Friday, May 3, 2024

Design Controls

design control

Having this clear picture is very helpful when it comes to conducting Design Verification. Often times User Needs are broad statements that may be difficult to measure. User Needs include words like “easy”, “better”, “simple” -- subjective, abstract concepts. The expectation is that your Design Review include the right functions (engineering, marketing, manufacturing, etc.).

Design Control for Medical Devices MEDD.X400

And with the right device management tools, you can double down on compliance through automation. Compliance and security go together like peanut butter and jelly, as a custom operating system allows stricter compliance enforcement than anything off the shelf could provide. With the use of integrated drift detection, automated compliance monitoring and enforcement becomes second nature—not a process. When security is baked in at the conceptual level, your device strategy becomes secure by design. Off-the-shelf hardware from reputable vendors is a great starting point—especially for consumers.

Design Input Insight

Design Outputs, Design Verifications, and Design Validations become these risk controls. An industry best practice is to construct a traceability matrix to show the linkages and relationships between User Needs, Design Inputs, Design Outputs, Design Verification, and Design Validation. Data collection and management designed for MedTech clinical trials. Design Validation, on the other hand, is in place to ensure that the final product can consistently meet all the User Needs determined in the first stage.

Keep the DHF separate from project file

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And, just like design inputs, outputs need to be reviewed and approved by stakeholders (with signatures). This document is intended to provide guidance to those involved in designing clinical studies intended to support pre-market submissions for medical devices and FDA staff who review those submissions. This guidance document describes different study design principles relevant to the development of medical device clinical studies that can be used to fulfill pre-market clinical data requirements. This guidance is not intended to provide a comprehensive tutorial on the best clinical and statistical practices for investigational medical device studies.

design control

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Production devices used in design validation may have been manufactured in a production run during process validation. However, if the firm has not completed any design projects, has no ongoing or planned design projects, and has not made a design change, it is only required to maintain a de-fined and documented design change procedure. The following document provides guidance for the preparation of quality system design and manufacturing information to be included in the PMA.

During Design Reviews, you and the project team are formally reviewing -- and agreeing to -- Design Controls. This means your team will review and agree to your User Needs, Design Inputs, Design Outputs, Design Verifications, and Design Validations. A Design & Development Plan describes all the Design Controls, including when Design Reviews are expected. The plan describes who the team members are, including roles and responsibilities. The plan is not a “one and done” and needs to be revisited and updated throughout the project. Project schedule versus Design & Development Planning is in the same vein.

Next-gen MedTech Techniques Applied During Design and Development

I bring this up largely because of the current popularity of “agile” methodology for product development, especially with complex devices and software as a medical device (SaMD). Design Controls and Risk Management address design, development, and manufacturing of medical devices from slightly different perspectives. Ideally, design output records will be generated so it allows for development of your medical device with the same quality and characteristics from scratch. Production specifications typically consist of written documents such as assembly drawings, inspection and test specifications, and manufacturing instructions. However, they can also consist of electronic records, training materials such as video tapes or pictures, and manufacturing jigs and molds.

CQ’s Audit Checklist feature helps quality leaders “know their gaps,” take preventive action and, overall, stay compliant with all regulations. Design Controls are not vastly more burdensome than following sound engineering practices. A process with well-defined stakeholders, responsibilities and goals is a far better experience for teams than a disjointed approach, regardless of the stage of the product. Making changes to the device after VnV is costly since it may require going back and completing VnV activities again. Making sure prior phase reviews have been completed can help prevent sending a device out for VnV that is destined to fail.

But when organizations rely on devices for critical functionality in their businesses, a great starting point isn’t good enough. You need great long-term support, robust security and well-thought-out countermeasures against the growing cyber threat. Please let us know what you think of our products and services.

It is applied early to the development process, as risks and harms are to be considered as an outcome and a driver for User Needs and Design Inputs. Risk is subsequently re-evaluated as the design takes shape and new considerations likely arise. Risk will be continually reviewed throughout the product life cycle. You can get the most out of your design reviews by being strategic about your reviewers.

Design controls encompass the whole lifecycle of a medical device. They begin with approval of the design inputs, encompass development of the design and manufacturing processes, transfer to production and changes to the on-market device. Design outputs are the documents that you would give to manufacturers to make the device and its component. Basically, if you listed it as a work item or deliverable in the design & development plan (covered earlier), then it is a design output.

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