quality of your audits, and change might save the life of someone on your audit team.

20190531 005146 150x150 Plague Doctors Scary Guide   Available for Pre OrderMatthew Walker is the creative genius behind this book. Matthew and Rob Packard just finished creating a new lead auditor course for a major US non-profit training organization. Matthew’s job is to help clients implement new quality systems for ISO 13485 certification. He is the gap analysis guru for the consulting firm, and he is continuously updating quality system procedures. Matthew is a gifted writer. His delightful sarcasm and satire will entertain you while you read about the most boring topic on planet earth.

Rob Packard 150x150 Plague Doctors Scary Guide   Available for Pre OrderRob Packard was the instructor in 12 different lead auditor courses for more than 100+ lead auditors in total. He was a certified lead auditor for CE Marking, CMDCAS, ISO 13485, and ISO 14971. He was director of quality, and the audit program manager, for four different medical device companies. Rob now owns and operates a successful regulatory and quality system consulting firm with six full-time employees, and 100% of the employees work remotely.

Other Information

Our first book was “How to Prepare Your 510(k) in 100 Days.” The book was only made available to attendees of our 510(k) courses in Amsterdam and Las Vegas. We also made an PDF version available to people that purchased our 510(k) templates and 510(k) webinar series.

This new book was the idea Matthew Walker and is being co-authored by Matthew Walker and Rob Packard. The target length is 25,000 words, but we are likely to exceed that. The content will be organized in the order of the ISO 19011:2018 standard.

Sean Gardner is the artist that is creating our book cover design. The above picture is a draft for the cover art (tell us what you think). He is a talented caricaturist and tattoo artist that works at Helheim Gallery in Salem, MA.

We are also kicking off the project with a blog series specific to remote auditing techniques:

  1. Changes triggered by COVID19 in your quality system – May 2
  2. Remote audit opening meeting – 4 changes – May 12
  3. Audit team communications – May 19
  4. Remote audit resources – software and hardware tools – May 26
  5. Risk based auditing applied to remote audits – June 2
  6. Remote supplier audit questionnaire – June 23
  7. Remote audit duration less than 90 minutes – June 30
  8. Remote auditing work instruction – July 14
  9. Planning partial remote audits – July 21
  10. Remote audit invitations – 4 things to remember – August 4
  11. Training new audit team members and lead auditors – August 11

Five (5) new webinars planned on related topics:

  1. Opening Meetings Webinar (free) – May 14, 2020
  2. Audit team communication during a remote audit (free) – June 4, 2020
  3. How to qualify your suppliers webinar (pre-order by June 1) – June 25, 2020
  4. Remote auditing techniques webinar (pre-order by July 1) – July 16, 2020
  5. MDSAP Certification Body Interviews (free) – August 6, 2020

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Remote audit resources – software and hardware tools

If you are planning a remote audit, you will need more remote audit resources than a webcam and web conferencing software. Matthew Walker is a significant contributor as co-author of this article.

20200525 095104 scaled Remote audit resources   software and hardware tools

Clause 5 of ISO 19011:2018 is titled “Managing an audit program,” and subclause 5.4.4 is specific to determining audit program resources. For conducting audits remotely, you will need remote audit resources. Almost every laptop has a built-in webcam and microphone, and that is the minimum functionality you will need to conduct a remote audit. However, adding other software and hardware technology can improve the efficiency and effectiveness of your audit team.

What remote audit resources do you need?

Remote audits are not the same as a desktop audit, because a remote audit requires remote access to more than emails containing procedures and records. Auditors need access to people and access to physical areas of your facility. This creates one of the greatest challenges for this type of audit method. Call me a Negative Nancy, but my suspicion is that most audit plans do not specifically include logistical preparations to support this audit method. On the surface it seems like a simple concept. Internet access and a scanner should cover most of the needs for the auditee to survive this digital encounter. In practice, conducting a remote audit that truly adds value and does more than check boxes, requires serious planning.

Let’s start with the obvious, a remote audit needs a way for the auditor and the auditee to communicate with each other. Ideally, you need more than your phone. We recommend Zoom for video conferencing, but we list several other video conferencing software applications below. Here are the features of Zoom that we typically use during a remote audit:

  • Video Chat – Using Zoom, two or more parties can communicate using video input from webcams. This is nice because it allows for a more visual conversation and you can see more of the facial expressions and body language of the person you are speaking with than you can with a traditional phone call. It also allows for sign language to be used if necessary.
  • Screen Sharing – Screen sharing is the most important tool you will use during a remote audit, because it allows you to share documents and records on your screen even if you are not the host. The more records you have electronically, the more valuable screen sharing will be during the audit. An auditor can say, “Can you show me that quality system certificate again?” or “Can you show me where Isomedix is on your approved suppliers list?” Being able to facilitate those verification activities saves the auditee the hassle of emailing documents or uploading content to a shared folder. This ability to share your screen is also essential for an auditee to demonstrate training effectiveness and competency.
  • Recording – Meetings can be recorded in their entirety or in sections. This allows the auditee to record the opening or closing meetings of the audit to share with others that were unable to attend. If there are questions regarding nonconformities, or opportunities for improvement, a recording of the conversation ensures that the auditor has an accurate record of complex objective evidence that would slow down the audit and gives managers a perfect record to demonstrate the issue when corrective actions are initiated.
  • Chat Record – Zoom, and most other video conferencing software, provides a chat box that can be used to take notes. If someone runs to the bathroom, and you don’t want to forget your question, you can enter it in the chat box. Chat boxes are especially helpful when there is a language barrier or someone’s accent is hard to understand. Text typed in the chat box also serves as a place to record information that may be difficult to remember if you cannot access your audit report. If a production area has too much background noise, the chat feature might be the best way to communicate important details, such as: “That information is found in section 7.5.6 of the Quality Manual; POL-001 rev A.” The chat box can also be used to communicate a list of documents, or records in a specific date range, that you want an auditee to make available for you to review off-line. Other participants observing the audit may also be responsible for collecting those documents in real-time to ensure the audit is able to continue without any delay. Finally, content in the chat box can be recorded as a text file automatically.
  • Tour Guide – Video chat allows auditees to bring auditors into physical places of their facility as if the auditor were there in person. Production employees can be interviewed, in person and in real time, while the employee demonstrates processes. You can show how nonconforming materials are labeled and segregated to keep them from accidentally being used for production. When requesting this audit method in an audit agenda, the lead auditor should recommend a dedicated “camera person” with a mobile phone and selfie stick, because it is difficult to answer auditor questions and operate a video camera simultaneously. Remember, remote audit resources consist of hardware, software, and people

My favorite remote auditing tools (hardware)

My favorite hardware resource is the Pixelbook that I am using to write this article. We write audit reports with Google Docs instead of Microsoft Word, because multiple team members can simultaneously edit the same document without creating conflicted versions. We operate Zoom video web conferencing software to speak with auditees and clients, but we use the Pixelbook to type our notes and audit reports. The Pixelbook is lightning fast, and it is a little smaller so there is just enough room on your desk next to a laptop. The biggest advantage of using Google Docs is realized when you are the lead auditor of an audit team. As lead auditor, you can type notes in the section of the audit report that other team members are working on, to make sure that they include audit trails from other members of the audit team. This is also an extremely effective technique when you are training a new auditor and you want to give them guidance without disrupting the flow of an interview with a subject matter expert.

My second favorite hardware resource is an HD webcam mounted on a flexible arm with a clamp (see picture above). The video quality is 1080p instead of the 720p that is typical of a laptop camera. The flexible arm is equally important, because you can look directly at the camera while I’m simultaneously looking at the monitor. The only thing I dislike about the webcam I am using is the audio quality. Therefore, I use a gaming headset with a microphone to record the audio so I can hear the people I am interviewing better. Another alternative is high quality microphone and headphones as typically seen in use by podcasters. Even though the sound quality is ideal with a separate microphone and headphones, the cost is higher than most gaming headsets and you will be tethered to microphone–either physically or at least virtually by the need to maintain a consistent distance between your mouth and the microphone. The more hours you spend at the computer, the more you will appreciate the ability to stand up, adjust the camera and move your legs a little.

Finally, the last piece of essential remote auditing hardware is your mobile phone. Even with a desktop running Zoom, and a Pixelbook running Google Docs, I still need to ask audit team members questions and conduct quick internet searches. Therefore, your mobile phone is essential to keep with you, in silent mode, during your audit. If you don’t have your phone, then you need to stop sharing your screen and send a message during your audit. Your phone is much less disruptive. I use the phone to keep track of time, to set reminder alarms, and to send Slack messages with other people. You can also join a separate Zoom session on your phone where an audit team member may need you (the lead auditor) to provide input on objective evidence or evaluation of conformity regarding specific quality system requirements. You might also want to take a quick picture of something you observe on video during the audit. If you record the Zoom session, you can always extract a still image, but taking a picture with your mobile phone is more convenient and takes less time. You can then share the image with a Google Drive folder for your remote audit and copy the image into your audit report. As they say, a picture is worth 1,000 words.

One last note on hardware: a 48″ flat screen is great for virtual bike rides on your trainer (as seen in the picture above), but it’s just a little too big for a desktop monitor. It’s really nice for side-by-side viewing, but dual monitors is a better approach.

Remote Auditing Resources for Web Conferencing

Currently we are using Zoom as our video web conferencing software, but we used to use GoToMeeting and there is very little difference in the functionality of the two software platforms. One of the consequences of the COVID19 pandemic, is that everyone is more familiar with web conferencing software. Here are a few other options you could consider, including Slack, which we use as a messaging tool and we have integrated with Zoom within our team’s channel.

  1. Google Meeting
  2. Skype
  3. Microsoft Teams
  4. Monday
  5. Slack

Remote Audit Resources for Scheduling Your Audit

Currently we are using Calendly as the automated appointment scheduling software application for our consulting business. However, the functionality of software applications have changed dramatically in the past few years with better integration tools, such as Zappier.  Therefore, don’t be surprised if we change to one of the applications listed below. These applications allow you to manage people, equipment, and conference rooms, but you can also integrate these applications with accounting business processes.

  1. Simplybook.me 
  2. Acuity Scheduling 
  3. Jobber 
  4. Gigabook
  5. vcita

Remote Auditing Accessories

We hosted three international training workshops and we record training videos for medical device companies every week. Therefore, we gradually accumulated all of the accessories listed below. Technology gadgets for recording videos are constantly changing, and our best advice is to save your money. Instead, rely upon a mobile phone and an extra person with “the original selfie sticks” (i.e., arms). Once you complete your first remote audit, then you can think about which of the latest gadgets might make your life easier.

  • Selfie Sticks
  • Tripod
  • External microphones
  • Portable Batteries
  • Additional lighting

If you have any suggestions for additional hardware and software for remote auditing, please add a comment to this article so we can keep this up to date with the latest technology. 

Future Articles & Webinars

Thank you for reading. This article is our third in a ten-part blog series specific to remote auditing techniques:

  1. Remote audit opening meeting – 4 changes – May 12
  2. Audit team communications – May 19
  3. Remote audit resources – software and hardware tools – May 26
  4. Risk based auditing applied to remote audits – June 2
  5. Remote supplier audit questionnaire – June 23
  6. Remote audit duration less than 90 minutes – June 30
  7. Remote auditing work instruction – July 14
  8. Planning partial remote audits – July 21
  9. Remote audit invitations – 4 things to remember – August 4
  10. Training new audit team members and lead auditors – August 11

Five (5) new webinars planned on related topics:

  1. Opening Meetings Webinar (free) – May 14, 2020
  2. Audit team communication during a remote audit (free) – June 4, 2020
  3. How to qualify your suppliers webinar (pre-order by June 1) – June 25, 2020
  4. Remote auditing techniques webinar (pre-order by July 1) – July 16, 2020
  5. MDSAP Certification Body Interviews (free) – August 6, 2020

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Audit team communication

Communication between the auditor and the auditee may be hindered by the lack of visual cues, but software tools can enhance audit team communication.

Audit Team Communication Cup Phone Audit team communication

Audit Team Communication Requirements

During the opening meeting, the lead auditor is responsible for confirming the “formal communication channels between the audit team and the auditee…[and] the auditee being kept informed of audit progress during the audit” (ISO 19011:2018, Clause 6.4.3). Typically, the audit program manager will follow the lead auditor during the audit. In that situation, audit team communication with the auditee is direct and verbal. However, if the audit team consists of multiple auditors, the lead auditor also needs to establish a method of communication between the team members and the lead auditor. Team members need to make the lead auditor aware of any potential nonconformities, but more important information includes:

  1. audit trails that require follow-up by auditors in other process areas
  2. any delay experienced by team members
  3. if an audit team member is ahead of schedule

Communication Limitations During On-Site Audits

During an on-site audit it is not uncommon to have limited communication with the rest of the team, because the team is interviewing auditees and walking through the facility–not sitting at their computer. Sometimes your cellular signal is inadequate for texting or other messenger services such as Slack. It may also be more difficult to have private discussions between team members during an on-site audit. Usually the audit schedule is very tight, and team discussions must wait until lunch breaks or scheduled team discussions. Unfortunately, these limitations frequently result in follow-up of audit trails waiting until the very end of the audit, instead of addressing audit trails at more convenient times in the middle of the audit.

Communication Between Auditors During Remote Audits

During a remote audit, all of the audit team members will readily be able to exchange information by email, text, or Slack. In addition, applications like Google Docs allow multiple auditors to type in the same audit report simultaneously. Therefore, auditors can type a specific follow-up item in the section of the audit report where another auditor will be typing their notes for the applicable audit area. For example, if one auditor is interviewing incoming inspection activities, they can type a note for the auditor that will be auditing calibration to review the calibration certificates for inspection devices used in the incoming inspection process. If an audit team leader needs more time, they can type a quick note for the lead auditor about the need for more time. The lead auditor can also quickly send a Slack message to the rest of the audit team asking if anyone can aid the audit team member that is behind schedule. This communication is efficient, documented directly within the report, and occurs real-time. The result is that communication between team members is more effective and the audit is completed earlier.

Improvement of Auditor Training with Remote Auditing

When audit team members are being trained, the lead auditor must observe their auditing and provide constructive feedback. Ideally, the lead auditor will wait for a “teachable moment.” This is the moment immediately after the lead auditor-in-training makes a mistake. Telling an auditor-in-training what to do during an audit teaches the auditor little. However, if the auditor is allowed to make a mistake, such as forgetting to ask for an audit record, then the lead auditor can point out the mistake immediately afterward. Correcting the auditor can be as simple as adding a note in red font within the audit report in the same section where the auditor is currently typing. The auditor will see the comment and make the correction, but the auditee will not be aware of the error. This approach avoids any embarrassment to the auditor, and the auditor is more likely to remember the instruction as constructive feedback that will make them better.

Remote Auditing Can Be Easily Recorded

Auditors can learn from the constructive feedback provided by a lead auditor, but they can also learn by watching and listening to themselves if the remote audit is recorded. This is especially easy to accomplish for internal audits, but suppliers may also allow recording of certain process audits. Opening meetings, closing meetings, and common procedures such as incoming inspection usually do not include confidential information. Therefore, you should be able to obtain permission to record these portions of the audit. These recordings can be reviewed by the auditor to identify when poorly worded questions were used. Auditors-in-training can identify when they miss an opportunity to follow an audit trail, or an auditor may realize that they ask auditees certain closed-ended (i.e., yes/no) questions instead of open-ended questions that will help them gather more information from the auditee.

Audit Team Communication with Guides

In addition to the communication between the lead auditor and the audit team members, audit team members also need to communicate with their audit guides. Guides should be used to communicate messages throughout the company. For example, if the audit is behind or ahead of schedule, the guide can communicate adjustments in the timing of the agenda. If an audit team member requests records to be provided, the guide can communicate this request and make sure the records are waiting for the auditor when they return to the audit conference room. Guides also are responsible for helping the audit team navigate from one process area to another during the audit, and to make sure that the audit team observes all safety and gowning requirements during the audit. Finally, guides may also be asked to act as an observer and verify objective evidence collected by the auditor.

Shifting Role of a Guide During Remote Audits

During a remote audit, requests for records to be provided and communication of deviations from the agenda can easily be communicated by the auditor chat features in the video conference, instant messengers, or email. Therefore, you might think that a guide is unneeded. However, when audit team members request viewing another area of a facility during a remote audit, it may be necessary to provide live video images of the process areas. It is very difficult to speak with the auditor and provide live video images. In fact, it may be dangerous to walk backwards through your facility carrying a selfie stick and concentrating on your discussion with the auditor instead of where you are walking. Instead, the guide should focus on providing live video, and the process owner should be concentrating on providing a guided tour and answering the auditor’s questions. The guide may also be asked to record certain information in video or picture format as objective evidence.

Conclusion

Audit teams should practice using shared documents in Google Docs and Slack during the audit to facilitate real-time audit team communication. Google Docs enables everyone to write their audit notes directly into an audit report template to eliminate delays in completion of the audit report. Using Google Docs also makes it possible for the lead auditor to observe the progress of the audit real-time. Audit team communications of audit trails for team members to follow-up can be accomplished real-time by just adding a note about the trail in the applicable section of the audit report. Finally, remote auditing can facilitate better training of auditors.

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Remote audit opening meeting – 5 changes

This article describes five minor adjustments that lead auditors should make when they plan a remote audit opening meeting.

Remote Audit Opening Meeting Remote audit opening meeting   5 changes

Regardless of whether you are conducting an on-site audit, or a remote audit, the first activity conducted during the audit is an opening meeting. The process for conducting opening meetings is defined in ISO 19011:2018, Clause 6.4.3; and it is the responsibility of the lead auditor to lead this meeting. There are three purposes to the opening meeting:

  1. confirm agreement to the audit plan,
  2. introduce the roles of the audit team, and
  3. ensure the audit can be conducted as planned.

Opening meeting checklists

There is a long list of items that are typically confirmed during the opening meeting. New auditors are trained to rely upon an opening meeting checklist to ensure that none of the items on the list are accidentally forgotten. Some auditors will rely on a formal presentation during an opening meeting, but usually this requires more time to set-up. Therefore, most auditors work from a pre-written checklist on their computer or on paper.

Change #1: Presentations replace checklists in a remote audit opening meeting

If you are conducting a remote opening meeting, most of the attendees will be looking at a computer screen. The lead auditor can share their screen as they go through a formal presentation, without wasting any set-up time during the opening meeting. In addition, attendees can be emailed the presentation prior to the opening meeting along with the audit plan. If you are the lead auditor planning a remote audit, you should use an opening meeting presentation template to make sure that none of the items in clause 6.4.3 are skipped. If your company is developing a work instruction for conducting audits remotely, you should create a controlled template to ensure consistency among auditors. This should also be done for closing meetings. You can learn more about conducting opening and closing meetings in our webinar on May 14, 2020.

Change #2: Every audit team member should create a personal slide

One of the challenges of being remote is that you have trouble establishing rapport with the auditees. In order to overcome this challenge, you should use live video to show your face, smile, and say hello to auditees. You should also create a slide for the opening meeting presentation that includes a personal picture which conveys your congenial character and less formality. You should also include your preferred method(s) of contact during the audit, such as: email address, mobile phone number, or Slack @username. If you are part of a team, you should also present the slide(s) that explain which process areas you will be responsible for auditing. If you have any special needs, such as vision or hearing impairment, you should also  indicate how you prefer auditees to communicate with you.

Change #3: Edit the agenda during the remote audit opening meeting

Auditors confirm the planned agenda with the auditees during the opening meeting, but adjustments to the schedule are typical of remote and on-site audits. At most on-site opening meetings, everyone will have a hardcopy of the agenda and make notes on their agenda to reflect schedule changes. It is the responsibility of the lead auditor to distribute an updated version of the revised agenda, and to include the updated agenda with the audit report. However, in a remote audit opening meeting, the lead auditor should share a copy of the agenda with everyone in a software tool like Google Docs(see below). When changes are made, switch screen sharing from your presentation to the agenda. You can make the changes in view of all attendees. In addition, if you share the document with auditees, they can correct errors in the audit agenda for you (e.g., spelling of names), and often with greater efficiency than giving you verbal explanation of the changes.

Google Docs Audit Report Template Remote audit opening meeting   5 changes

Change #4: Verify meeting invitations are updated at the end of the opening meeting

When there is an audit team conducting a remote audit, each auditor should send out a separate meeting invitation and include the lead auditor. This is important, because each of the auditors needs to be able to audit simultaneously, but they may need the lead auditor to join their segment of the audit briefly. When changes are made to the audit agenda, such as changing the sequence of process areas being sampled, the time of the invitations needs to be updated for everyone involved. The lead auditor should verify that all of the invitations on their calendar match the updated agenda.

Change #5: Record your remote audit opening meetings (and closing meetings)

Recordings document critical information that might not be captured in the notes of the lead auditor while they are presenting. Therefore, requesting permission to record an opening and closing meeting of an audit is recommended. More importantly, if anyone is absent, the recording can be shared with that person. Finally, recordings allow you to “replay” mistakes and successes. The ability to replay the meeting, and observe yourself, is an invaluable tool for lead auditors in training and anyone that wants to improve.  

How long should your opening meeting be?

Audits are difficult to complete on-time, and therefore shorter opening meetings are desirable. However, the opening meeting is also dependent upon the scope of activities being audited and the number of audit team members. A duration of 30 minutes is typical for an on-site audit, but the opening meetings are often preceded by casual discussion and informal greetings. Teleconference calls and video chat meetings are less conducive to informal greetings, because it is difficult for two people to speak at the same time. The remote meetings also seem more likely to start on-time. Therefore, you should expect a remote audit opening meeting to be more efficient (i.e., shorter).

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Changes triggered by COVID19 in your quality system

The 2020 global pandemic has changed life as we know it, but this article focuses on three important quality system changes triggered by COVID19.

3 things COVID19 changed 2 Changes triggered by COVID19 in your quality system

Last night my daughter Gracie mentioned that her teacher assigned an essay to write about three changes triggered by COVID19 in her life. The three things that she felt had changed the most were: 1) she goes to bed much later, and sleeps in every day; 2) her school is closed, and she only talks to her teacher twice per week via Zoom; and 3) she misses her friends. I know that her story is similar to my son Bailey who is in his Freshman year of college, and I know that my own personal story is quite similar. Coincidentally, I started writing this article earlier this week about three significant quality system changes triggered by COVID19:

  1. If you are going to conduct on-site audits, you need to ask about using personal protective equipment (PPE).
  2. There needs to be greater focus on business continuity plans and robust supply chain monitoring.
  3. Remote audits are suddenly encouraged for 1st, 2nd, and 3rd-party audits.

Changes triggered by COVID19: #1 Use Face Masks

US FDA Issues EUAs

At the beginning of the COVID19 pandemic, the US FDA created several emergency use authorizations (EUA). The three EUA areas were IVD testing, ventilators, and face masks. The EUA for IVD testing is not surprising, because the FDA issues and EUA every time a new lethal and contagious virus emerges (e.g., Zika and Ebola). The EUA for ventilators was issued, because the number of people with respiratory issues was expected to explode with the spread of the virus, and the supply chain for components of ventilators had already been disrupted by the initial spread of the virus in China. The EUA for face masks was issued, because it is the second best way to protect people from the virus and existing infrastructure for face mask production could not possibly supply the entire world with face masks overnight.

Everyone in the World Gets a Face Mask

As soon as the EUA for face masks was issued, every regulatory consultant in the USA was inundated with urgent requests for help to complete EUA requests for masks. I also received similar requests for assistance with Canadian filings. The FDA did a great job of providing detailed information about the different types of face masks (i.e., face masks, surgical face masks, and N95 respirators). Testing companies created new website pages specifically for each of the different face mask tests, and every company with a sewing machine suddenly wanted to manufacture masks. I even read an article about a elderly woman making face masks for her entire family while she listened to The Beatles “HELP!” in the background.

Why aren’t you wearing your face mask?

Even after the world makes the first 7 billion face masks, not everyone will wear their face masks. Masks will protect us from touching our hands to our face–which spreads many germs in addition to the SARS-CoV-2 virus. Masks will also keep us from coughing on other objects and people if we have the virus. Finally, face masks protect us from the small droplets that carry the virus from one person to the next. Even though there are obvious safety reasons for everyone in the world to wear a face mask, most people don’t want to wear a face mask. This is no different from the argument to wear a seat belt, and unless our government creates a law or temporary order requiring us to wear face masks most people won’t bother to wear one.

Changes triggered by COVID19: Auditors need to wear face masks 

As a medical device auditor, I feel it is critical that I always follow safety rules in every facility I visit. Lead auditors are supposed to contact the company ahead of time, and ask about the safety policies as part of audit preparation and initiating the audit. I’m 6’6” (2.00m) in height and my shoe size is 14. There is almost never gowning for me to wear that fits properly–especially in Southeast Asia. I squeeze into the garments and they are uncomfortable and hot, but I wear the garments anyway. My job includes auditing clean rooms, and I can’t do my job without gowning up. By following the rules, I also eliminate the excuses for anyone in the facility I visit. Now that we have a global pandemic, you should be wearing a face mask in every medical device facility to protect yourself, people you work with, and users of medical devices. You should also consider carrying spare face masks with you to protect yourself on airplanes, in hotels, etc.

Changes triggered by COVID19: #2 Business Continuity Plans

Will business continuity plans be required now?

In addition to the cultural shift to wearing face masks, we will also need to make significant changes in our overall preparations for natural disasters, fires, and biological threats. Although there is no specific requirement for a business continuity plan in ISO 13485:2016, there are many places where an auditor can identify a requirement to maintain effectiveness of a quality system (no exceptions):

  1. Clause 1, Scope
  2. Clause 4.1.1 & 4.1.3, General Quality System Requirements
  3. Clause 5.3, Quality Policy
  4. Clause 5.4.2, Quality management system planning
  5. Clause 5.6.3, Management Review Output
  6. Clause 6.1, Provision of resources
  7. Clause 8.1, General requirements for Measurement, analysis and improvement
  8. Clause 8.2.4, Internal audit
  9. Clause 8.5.1, General Improvement

Although any of these clauses could potentially be referenced as a requirement for a business continuity plan, the last clause would generally be the most appropriate. This clause states, “The organization shall identify and implement any changes necessary to ensure and maintain the continued suitability, adequacy and effectiveness of the quality management system…”. In this time of radical change, adding provisions to your business continuity plan for coping with a global biological threat seems obvious and urgently needed.

Suggested content for your business continuity plan

Sadly, the USA was probably better prepared for disaster in the 1960s after the Cuban Missile Crisis than we are today. If you do not yet have a business continuity plan, or if you need suggestions for improving your plan, the following is a list of suggested items to include in your plan:

  1. Develop a plan for power outages, fires, floods, earthquakes, severe wind/tornadoes, hurricanes, workplace violence, and biological threats 
  2. Develop an emergency alert system to notify employees of any emergency
  3. Build emergency kits and store the kits for when they are needed
  4. Document your plan in multiple formats (virtual and physical) and distribute to all employees–including a social media plan
  5. Translate your plan into multiple languages for non-English speaking employees
  6. Develop a training program that address the various aspect of emergency preparation
  7. Practice your plan just like fire drills, so everyone is prepared and nobody panics

The Ready.gov website has many resources for the above items, including a series of “Ready Business Videos” and “Ready Business Toolkits.”

How to practice your business continuity plans

My sister is a teacher, and she is in the process of opening a new charter school in Maine. We were discussing her planning for the school, and the disruption of schools by the COVID19 pandemic has challenged all teachers to learn to use distance learning. My sister’s school focuses on teaching children about the environment, and she doesn’t really like to spend lots of time on the computer. I was sharing some of the environmental studies my daughters are receiving via Zoom from their teachers. I suggested that she might want to pick one topic each week to teach via distance learning. The purpose of this would be to give her and her students practice using distance learning for a variety of subjects. Therefore, when we experience another biological disaster her students will already know exactly how to use distance learning to continue their education. My argument was that this routine use of distance learning will be more effective preparation for emergencies than a once-per-month “fire drill.” The same approach should be used by companies. Your company should create a schedule for practicing remote management meetings and working from home. This will ensure that systems are in place to keep your business running smoothly when disaster strikes again.

Changes triggered by COVID19: Expect regulators to require business continuity plans

The widespread shortage of face masks, ventilators, and other critical supplies needed during the COVID19 pandemic is going to result in new regulations requiring business continuity plans. This is a certainty born from the observation that every single medical device regulation we have resulted from serious public health threats. The COVID19 pandemic is the biggest global health crisis the world has experienced in 100 years. Therefore, we can expect corrective actions in the form of new regulations requiring companies to have a business continuity plan. Some regulators will act independently, but I would expect this to also be an action taken by the International Medical Device Regulators Forum (IMDRF). We can also expect there to be new laws requiring amendments to business continuity plans for public companies. The Sarbanes-Oxley Act of 2002 requires public companies in the USA to have business continuity plans. Despite this requirement, many public companies have been ruined by the COVID19 pandemic. Therefore, we should expect amendments to these requirements and revisions to the international standard for business continuity planning (i.e., ISO 22301:2019). We should also expect to see new interest in becoming certified to this standard.

Changes triggered by COVID19: #3 Remote Auditing

What are certification bodies doing about surveillance audits and re-certification audits?

Most of the companies that had initial certification audits scheduled for the first quarter of 2020 were forced to reschedule their audits, because the employees must work from home and the certification bodies must conduct at least some of their audit on-site. The FDA was also forced to cancel all foreign inspections temporarily. However, companies that already have certification need surveillance audits and recertification audits to maintain validity of their quality system certificates. Therefore, certification bodies now have plans for conducting audits remotely. For companies that virtual medical device manufacturers, certification bodies are able to conduct full quality system audits remotely. However, manufacturers with production activities on-site are only able to conduct partial audits. The certification bodies must still conduct on-site audits, but they are being permitted 6 months to conduct an on-site audit to cover the gaps remaining from the partial remote audits. Prior to conducting the partial remote audits, certification bodies are sending out questionnaires to all of their clients to gather information about whether the manufacturers can support a remote audit and to what degree.

Second party audits conducted remotely

Second party audits, also known as supplier audits, have always been of interest for manufacturers to conduct remotely–especially if the supplier is located overseas. The US FDA regulations do not require companies to conduct supplier audits. However, if there are quality problems with suppliers, you are expected to conduct a thorough investigation to identify the root cause of the quality problems. In most cases that requires an on-site audit. However, if your suppliers are providing good quality and they are ISO 13485:2016 certified, then you probably are using this as a justification for not conducting on-site audits or at least reducing the frequency of those audits. Now that most people are not able to travel, or because the people you need to speak with are working from home, manufacturers are being forced to conduct remote audits. This has always been permitted, but the effectiveness of remote audits is often questioned. Supply chain disruptions are now a global issue that is impacting the safety and effectiveness of our hospitals, and regulators will expect you to improve the rigor of your supplier evaluations–including conducting more supplier audits. Therefore, establishing more effective procedures for remote supplier auditing is urgently needed.

Changes triggered by COVID19: We need to develop procedures for remote auditing

Although most first party audits are conducted on-site, especially if conducted by employees of your company, we will still need to establish procedures for remote auditing for internal audits. Some of our clients scheduled internal audits for the months of April and May that they had to cancel because they were unable to access the records needed for the audit while they were working from home. In addition, most of the US States have implemented stay-at-home audits that prevent our team from traveling to our clients. This is forcing our team to develop more robust procedures for remote auditing. We needed to change our audit agendas to accommodate eight 90-minute audit sessions in four days, instead of conducting two full days of on-site auditing. We are also doing more preparation prior to the audit in order to allow the auditees time to scan paper records so that we can review those records remotely. Finally, we are experimenting with techniques for collaboration as an audit team so that multiple auditors can simultaneously audit a client and complete a full quality system audit more quickly without forcing any one person to work for longer than 90 minutes in front of a computer. We are still perfecting these new methods, but we are writing a series of articles on this topic. You can order the book from Amazon ($5 pre-order discount until August 28, 2020).

Thank you & Future Articles

Thank you for reading. This is the longest article we have published on our site since 2012. This article also kicks off a ten-part blog series specific to remote auditing techniques:

  1. Remote audit opening meeting – 4 changes – May 12
  2. Audit team communications – May 19
  3. Remote audit resources – software and hardware tools – May 26
  4. Risk based auditing applied to remote audits – June 2
  5. Remote supplier audit questionnaire – June 23
  6. Remote audit duration less than 90 minutes – June 30
  7. Remote auditing work instruction – July 14
  8. Planning partial remote audits – July 21
  9. Remote audit invitations – 4 things to remember – August 4
  10. Training new audit team members and lead auditors – August 11

There are also five new live webinars planned on related topics:

  1. Opening Meetings Webinar (free) – May 14, 2020
  2. Audit team communication during a remote audit (free) – June 4, 2020
  3. How to qualify your suppliers webinar (pre-order by June 1) – June 25, 2020
  4. Remote auditing techniques webinar (pre-order by July 1) – July 16, 2020
  5. MDSAP Certification Body Interviews (free) – August 6, 2020

Posted in: Business Continuity Plan, Quality Management System, Remote Auditing

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NSE letter: A CAPA plan for your 510k process

Cry, complain, call the reviewer…you might feel a little better, but you received an NSE letter and tomorrow you still can’t sell your device.

NSE Letter NSE letter: A CAPA plan for your 510k process

Instead, try approaching an NSE letter like a CAPA investigation. What is the issue? The FDA determined that your device is not substantially equivalent to the predicate you selected. What is the root cause? There are four (4) possible root causes.

NSE Letter Cause #1: You failed to verify that the predicate is a legally marketed device.

If your the predicate device is not a legally marketed device, you need to select a new predicate and re-submit. However, it is extremely unlikely that your device would pass the refusal to accept (RTA) screening process if the predicate was not legally marketed. If your predicate was not registered and listed with the FDA (check using this link), then you should have submitted a pre-sub request to determine if the agency has any problem with using the device you chose as a predicate. This is an important question if the manufacturer is no longer in business and the product is no longer for sale.

NSE Letter Cause #2: You failed to evaluate the substantial equivalence of your device’s intended use with the predicate.

The intended use of your predicate device is documented for every potential predicate since February 1992 on FDA Form 3881–which you can download along with the 510(k) clearance letter for the predicate. There is also an intended use documented for every device category in the applicable regulation for that device. This intended use is more generic than FDA Form 3881, but both are applicable. The FDA Form 3881 you submit for your device must be equivalent. I recommend a point-by-point comparison with regard to the following elements: 1) OTC vs. prescription use, 2) user, 3) patient population, 4) illness or medical condition, 5) duration of use, 6) environment of use, and 7) target part of the body. Any difference can raise new issues of risk, and may result in an NSE decision. However, the FDA typically will work with the company to modify the wording of FDA Form 3881 to ensure the intended use is equivalent or to make sure you provide clinical evidence to address the differences. In my pre-submission requests, I include a comparison document for the intended use to ensure that the FDA is aware of any differences in the intended use.

Cause #3: You failed to convince the FDA that technological differences do not raise different questions of safety and effectiveness.

Unless your device is identical in every way to the predicate device, you will have to persuade the FDA that differences do not raise questions of safety and effectiveness. At the beginning of the 510(k) process it is helpful to systematically document technological differences. Specifically, this should include: 1) materials, 2) design, 3) energy source, and 4) other features. For each difference you must provide a justification for why the difference does not raise different issues or you must provide data to prove it. It is also possible that you were not aware of questions of safety and performance raised by technological differences. To avoid this problem you can submit a detailed device description and draft labeling to the FDA in a pre-sub meeting request. If you ask questions about differences in a pre-sub meeting, you can avoid an NSE letter.

Cause #4: You failed to provide data demonstrating equivalence.

For each difference you should determine an objective method for demonstrating that the difference is equivalent in safety and performance to the predicate. Your test method can be proposed to the FDA in a pre-sub request prior to testing. The FDA sees more than 3,000 companies propose testing methods to demonstrate equivalence each year. They have more experience than you do. Ask them in a pre-sub before you test anything. There may be a better test method, or you might need to adjust your test method. Sometimes results are unclear, but there might be another test you can perform to demonstrate equivalence and then you can resubmit your 510(k). Possibly you were unaware of the need to perform a test and you were unable to complete a test within the 180 days the FDA allowed for submitting additional information. The good news is you now have all the time you need.

What is similar between all four causes of NSE letter?

In all four root causes identified above, you could benefit greatly from pre-sub meeting. Now you have an NSE letter and you know which of the four reasons why your submission did not result in 510(k) clearance. However, the correction to your NSE letter may not be clear. Therefore, you should consider requesting a pre-sub meeting as quickly as you can. Most companies choose not to submit a pre-sub meeting request, because they don’t want to wait 60-75 days. However, sometimes pre-sub meetings are scheduled sooner. In addition, 60-75 days is not as costly as receiving a second NSE letter.

Prevent a future NSE letter by requesting a pre-sub meeting

Regardless of your corrections for the current NSE letter, you should prevent future occurrences by planning to submit a pre-sub meeting request for every submission. I try to help clients gather all the information they need without a pre-sub meeting, but each new 510(k) reminds me why a pre-sub meeting is so valuable. You always learn something that helps you with preparation of your 510(k).

Help with Pre-sub meeting requests

The FDA published a guidance document for pre-sub meeting requests. If you need additional help, there is a webinar on this topic.

Posted in: 510(k), CAPA, Design Control

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EU MDR delay – a huge miss

Industry is cheering for the EU MDR delay, but the historic amendment represents a huge missed opportunity to amend the EU IVDR.EU Regulation 1 year delay 1 EU MDR delay   a huge missOn Friday, April 17, 2020 the European Parliament voted 693 votes in favor, 1 against, and 2 abstentions for the EU MDR delay. Parliament voted in favor of a one year delay for the date of entry into force of the EU MDR from May 26, 2020 to May 26, 2021. Although device companies were certain that European regulators would delay the implementation of the EU MDR, regulators repeatedly insisted that it was critical to renew the public confidence in the European device regulations and implementation of the EU MDR would not be delayed. Then the COVID19 pandemic happened, and the EU Council and Parliament cooperated in the creation of a historic amendment to delay the implementation date.

What else was changed in this amendment?

The Commission originally proposed the delay of implementation due to the public health emergency caused by the COVID19 virus. The Council moved forward with the proposal as a first reading, and Parliament adopted the first reading with only two minor corrections. The amendment also includes an important amendment to Article 59, “Derogation from the conformity assessment procedures.” The amendment allows the Commission to issue Implementing Acts that extend emergency measures from a single member state to the whole EU. This effectively creates an additional emergency market access mechanism under the three current directives before the EU MDR comes in to force. This could prove to be important in the current health crisis created by the coronavirus.

Manufacturers are still not out of trouble

Notified Bodies (NBs) were not anticipating a delay in the EU MDR implementation date. Therefore, NBs that had not applied for designation were expecting to no longer need to support the MDD and the AIMD after May 26, 2020. Personnel have left those NBs in many cases, and the resources to support the MDD and AIMD for another year may not be available.

NBs were refusing to quote new CE Certifications under the MDD and AIMD, because there was not enough time to complete new certifications prior to May 26, 2020. However, with the EU MDR delay, there is an additional year in which to process additional applications for CE Certification. The question is whether NBs will have the resources to process additional applications under the current directives.

The transition deadlines for use of inventory has not be delayed, and therefore manufacturers now have one year less of a transition from the directives to the EU MDR. Any certificates issued under the MDD and AIMD will still become invalid on May 26, 2024, because this amendment did not extend the latest date of validity for certificates issued under current directives. The NB bottleneck has also not disappeared. Any NBs that have not successfully been designated under the EU MDR by the end of this year will not be position to significantly help alleviate the bottleneck before the delayed date of enforcement.

Why wasn’t the EU IVDR delayed along with the EU MDR delay?

Implementation of the EU IVDR is arguably in a more difficult position that the EU MDR, because there are not enough NBs that applied for designation under the EU IVDR, and the IVD industry must shift from approximately 20% requiring NB involvement to 80% requiring NB involvement by May 26, 2022. This is expected to result in a shortage of CE Marked IVD products in the EU, and the bottleneck industry has experienced for medical devices will be more severe for the IVD manufacturers. The Commission could still initiate a proposal to delay the implementation of the EU IVDR, but it would seem logical to take this opportunity to delay the date of both regulations coming into force at one time when there was almost unanimous support for the amendment.

The Commission’s original proposal stated “As the coronavirus crisis increases demands for certain vital medical devices, it is crucial to avoid any further difficulties or risks of potential shortages or delays in the availability of such devices caused by capacity limitations of authorities or conformity assessment bodies related to the implementation of the Medical Devices Regulation.” This argument for delaying the EU MDR would seem to be equally valid for the EU IVDR. In addition, the amendment made to Article 59 could also be made to the equivalent section of the EU IVDR (i.e., Article 54). In the current crisis, the power of Commission to expand the availability of in vitro diagnositic tests is critical. Therefore, limiting the amendment to the EU MDR seems like a huge missed opportunity.

What the EU IVDR needs that was not possible for the EU MDR delay

The EU MDR was less than 60 days from the date of enforcement when the Commission presented its proposal for the amendment to delay the EU MDR. Therefore, it was necessary to forgo formal procedures for review and approval of amendments. We have more than 750 days until the date of enforcement for the EU IVDR. Therefore, there is more time for the Commission to think carefully about any additional changes that might be desired in the fight against a global pandemic. The need for rapid market access for in vitro diagnostic tests, both molecular and serological tests, will be crucial in the coming months for identifying people with active infections and resistance to the virus. Hopefully, the Commission will watch, learn, and take preventive action in the form of an amendment to the EU IVDR.

Posted in: CE Marking

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Design change control – best practices in managing changes?

This article describes best practices in managing your design change control process, including a list of the 10 most common mistakes.

Tire Change Image for Change Control Blog Design change control   best practices in managing changes?

During every visit by FDA inspectors, and CE Marking auditors, the changes you have made will be reviewed. The focus by inspectors and auditors is: 1) to verify that your design verification and validation was adequate for the changes, and 2) to verify that necessary regulatory approval of the changes was obtained. Due to this scrutiny, your design change control process is one of the most important processes to manage well.

10 most common mistakes in managing design change control

  1. Failure to carefully update drawings and specifications. Often these errors are typos, but it is important to perform a thorough review of all your drawing dimensions, tolerances, notes, etc.
  2. Failure to update procedures and work instructions, especially inspection instructions. As a quality system becomes more mature, it becomes harder to identify all the places where a reference is found. If you have a 100% electronic quality system, with the ability to include cross-references, finding the related documents is easier. MasterControl uses “info cards.” It is possible to do this in any system by adding tags to your master document list. The “tags” can be standards, regulations, other procedures, and forms.
  3. Failure to validate inspection methods. Often a new inspection tool or method may appear to be better, but it is important to revalidate inspection methods whether you are changing: 1) design, 2) inspection tools, or 3) inspection methods. A Gauge R&R study is an example of one method for validation of inspection methods.
  4. Failure to re-verify and re-validate your design. In general, whenever you make a design or process change, you need to repeat your verification and validation that was initially performed. You may be able to abbreviate the verification and validation testing, but if you cannot provide a justification for the abbreviated method, then you should use the same method and the same acceptance criteria. This obviously presents an enormous burden for any device that required a clinical study to demonstrate safety and effectiveness. This is also why it is so expensive to implement changes in CE Marking for Class III devices and for FDA approved Class III PMA devices. In both cases, there is typically a large supplement required for regulatory approval.
  5. Failure to update your risk management documentation and post-market surveillance plans. Risk management files and post-market surveillance plans are meant to be “living documents.” Therefore, whenever you make changes, even minor ones, you should document your evaluation of the need to update the risk management file or your PMS plan. If the changes planned are related to a CAPA or recall, it is critical to verify the effectiveness of the changes made. This verification is both a verification of the design change and the effectiveness of your risk controls. It will also be critical to document the change in the PMS plan by identifying potential confusion and use errors associated with your change.
  6. Failure to change UDI. Most companies created their change control procedure in the early stages of their quality system, and very few revisions and updates are made to the change control procedure and associated forms. Your UDI process and procedure are probably much more recent, and many companies forget to add UDI requirements to their change control process. It is important to update your device identifier, not only for regulatory compliance, but also as a tool to help your company better track which quality issues are related to the previous version of your device and which quality issues are limited to the new version.
  7. Since the EU MDR requires that DI portion of your UDI is included in your Declaration of Conformity, this is another document to make sure you update when you make a design change. In fact, I recommend identifying the date (or lot) of first CE Marking and last CE Marking for your previous version in an updated Declaration of Conformity. Then you will also need the date of first CE Marking for the new version of your product. This can create a very long and complicated declaration, but it is important to control these transitions in anticipation of potential complaint investigations during the period of time when both versions are in distribution/use.
  8. Failure to update your technical file and device master record (DMR). Every time you change a drawing, specification, tolerance, testing method, etc. you need to update your technical documentation and DMR. This is why using a Technical File Index and DMR Index are considered best practices. These tools just list all the related controlled documents and the current revision. The best indices will also identify how revisions were controlled (e.g., change notification or design change order). You might even identify which CE Certificate or 510(k) clearance is associated with each item in the index. This is especially helpful when you have multiple accessories involved. FDA inspectors will verify that you updated your DMR, and they will review the MDR for design changes that were not adequately validated. Your Notified Body will also review changes made to your Technical File to make sure you have notified them of changes or obtained prior approval to commercial release.
  9. Failure to document your rationale for no new regulatory approval. Whenever you make a change you need to document your rationale for whether a new regulatory submission is required. You should have a systematic method that is documented. The FDA has published two guidance documents with decision trees to assist with this decision for 510(k) cleared products: 1) Deciding When to Submit a 510(k) for a Change to an Existing Device, and 2) Deciding When to Submit a 510(k) for a Software Change to an Existing Device. For CE Marking and Canadian Licensing, there are guidance documents on determining when a submission is required for significant changes. Regardless of your decision, you need to document the decision and the form you use to document this decision should be a controlled form within your change control process.
  10. Failure to notify suppliers of your changes. Whenever you make a change, it is critical to notify your suppliers of the change. However, you also need to determine if there are any open purchase orders that may be impacted by the change. Will you need to rework or scrap any work in progress? Will you need to coordinate the use of components so that all components are used up before the change? There may even be obsolete inventory that you need to disposition as “use-as-is” or “rework.”

Create controlled templates for verification and validation testing

For every verification and validation test that you perform, you should have some kind of documented testing plan or formal protocol. Plans are more appropriate when the testing will be outsourced to a lab that has their own testing protocols. If you are performing the testing in-house, you should have a formal protocol that references any internal testing work instructions that may be relevant and any testing standards that apply. The protocols should also be designed for “fill-in-the-blank” use in order to facilitate reuse of the protocol for multiple devices. Protocols should also identify the following required elements: 1) facilities needed for testing, 2) calibrated devices needed for measurement, 3) any controlled documents or standard referenced in the protocol, 4) sample requirements, 5) acceptance criteria, and 6) statistical rationale for sample sizes. The FDA also released a guidance document defining the format and content for testing reports. Whenever a standard is revised, it will also be important to assess the impact on current regulatory approval. CE Marked products will need to be retested to the new standards or at least a scientific justification must be provided. By maintaining these plans and protocols as controlled documents, you will be able to execute testing plans and protocols much more quickly and consistently. You may also want to consider maintaining an appendix for testing plans that identifies any vendors and contacts for obtaining quotations for new testing.

Organizing design change control approval forms

One of the biggest mistakes people make is to try and streamline questions down to check boxes or yes/no questions. For example, don’t ask the question “Is 510(k) clearance required for this change?” Instead, require the person to always fill out a form to document the decision for whether a 510(k) is required or not–which should also be a controlled form. Don’t ask the person if there is inventory that is affected by the change. Instead, ask the person to identify how many units are at each stage of the process (i.e., pending purchase orders, inspection quarantine, and finished good inventory). Then ask the person to identify the disposition for the product at each stage. This would typically be documented with a nonconforming material record (i.e., NCMR). You should also define which roles and responsibilities complete each part of your form, unless you have a small company where key individuals are responsible for multiple roles.

Who should approve design changes?

There is no specific requirement for who must review and approve changes, but each document that is revised and updated will need to be reviewed and approved by the same functions that approved the previous version. Therefore, it would make sense that the same functions who reviewed and approved the design in a final design review should also be involved in the review and approval of a design change for the same device. There is no requirement for an independent reviewer for design change review and approval, but I have observed so many mistakes and I think an independent reviewer and approver is extremely valuable for design changes.

What if you are facing a deadline

There is always pressure from peers and superiors to release design changes to the market as soon as possible. In theory everything new is better, but this is often untrue. Forcing everyone to follow your change control process is intended to prevent release of a product that is not ready for release. Therefore, you should fill out as much of your design change approval form at the beginning of a design change as possible. This will help everyone identify the documentation updates at the beginning. All the documentation and testing that is required should be planned in advance, target dates for completion of each update should be documented, and the person responsible for each updated document should be identified. By documenting your plan and maintaining that plan, everyone will know what needs to be completed before a modified device can be released. By controlling the changes in this way, it becomes the responsibility of the whole team to make sure each document is completed by the responsible person and on-time. If you adopt this strategy, more device changes will be released on-time. You will also find that fewer mistakes will be made and the team will share the burden of meeting launch deadlines.

Are “full” design controls required?

For minor design changes, you don’t want to apply “full” design controls and create a new design history file (DHF). However, you may want to create a shorter version of a design plan to document what level of control is required and how the project will be managed. This could be as short as a page, but it is likely to be several pages. The following is a list providing examples of things you might document in the abbreviated plan for control of design changes:

  1. Previous regulatory approvals [e.g., 510(k) number]
  2. Applicable Technical File or DMR Index that will be updated
  3. Any new risks identified
  4. Any new applicable standards
  5. Approved Design Inputs (indicate if changes are needed)
  6. Design Outputs that need to be updated (consider highlighting in your DMR index)
  7. Changes to your supply chain (e.g., process changes, supplier changes, supplier quality agreements and process changes)
  8. Process validation and Revalidation required
  9. Labeling and UDI changes
  10. Obsolescence of inventory and reverse/forward compatibility of components
  11. Impact on service procedures and/or providers
  12. Changes and changeover of internal calibrated tooling and testing stations

What if you are making a design change before a product is commercialized?

The quality system requirement for control of design changes also applies to changes made prior to release of a product. During the design process, changes made prior to “design freeze” will be frequent. For these changes you want to make the process as simple as possible. Once you begin purchasing capital equipment and performing verification or validation testing, now the design changes are extremely expensive. This is when you really must have tight control of changes. Many companies designate that drawings and specifications have begun design transfer when the revision changes from a number (e.g., 1, 2, 3) to a letter (e.g., A, B, C). This is helpful to identify any documentation that will now require tighter design change control. If the design is being conducted internally, then a representative of top management may need to approve changes. If the design is being conducted by a contract design firm, then approval by the customer may be required for any changes during design transfer.

Additional design change control resources

If your firm needs a procedure for design change control, please visit our webpage for our Change Control Procedure (SYS-006). If you are interested in Design Controls, prior to the release of a product from the design process, please visit our webpage for the Design Change Procedure (SYS-008).

Posted in: Design Control

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What can you do to save freedom today?

Today Americans remember Dr. Martin Luther King Jr, but this weekend I had the privilege to visit the Liberty Bell and saw the picture below.Martin Luther King Jr with Liberty Bell rvp 1 19 2020 What can you do to save freedom today?Today, the third Monday in January, is the day Americans observe Dr. Martin Luther King Jr’s birthday. Dr. King was a leader of the Civil Rights Movement in the USA, but he also stood for peace. I like to think that on February 1, National Freedom Day, he would still be visiting our Liberty Bell in the City of Brotherly Love.

Saturday I was in Philadelphia, and Tifany and I took the time to visit the Liberty Bell. It has been more than 30 years since I last visited the Liberty Bell in Philadelphia. The last time I was with my grandparents as a young boy. My grandfather was a Quaker, and he taught me every day about principles he believed in:

  • Peace
  • Religious Tolerance
  • Helping Others

He lived these principles in everything he did, and I remember most his gentle greeting when he said hello to someone. If the other person said, “How are you today?” his reply would always be, “All the better for meeting you today.”

This was one of the Quakerisms he developed on his own over his life, and I encourage everyone reading this to do three things:

  1. Use my grandfather’s greeting to make someone smile today.
  2. Help someone else in need today.
  3. Remember that peace was part of Dr. King’s message too.

The image above includes the following description: “In 1959, Dr. Martin Luther King Jr. and Dr. Emmanual Wright, leaders of the modern Civil Rights Movement, participated in the annual tradition of celebrating National Freedom Day, the commemoration of the Thirteenth Amendment, at the Liberty Bell begun by Dr. Wright’s father. Photograph. “Dr. Martin Luther King, Jr. and Dr. Emmanuel C. Wright at the Liberty Bell,” 1 February 1959. Courtesy, Urban Archives, Temple University Library.”

Posted in: News

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eCopy Guidance is Finally Updated by FDA

This blog summarizes the changes in FDA policy which was released on April 27, 2020 as a new eCopy guidance for device manufacturers.

eCopy statement screen capture eCopy Guidance is Finally Updated by FDA

The date of the guidance above was updated, but the changes to the guidance do not represent any changes in policy. It is an update of contact information and a note regarding eCopies for EUA requests. In August 2016, I had a frustrating week where I had three (3) different submissions placed on eCopy hold by the FDA, three (3) different times, for a total of nine (9) eCopy holds in the same week. That resulted in an extra $175 of FedEx charges and wasted six (6) USB flash drives. The biggest problem was the submission delay experience by each of our clients that week, and it was quite embarrassing. This terrible, no good, very bad week ultimately resulted in our company creating a new productized service–preparing FDA eCopies for clients and competitor consultants. We also became the international experts on the FDA eCopy guidance. I figured if my experience was this painful, there must be other people that were experiencing the same problem, or many people would experience this problem as soon as they tried to submit their next filing with the FDA.

For about 18 months we helped a lot of companies prepare FDA eCopy submissions, but then their was a government shutdown and the FDA unofficially changed their policy. A printed, paper copy of pre-submissions, 510ks, and De Novo classification requests would no longer be required. You only needed to print a paper copy of your cover letter and include an electronic copy on a CD, DVD, or USB flash drive. Despite this change in policy, many clients still requested the printed copy, because the FDA legislation was not yet changed and their was not updated guidance. We explained to each client that the policy had changed, and only two clients asked us to print the paper copy anyway.

In the fall of 2018, the unofficial policy became official, but there was still no updated FDA eCopy guidance for us to refer clients to. This situation frequency resulted in questions from clients about how they should phrase the “eCopy Statement” in their submission cover letter. The eCopy guidance that was current at in 2018 stated that you should include the following phrase in your cover letter: “This submission includes an eCopy and a paper copy. The eCopy is an exact duplicate of the paper copy.” However, the paper copy consisted only of the cover letter, and the rest of the submission was only being provided in electronic format.

The FDA released a new pilot version of the eSubmitter software to help companies prepare 510(k) submissions and to streamline the FDA review of submissions in 2018. However, the even electronic submissions prepared with eSubmitter still have to be sent by courier or mail to the FDA Document Center. In 2019, the FDA mentioned that they would be releasing new guidance documents regarding electronic submissions, but we were also told that the FDA has no near-term plans to enable companies to submit pre-submissions, 510ks, or De Novo classification requests to the FDA via an electronic submissions gateway (ESG).

Finally, on December 16, 2019 the FDA released a new eCopy guidance. The eCopy guidance was updated again on April 27, 2020 but the changes are updates to include emails, updated webpages, and a note regarding EUA requests.

What DID NOT change in the new eCopy guidance?

The file name requirements are identical. You can still organize your submission in volume structure or document-only structure. You are still limited to PDF file sizes of 50 MB. The eCopy will still be problematic for the FDA to upload if your submission exceeds 1 GB. You still need to ship your eCopy to the FDA Document Center, unless you are submitting to CBER instead of CDRH. You can and should continue to use the eCopy validation software module provided by the FDA to ensure that your eCopy will properly upload. The guidance barely even changed in length; it’s just a few pages shorter now.

What DID change in the new eCopy guidance?

Only two things changed in the new guidance. First, there is no mention of an eCopy statement anywhere. Second, you are required to submit a cover letter in paper format, but it does not need to be included in the electronic format (that’s only recommended).

The “new” eCopy process is not really any easier than the process we have been using since February 2018. However, we did update our cover letter template. If you would like a copy, please register for our FDA eCopy webinar.

Should you create you own eCopies or should you outsource?

If my job was Director of Regulatory Affairs (or a similar position), I would definitely outsource. Regulatory managers in companies are swamped with trying to remain compliant with every applicable medical device regulation, every change to applicable standards, and one hour of your time is a lot more important to your boss than $150.

Does it take one hour to create an eCopy?

No, we can prepare, validate, and ship your eCopy in less than 15 minutes. This is only possible because we do this almost every single day of the week, and we are located only 4 miles from a FedEx full-service office with a 6:25pm cut-off for drop-off. On the last business day before the end of the FDA fiscal year, we average four (4) submissions on that day alone. We know exactly what to do, we know how to fix all of the most common errors, we know our validation software module is up-to-date, and we never run out of USB flash drives.

How long could it take you to create an eCopy?

If you haven’t done an eCopy in that past year, it could easily take you all day to create an eCopy. You have to read the new eCopy guidance document. You need to format your submission according to the rules and proof-read 100% of the folder and file names. You need to find a blank flash drive. You need to save the submission on your USB flash drive. You need to run the eCopy validation software module. You need to read my blog about how to eliminate hidden system volume information folders created by Microsoft Windows 10. You figure out how to find the Command Prompt on your computer. You need to eliminate the hidden folder. You need to re-validate the electronic copy. You need to eject the USB (don’t accidentally re-insert it for any reason). Then you need to download my template for a cover letter, create your cover letter, and sign the cover letter. Then you need to find a FedEx envelope, find the company’s FedEx account number, complete the shipping label, and package up your FedEx envelope. If you’re lucky, you have regular pick-ups scheduled each day, and you finished just-in-time. For 80% of you, you will need to look-up the nearest FedEx dropbox and drive there like a crazed maniac and try to avoid getting a speeding ticket.

Or you could just outsource your eCopy problems.  

Posted in: 510(k)

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