the business case for integrated design controls

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The Business Case for Integrated Design Control Presented by: Jon D. Speer Founder & VP QA/RA of greenlight.guru 1

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Page 1: The Business Case for Integrated Design Controls

The Business Case for

Integrated Design Control

Presented by:

Jon D. Speer Founder & VP QA/RA of greenlight.guru

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Page 2: The Business Case for Integrated Design Controls

Concepts to Cover

Design control integration as a competitive advantage

Improved product quality and speed to market

Learning from others and from experience

Aligning design control with the business process

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Page 3: The Business Case for Integrated Design Controls

About the Presenter

Jon D. Speer is the founder

and VP of QA/RA of greenlight.guru.

• 17+ years in medical device industry

• Product development engineer,

quality manager, regulatory

specialist

• 40+ products to market

• Expert at QMS implementations

• Dozens of ISO audits & FDA

inspections

greenlight.guru produces beautifully simple

quality, design control and risk management

software exclusively for medical device

manufacturers.

@creoquality @greenlightguru

[email protected]

+1 317 960 4280

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Page 4: The Business Case for Integrated Design Controls

Design Controls – Overview

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Page 5: The Business Case for Integrated Design Controls

Design Controls FDA 820.30 Design & Development ISO 13485:2003

Design & Development ISO 13485:2016

(a) General 7.3.1 Design and development planning

7.3.1 General

(b) Design and development planning

7.3.1 Design and development planning

7.3.2 Design and development planning

(c) Design input 7.3.2 Design and development inputs

7.3.3 Design and development inputs

(d) Design output 7.3.3 Design and development outputs

7.3.4 Design and development outputs

(e) Design review 7.3.4 Design and development review

7.3.5 Design and development review

(f) Design verification 7.3.5 Design and development verification

7.3.6 Design and development verification

(g) Design validation 7.3.6 Design and development validation

7.3.7 Design and development validation

(h) Design transfer 7.3.1 Design and development planning

7.3.8 Design and development transfer

(i) Design changes 7.3.7 Control of design and development changes

7.3.9 Control of design and development changes

(j) Design history file No reference 7.3.10 Design and development file

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Page 6: The Business Case for Integrated Design Controls

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Page 7: The Business Case for Integrated Design Controls

What is Design Control?

• SAFE

• EFFECTIVE

• MEET INTENDED USE

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Page 8: The Business Case for Integrated Design Controls

Did I design my medical device

correctly?

Design Input (Requirement)

Design Output (Specification)

Design Verification

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Page 9: The Business Case for Integrated Design Controls

Did you design the correct medical

device?

User Needs Medical Device Design Validation

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Page 10: The Business Case for Integrated Design Controls

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Page 11: The Business Case for Integrated Design Controls

It is my responsibility to document design

controls and maintain the DHF.

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Page 12: The Business Case for Integrated Design Controls

Design Controls – Myths

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Page 13: The Business Case for Integrated Design Controls

Myth: Design Controls Impede Product Development

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Page 14: The Business Case for Integrated Design Controls

Truth: Design Controls Aid Product Development

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Page 15: The Business Case for Integrated Design Controls

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Page 16: The Business Case for Integrated Design Controls

Myth: Design Controls Should Be Delayed Until After A

Working Prototype Has Been Established

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Page 17: The Business Case for Integrated Design Controls

Truth: Design Controls Should Start During Prototyping

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Page 18: The Business Case for Integrated Design Controls

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Page 19: The Business Case for Integrated Design Controls

Myth: Documenting Design Controls Is Too Rigid A Process

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Page 20: The Business Case for Integrated Design Controls

Truth: The Design Controls Process Should Be Flexible

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Page 21: The Business Case for Integrated Design Controls

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Page 23: The Business Case for Integrated Design Controls

Myth: Design Controls Are Optional

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Page 24: The Business Case for Integrated Design Controls

Truth: Design Controls Are Required

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Page 25: The Business Case for Integrated Design Controls

Class I Class II Class III not intended to help

support or sustain life or be substantially important in preventing impairment to

human health, and may not present an unreasonable

risk of illness or injury

more critical than Class I but designed to perform as indicated without causing

injury or harm to patient or user.

support or sustain human life, are of substantial

importance in preventing impairment of human

health, or present a potential, unreasonable risk

of illness or injury

LOW RISK MEDIUM RISK HIGH RISK

General Controls

General Controls + Special Controls

510(k)

General Controls + Premarket Approval

(PMA)

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Page 26: The Business Case for Integrated Design Controls

510(k) Data

http://www.meddeviceonline.com/doc/how-to-avoid-having-your-fda-submission-rejected-and-what-to-do-if-it-is-0001

69% 510(k)s rejected 1st time

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Page 27: The Business Case for Integrated Design Controls

510(k) Data

1.0 Medical Device User Fee Cover Sheet (Form FDA 3601)

11.0 Device Description

2.0 CDRH Premarket Review Submission Cover Sheet 12.0 Substantial Equivalence Discussion

3.0 510(k) Cover Letter 13.0 Proposed Labeling

4.0 Indications for Use Statement 14.0 Sterilization and Shelf Life

5.0 510(k) Summary 15.0 Biocompatibility

6.0 Truthful and Accurate Statement 16.0 Software

7.0 Class III Summary and Certification 17.0 Electromagnetic Compatibility and Electrical Safety

8.0 Financial Certification or Disclosure Statement 18.0 Performance Testing – Bench

9.0 Declarations of Conformity and Summary Reports

19.0 Performance Testing – Animal

10.0 Executive Summary 20.0 Performance Testing – Clinical

Sections of a 510(k)

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Page 29: The Business Case for Integrated Design Controls

• Myth: Design Transfer is an event • Truth: Design Transfer is an iterative, continuous process

• Myth: Design Transfer is Operations’ responsibility • Truth: Design Transfer is a collaborative effort between all of

the functions involved in design and development

• Myth: Design Transfer occurs after “design freeze” • Truth: Design Transfer begins early in design and

development, and is part of design refinements (design changes) that lead to a “final” design. Design Transfer can not end until the DMR is finalized.

Design Transfer Myths

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Page 30: The Business Case for Integrated Design Controls

Source of Misconceptions 21 CFR Part 820.30 Design Control

b) Design & Development Planning

c) Design Input

d) Design Output

e) Design Review

f) Design Verification

g) Design Validation

h) Design Transfer

i) Design Changes

Which gets visualized as:

Planning Design Input

Design Output

Design Review

Design Verification

Design Validation

Design Transfer

But the process really looks more like this:

Design & Development Planning

Design Input

Design Output

Design Verification

Design Validation

Design Transfer

Design Review

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Page 31: The Business Case for Integrated Design Controls

Design Transfer Completion • All Device Master Record (DMR) elements reviewed,

approved, and production released

• All (DMR) elements are managed under formal change control

• Risk assessments completed and all identified risks appropriately dispositioned

• Defined and implemented test strategy for incoming, in-process, and final acceptance testing

• Plans in place to monitor and/or control features identified as critical to quality

• Process validation complete

• Test methods validated and complete

• Inspection procedures, visual inspections, and workmanship standards are complete

• Installation and servicing procedures are complete

• All equipment identified and calibrated and maintenance procedures are in place

• Manufacturing personnel and inspectors have been trained

• All supplier agreements and qualifications are complete

• Procedures in place to ensure control of device handling, storage and distribution of product

• Procedures in place to ensure identification and traceability of product

• Design verification testing performed and demonstrates design outputs meet design inputs

• Design validation testing performed demonstrates design meets user needs & intended uses

• All elements of the Design Transfer Plan have been completed or otherwise addressed

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Design Controls & FDA Inspections

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510(k) Data

http://www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofMedicalProductsandTobacco/CDRH/CDRHTransparency/UCM490768.pdf

CFR Clause QS Subsystem # 483 Observations % of 483s

820.30 - Design Controls DES 536 15%

820.100 - Corrective and Preventive Action CAPA 474 13%

820.198 - Complaint Files CAPA 435 12%

820.90 - Nonconforming Product CAPA 222 6.3%

820.80 - Receiving, In-Process, and Finished Device Acceptance

P&PC 195 5.5%

820.75 - Process Validation P&PC 180 5.1%

820.70 - Production and Process Controls P&PC 153 4.3%

820.184 - Device History Record DOC 152 4.3%

820.22 - Quality Audit MGMT 145 4.1%

Top 9 Reasons for 483 Observations by CFR Clause in 2015

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Page 36: The Business Case for Integrated Design Controls

510(k) Data

http://www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofMedicalProductsandTobacco/CDRH/CDRHTransparency/UCM490768.pdf

CFR Clause QS Subsystem # WL Citations % of WL Citations

820.100 - Corrective and Preventive Action CAPA 171 25%

820.30 - Design Controls DES 101 15%

820.198 - Complaint Files CAPA 76 11%

820.50 - Purchasing Controls P&PC 54 7.8%

820.90 - Nonconforming Product CAPA 48 7.0%

820.75 - Process Validation P&PC 45 6.5%

820.70 - Production and Process Controls P&PC 45 6.5%

820.80 - Receiving, In-Process, and Finished Device Acceptance

P&PC 41 5.9%

820.22 - Quality Audit MGMT 38 5.5%

Top 9 Reasons for Warning Letter Citations by CFR Clause in 2015

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Design Controls – Other Indicators

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Page 39: The Business Case for Integrated Design Controls

How many product complaints?

How many product changes?

How many product CAPAs?

What about competitor products?

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Page 40: The Business Case for Integrated Design Controls

Concepts to Cover

Design control integration as a competitive advantage

Improved product quality and speed to market

Learning from others and from experience

Aligning design control with the business process

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Page 41: The Business Case for Integrated Design Controls

Questions?

@creoquality @greenlightguru

[email protected]

+1 317 960 4280

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