Search Results for: 13485

What is a MEDDEV?

The author defines what a MEDDEV is, recent updates, and information resources to learn more.

The most important part of my website is “Helpful Links.” These are the links that I use most in Regulatory Affairs. It started as an auditor’s toolbox, but now I am morphing it into a place to review updates to regulatory requirements and external standards. The MEDDEV’s are on the top of my list. These are the guidance documents written by Competent Authorities. Still, most of the Notified Bodies treat them as requirements and often write nonconformities against at least one of them: MEDDEV 2.12/1 – Medical Device Vigilance System.

Many companies rely on RSS feeds to keep them current on the latest external standards, but this doesn’t work for a MEDDEV. For MEDDEV’s, your best bet is to go to the source. Sure, you can hire a consultant that will try and keep you current. You can also wait until your NB auditor lets you know the hard way (i.e.,. – time to write another administrative CAPA).

For those of you who don’t know the source, it is my #1 “Helpful Link”:

http://ec.europa.eu/health/medical-devices/documents/guidelines/index_en.htm 

When asked how to keep current, my advice is to have a systematic process for checking various sources of external documents. At a minimum, you should be checking all of the possible sources just before each Management Review. This will give you something to include for the requirement in clause 5.6.2h) of the ISO 13485:2003 Standard. “More preferably,” as lawyers would say, check out the website link above at least once per month. For those of you that are completely out of touch, and those that just fell off the University hayride, the following explains why you can’t get away with saying:

“There haven’t been any new or revised regulatory requirements since the last Management Review.”

MEDDEV Updates

There were several updates to the MEDDEVs released as supporting documents for the M5 version of the MDD (93/42/EEC as modified by 2007/47/EC). Specifically, there were four in December 2009 and one in June 2010. Then there were two more MEDDEVs released in December 2010 related to clinical study requirements in Europe. In January 2012, another six MEDDEVs were released, and one more was released in March. Not all of these updates apply to every company, but every RA professional working on CE Marked products has been busy readying themselves to sleep at night.

I could spend some time here telling you a couple of sentences about each of these new MEDDEVs, but someone already did that for me:

http://www.eisnersafety.com/eu-medical-device-meddevs-guidance-docs-newly-rlsed-or-updated/#.T8Oml7Dy-So

One fellow blogger indicated that the MEDDEV 2.5/10, about Authorized Representatives (ARs), was disruptive:

http://medicaldeviceslegal.com/2012/02/09/new-meddev-on-authorised-representatives-everything-you-know-is-wrong/

I don’t agree with Erik Vollebregt about it being disruptive. Erik feels that we can all expect substantial revisions in the AR contracts, but I think the Germany AR’s I have worked with were already moving in this direction. Emergo has been a strong AR all along—with a distinctly more friendly Dutch style to their processes. In the end, I just don’t see Notified Bodies (NBs), making these contracts a priority initiative. I think we’ll see more auditors verifying that contracts are in place and current, but I don’t expect auditors to receive guidance on how to review contracts anytime soon.

The real changes will be in the smaller AR’s that are not European Association of Authorized Representatives (EAAR) members. The Competent Authorities (CAs) have been knocking on the door of various “wannabee” AR’s for a few years now. I think they have done an excellent job of shutting down illegitimate representatives, and the member companies of EAAR (http://www.eaarmed.org/) have done well in raising awareness. The next logical step was to provide some guidance so that there is more consistency among the ARs. I see this as just the beginning of the CA’s moving toward one approach.

Erik wrote another article about MEDDEV 2.12/2 on the subject of Post-Market Clinical Follow-up (PMCF):

http://medicaldeviceslegal.com/2012/01/17/new-eu-guidance-on-post-market-clinical-follow-up-studies-published-and-other-meddev-guidance-announced/

Erik just touched on this MEDDEV briefly, but if your company is a manufacturer of a Class III device that is CE Marked—YOU NEED TO READ THIS MEDDEV!

MEDDEV Whitepaper

As in all things post-market related, BSI has taken the lead by publishing an article that is almost as long as the original MEDDEV. This white paper was written by Dr. Hamish Forster, BSI’s Orthopedic & Dental Product Expert, and the document is called “The Post-Market Priority.” I think you can only obtain a copy of this white paper by requesting it from BSI online, but the customer service person that follows up is quite polite.

BSI’s leadership role in PMCF is not new, either. Gert Bos gave a presentation that highlighted the importance of PMCF back on March 31, 2010:

http://www.bsigroup.nl/upload/Presentatie%2031%20maart%20-%20Gert%20Bos.pdf

My advice for anyone that has a Class III device that is CE Marked is to read this MEDDEV a few times, Annex X 1.1c of the MDD, read the whitepaper, and review these presentations by Gert Bos. This will help you prepare for what is coming. For those of you that think you know something about PMCF and have justified why your company doesn’t need to do it, think again. You should review the 16 bullet points in the MEDDEV on pages 14 and 15 (17 bullets in the whitepaper, but one was just split into two parts). Identify how many of these points apply to your Class III device. The more points that apply to your product, the more extensive the NB’s will expect your PMCF plans to be.

 

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How to Write Design Control Procedures

The author has reviewed 100+ design control processes in his career, and this blog provides five steps to write design control procedures.

In my previous blog posting, I indicated six things that medical device companies can do to improve design controls. While the last posting focused on better design team leaders (WANTED: Design Team Needs Über-Leader), this posting focuses on writing stronger procedures. I shared some of my thoughts on how to write design control procedures just a few weeks ago, but my polls and LinkedIn Group discussions generated great feedback regarding how to write design control procedures.

No Need to Write Design Control Procedures

One of the people that responded to my poll commented that there was no option in the poll for “zero.” Design controls do not typically apply to contract manufacturers. These companies make what other companies design. Therefore, their Quality Manual will indicate that Clause 7.3 of the ISO 13485:2016 Standard is excluded. If this describes your company, sit back and enjoy the music.

1 Procedure Only

Another popular vote was “one.” If you only have one procedure for design controls, this meets the requirements. It might even be quite effective.

When I followed up with poll respondents, asking how many pages their procedures were, a few people suggested “one page.” These people are subscribing to the concept of using flow charts instead of text to define the design control process. I use the following diagram to describe the design process: The Waterfall Diagram!

waterfall diagram How to Write Design Control Procedures
From the US FDA Website.

I first saw this diagram in the first course I took on Design Controls. This is on the FDA website too. To make this diagram effective as a procedure, we might need to include some references, such as work instructions, forms, the US FDA guidance document for Design Controls, and Clause 7.3 of the ISO 13485:2016 Standard.

Many Design Control Procedures

The bulk of the remaining respondents indicated that their company has eight or more procedures related to design controls. If each of these procedures is short and specific to a single step in the Waterfall Diagram, this type of documentation structure works well. Unfortunately, many of these procedures are a bit longer.

If your company designs software, active implantable devices, or a variety of device types—it may be necessary to have more than one procedure just to address these more complex design challenges. If your company has eight lengthy procedures to design Class 1 devices that are all in the same device family, then the design process could lose some fat.

In a perfect world, everyone on the design team would be well-trained and experienced. Unfortunately, we all have to learn somehow. Therefore, to improve the effectiveness of the team, we write design control procedures for the team to follow. As an auditor and consultant, I have reviewed 100+ design control processes. One observation is that longer procedures are not followed consistently. Therefore, keep it short. Another observed is that well-designed forms help teams with compliance.

Therefore, if you want to re-write design control procedures, try the following steps:

  1. Use a flow chart or diagram to illustrate the overall process
  2. Keep work instructions and procedures short
  3. Spend more time revising and updating forms, instead of procedures
  4. Train the entire team on design controls and risk management
  5. Monitor and measure team effectiveness and implement corrective actions when needed

The following is a link to the guidance document on design controls from the US FDA website. In addition to the comments I made in this blog, please refer back to my earlier blog on how to write a procedure. You can also purchase Medical Device Academy’s design control procedure and forms.

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Design Team – Needs a Superwoman Leader

mona superwoman Design Team   Needs a Superwoman Leader
“Mona Superwoman” by Teddy Royannez (France)

This blog discusses the reasons for a female design team leader and the qualities and skills that she should possess to get maximum results out of her team.

Last November, Eucomed published a position paper titled, A new EU regulatory framework for medical devices: Six steps guaranteeing rapid access to safe medical technology while safeguarding innovation. While I have serious doubts that any government will ever be able to “guarantee” anything other than its own continued existence, I have an idea of how the industry can help.

The position paper identified six steps. Each of these steps has a comparable action that could be taken in every medical device company. My list of six steps is:

Only the best leaders have:

  1. Only one approach to design controls
  2. Stronger internal procedures
  3. Cross-pollination by independent reviewers
  4. Clear communication of project status to management
  5. Better project management skills

The most critical element to success is developing stronger design team leaders. Design teams are cross-functional teams that must comply with complex international regulations while simultaneously be creative and develop new products. This type of group is the most challenging type to manage. To be successful, design team leaders must be “Über-Leaders.”

Critical Design Team Leader Skills

The most critical skills are not technical skills but team leadership skills. The role of a design team leader is to ensure that everyone is contributing, without tromping on smaller personalities in the group. Unfortunately, there are more men in this role than women.

Why is this unfortunate? Because men have difficulty when it comes to listening (takes one to know one).

We need a leader that will be strong, but we also need someone that is in touch with the feelings of others and will use that skill to bring out the best of everyone on the team. This superwoman also needs to earn the respect of the male egos around the table. She needs to be an expert in ISO 14971, ISO 13485, Design Controls, Project Management, and managing meetings. Our beautiful heroine must also be a teacher because some of our team members will not know everything—even if they pretend to.

The Über-Leader will always remind the team that Safety & Efficacy are paramount. As team leaders, we must take the “high road” and do what’s right—even when it delays a project or fails to meet our boss’s unrealistic timetable. Superwoman must demand proof in the form of verification and validation data. It is never acceptable to go with an opinion.

She will remind us that compromise is the enemy, and we must be more creative to solve problems without taking shortcuts that jeopardize safety and efficacy. She will work harder on the project than anyone else on the team. She will keep us on schedule. She will whisper to get our attention, but she won’t be afraid to yell and kick our ass.

As Jim Croce says, “You don’t tug on Superman’s cape.” Superwoman is the only exception to this rule.

 

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Design Input Requirements: 3 Common Errors

The author reviews three common errors related to design input requirements and uses examples to illustrate compliance.

I have been directly involved in dozens of design projects throughout my career, and during the past three years, I have audited 50+ Design Dossiers for CE Marking of Medical Devices. Throughout most of these design projects, I have noticed one common thread—a misunderstanding of design inputs.

ISO 13485 identifies design input requirements. These requirements are:

  1. Functional (7.3.2a)
  2. Performance (7.3.2a)
  3. Safety (7.3.2a)
  4. Statutory/Regulatory (7.3.2b)
  5. Previous and Similar Designs (7.3.2c)
  6. Essential Requirements (7.3.2d)
  7. Outputs of Risk Management (7.3.2e)
  8. Customer Requirements (7.2.1)
  9. Organizational Requirements (7.2.1)
Design Input Requirements: 3 Common Errors Reviewed

The most common error seems to be the failure to include the outputs of risk management. For those of you that have used design FMEA’s—that’s what the right-hand columns are for. When you identify suggested actions to mitigate risks with the current design, these actions should be translated into inputs for the “new and improved” model.

The second most common error seems to be a failure to consider regulatory requirements. There are two ways this mistake is frequently made: 1) Canadian MDR’s were not considered as design inputs for a device intended for Canadian medical device licensing, and 2) an applicable ISO Standard was not considered (i.e., – “State of the Art” is Essential Requirement 2 of the Medical Device Directive (MDD)).

The third most common error, and the one that drives me crazy, is a confusion of design outputs and design inputs. For example, an outer diameter of 2.3 +/- 0.05 mm is not a design input for a 7 French arterial catheter. This is a design output. The user need might be that the catheter must be small enough to fit inside the femoral artery and allow interventional radiologists to navigate to a specific location to administer therapy. Validation that the new design can do this is relatively straight forward to evaluate in a pre-clinical animal model or a clinical study. The question is, “What is the design input?”

Design Input Examples

Design inputs are supposed to be objective criteria for verification that the design outputs are adequate. One example of a design input is that the catheter outer diameter must be no larger than a previous design that is an 8 French catheter. Another possible design input is that the catheter outer diameter must be less than a competitor product. In both examples, a simple measurement of the OD is all that is required to complete the verification. This also gives a design team much more freedom to develop novel products than a narrow specification of 23 +/- 0.05 mm allows for.

If you are developing a Class II medical device for a 510(k) submission to the FDA, special controls guidance documents will include design inputs. If you are developing a Class IIa, Class IIb, or Class III medical device for CE marking, there is probably an ISO Standard that lists functional, performance, and safety requirements for the device. Regulatory guidance documents and ISO Standards usually reference test methods and indicate acceptance criteria. When you have a test method and acceptance criteria defined, it is easier to write a verification protocol. Therefore, design teams should always strive to document design inputs that reference a test method and acceptance criteria. If this is not done, verification protocols are much more difficult to write.

In my earlier example, the outer diameter of 2.3 +/- 0.05 mm is a specification. Unfortunately, many companies would document this as an input and use the final drawing as the output. By making this mistake, “verification” is simply to measure the outer diameter to verify that it matches the drawing. This adds no value, and if the specifications are incorrect, the design team will not know about it.,

A true verification would include a protocol that identifies the “worst-case scenario,” and verifies that this still meets the design input requirements. Therefore, if the drawing indicates a dimensional tolerance of 2.3 +/- 0.05, the “worst-case” is 2.35 mm. The verification process is to measure either a previous version of the product or a competitor’s catheter. The smallest previous version or competitor catheter tested must be larger than the upper limit of the design output for the outer diameter of the new catheter.

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