Tag: FDA 483

Impact of QMS on Quality Maturity

Posted on by Brandon Miller

In an interview with Pharmaceutical Technology®, Susan Schniepp, distinguished fellow, Regulatory Compliance Associates®, and co-chair of board of directors, Parenteral Drug Association, expands on the importance of maintaining a robust quality management system (QMS) in bio/pharmaceutical manufacturing. 

 

For advanced therapy medicinal products (ATMPs) in particular, Schniepp emphasizes how fast-moving this sector is. “The regulations don’t keep up with the ATMPs. That technology, and their way of thinking, is turning over quicker than the regulatory standards,” she says.

 

Follow the link to watch the free video here

 

“The changes in the regulations that are going to come are going to be around quality culture and maintaining a robust quality management system,” she adds. Ensuring documentation and keeping equipment calibrated are important practices to apply to these new fast-moving ATMPs, she states. Schniepp does not necessarily expect to see many changes in the regulations around ATMP development and manufacturing but thinks that there will likely be more guidance documents issued in the future, with one of FDA’s focuses being its quality management maturity model.

 

“There are some regulations out there that call out quality culture. In particular, the World Health Organization has one on data integrity. It has a definition and standard[s] on what quality culture is,” Schniepp says. She points out that a new aspect of her presentation at INTERPHEX this year is its interactive component, in which she sets up a scenario involving an internal audit where an incident occurs. She gives the audience three potential responses to discuss, but rather than simply asking them which response do they pick or which response is correct, she instead asks what does the chosen response say about that person or that company’s QMS and the maturity of that system?

 

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Artificial Intelligence in Medical Devices

Posted on by Brandon Miller

Measuring the impact of the FDA’s Regulation Proposal

 

With recent developments in technology, we have seen artificial intelligence and machine learning more commonly used across all aspects of our lives. Whether it’s our phones or smart speakers, this dynamic technology has applications in all industries, including the medical device industry. To ensure AI in medical devices can evolve while still protecting patient well-being and safety, the FDA recently released new information about its plan to regulate developments.

 

Looking to Implement AI into your Medical Device? Contact Us Now →

 

Artificial Intelligence vs. Machine Learning

 

Artificial intelligence and machine learning are two similar terms people commonly use interchangeably when discussing this type of software or technology, but they actually mean different things.

 

Artificial intelligence refers to any kind of technology deemed to be “intelligent,” or capable of understanding new data and adapting its functions accordingly. Machine learning refers — not to the device or software itself — but rather to the method scientists use to “teach” software to adapt to new information through learning and updating stages. Usually, machine learning is applied in the form of decision trees, where a certain action will always lead to a certain response and each action after follows a set path.

 

Researchers are now using machine learning to improve the efficiency of AI in medical devices. Practitioners often use different kinds of software to help them examine and treat patients, and AI as a part of medical device software is growing a little more every day. Machine learning allows AI devices to monitor patients, improve medical imaging software and even the potential to deliver certain treatments to patients.

 

However, AI doesn’t learn the same way humans do. AI software and algorithms are taught to adapt based on statistics and patterns they gather from experience. This capability means AI medical devices have the potential to develop very quickly as they receive and analyze risk management data in real-time and in real-life applications.

 

FDA Concerns About Artificial Intelligence in Medical Devices

 

There are two main types of technological algorithms:

 

  • Locked algorithms: only understand information and analyze it based on the way they were programmed. If you ask a locked algorithm a question or input certain data, it will always offer the same solution or result.
  • Adaptive algorithms: can respond and recognize new patterns or opportunities as it receives new data, and adjust it’s process or response accordingly.

 

Adaptive algorithms in medicine are currently causing the FDA the most concern. When companies that create software or medical devices give AI-based programs or products the freedom to examine or help treat patients by allowing them to respond to real-world situations and data, they have less control over what the AI learns and how it uses that information to adapt. If left unchecked or under-regulated, this could pose the possibility of changes developing that could create patient risk.

 

The FDA is currently working to develop a framework that will allow for the safe use of ever-adapting AI in the hospital setting. To make sure patients stay protected, FDA representatives have indicated that if an AI medical device is approved, it would have to be monitored constantly for changes in its algorithm. Making sure all the information the AI absorbs and analyzes stays transparent and malleable is crucial for maintaining a secure healthcare practice.

 

Challenges of Implementing AI Medical Devices

 

Another concern that artificial intelligence medical devices FDA regulations will address is helping AI respond better to individual patients. Unfortunately, there is no one-size-fits-all approach. Some illnesses or conditions may affect people differently.

 

This means some situations might confuse an AI machine or cause it to not analyze things properly. Researchers and the FDA must account for such gray areas and variables that could cause an AI device to malfunction or compromise the safety of patients. Programming an AI algorithm to understand cause and effect or to strategize using a decision tree can’t account for all potential factors.

 

The Future of AI in Medical Devices

 

The FDA is working to develop appropriate regulations for the use of Software as a Medical Device. Products that are driven by AI software or processes fall under this category, but given their unique ability to adapt to new data, they likely require separate scrutiny. As AI continues to evolve in the coming years, the FDA will have to keep a close watch on its applications and uses in the medical field to ensure patient protection.

 

About RCA’s Medical Device Consulting Services

 

The regulatory compliance process surrounding the medical device industry involves a strict adherence to pre/post market information throughout a device’s life cycle. Even a single compliance issue you have can turn into a significant effect on your business. Regulatory Compliance Associates can help guide you through any stage of the medical device consulting process, with capabilities during product development through the regulatory clearance/approval of your product.

 

Our team of over 500 medical device consulting Experts — including former FDA officials and regulatory compliance leaders in the field of medical device regulation — will work with your company to create a quality assurance and regulatory compliance approach tailored to your products and regulatory needs. Regulatory Compliance Associates works with international Fortune 100 companies, venture capital start ups, and companies of all sizes and shapes. our compliance enforcement solutions for law firms include remediation for warning letters, FDA 483’s, import bans or consent decrees. Very few regulatory compliance services have the same regulatory compliance expertise in a variety of medical fields.

 

Cybersecurity

 

For medical device manufacturers, technology can be a double-edged sword. The innovative technologies that elevate the quality of life for patients can also be used to potentially undermine the organization using the device. The consequences can affect the device itself if Regulatory Compliance Associates medtech consultants do not implement good IoT cybersecurity and FDA cybersecurity protocols.

 

At Regulatory Compliance Associates, we offer a wide variety of services for medical devices security to help ensure that your product is protected from cyber-attacks. With a well-planned design, along with full visibility of product development and the supply chain, Regulatory Compliance Associates medical device consultant Experts can help strengthen your device’s cybersecurity. We partner with medical device companies in each phase of the design cycle, including protecting inputs from threat exposure and hardening outputs for regulatory compliance & FDA submission approval of your medical technology.

 

  • SaMD Consulting
  • Threat Modeling
  • Proof of Concept
  • Quality Assurance Services
  • TIR 57 & TIR 97
  • ISO 62304
  • ISO 27001

 

Regulatory Affairs

 

Regulatory affairs is Regulatory Compliance Associates® backbone, and we handle more submissions in a month than many manufacturers do in a lifetime. Our regulatory compliance consulting Experts have experience working with the FDA, global regulatory bodies and / or agencies, and notified bodies worldwide. Therefore, you can count on us for in-depth and up-to-date insights which increase speed-to-market.

 

As a trusted regulatory affairs consultant, our FDA veterans and industry experts represent Regulatory Compliance Associates® as one of the top medical device consulting firms. We’re here to help you navigate the difficulties associated with new product submissions. Regulatory Compliance Associates® medical device consulting company has expertise in both the approval process and post-approval support. 

 

  • New Product Approval
  • Post-Approval Support
  • Outsourced Staffing
  • EU MDR
  • Combination Products

 

Compliance Assurance

 

Increasingly, life science companies are feeling the pressure of greater scrutiny by regulators, and responding by developing sustainable compliance strategies. Whether it’s preparing for an audit, developing a response to an FDA finding, or remediation to an adverse event, Regulatory Compliance Associates® can help.

 

Our network of over 500 medical device consultant & FDA, MHRA & EMA veterans are industry professionals offers a unique blend of expertise. This allows Regulatory Compliance Associates® to handle both simple and complex regulatory compliance challenges within medical device consulting companies.

 

  • Gap Assessments
  • Internal Audits
  • Employee Training
  • Notified Body Response
  • Data Integrity

 

Quality Assurance

 

Regulatory Compliance Associates® Quality Assurance consulting includes quality system assessments, strategy, implementations, and identification of quality metrics to ensure continuous improvement, aligning with your business needs and goals. Each Regulatory Compliance Associates® medical device consultant is a quality expert with experience spanning major corporations and start-ups. We know firsthand how to achieve, maintain, and improve quality, and we excel in transferring this knowledge to your organization.

 

In the medical devices field, quality assurance (QA) is more than merely ensuring the quality of a finished product. You need the tools to monitor and regulate every process from the design of a new product to continued quality compliance as the device is sent to market. At Regulatory Compliance Associates®, we offer you the quality assurance services you need to monitor these processes and ensure quality compliance every step of the way.

 

With more than 20 years experience working with medical device consulting companies, Regulatory Compliance Associates® trusted medical device quality assurance consultant team is fully equipped to handle your unique QA needs.

 

  • ISO13485 
  • 21 CFR 210
  • 21 CFR 211
  • Outsourced Staffing
  • MDSAP
  • Facility Validation
  • Equipment Validation
  • Quality Metrics

 

Remediation Services

 

Regulatory Compliance Associates® is widely recognized within medical device consulting companies & the life science industry for our remediation services & support. Regulatory Compliance Associates® ability to help companies successfully resolve complex regulatory challenges have a proven track record of success. Our medical device consulting services include significant experience with the development of responses to 483 Observations, Warning Letters, Untitled Letters and Consent Decrees.

 

  • Regulatory Action
  • Regulatory Compliance
  • Regulatory Enforcement
  • Warning Letter
  • 483 Observation
  • Oversight Services

 

Our value goes beyond the initial response by helping companies successfully execute their action plans, develop an improved compliance culture tailored to the needs of their business, and ultimately move beyond the regulatory action to emerge as a stronger business. We negotiate difficult demands of remediation with insight and the clear advantage of our medical device consultant expertise and experience that makes partnering with Regulatory Compliance Associates®  a competitive differentiator in the remediation space.

 

  • Quality System
  • Technical File
  • Design History File
  • Data Integrity
  • cGMP

 

Strategic Consulting

 

Whether it’s a strategy, a technical plan, or project, Regulatory Compliance Associates® medical device consultancy can help ensure a successful project. Regulatory Compliance Associates® medical device strategy consulting can deliver your project on time, on budget, and you’re never embroiled in a costly mistake.

 

Our medical device consultant Experts are industry Experts are here to provide the unique insight you need before an M&A deal, through a staffing crisis and in every area of your product’s development and life cycle. As the trusted medical device manufacturing consultants of thousands of companies around the world, we have the knowledge and expertise needed to deliver exceptional results to your business — no matter your size or unique needs.

 

  • Manufacturing Optimization
  • Product Lifecycle Management
  • Mergers & Acquisitions (M&A)
  • Due Diligence
  • Device Vigilance
  • Risk Management Plan
  • Product Complaints
  • Medical Information

 

About Regulatory Compliance Associates

 

artificial intelligenceRegulatory Compliance Associates® (RCA) provides medical device consulting to the following industries for resolution of life science challenges:

 

 

We understand the complexities of running a life science business and possess areas of expertise that include every facet of R&D, operations, regulatory affairs, quality, and manufacturing. We are used to working on the front lines and thriving in the scrutiny of FDA, Health Canada, MHRA and globally-regulated companies.

 

As your partners, we can negotiate the potential minefield of regulatory compliance and regulatory due diligence with insight, hindsight, and the clear advantage of our unique expertise and experience.

 

  • Founded in 2000
  • Headquartered in Wisconsin (USA)
  • Expertise backed by over 500 industry subject matter experts
  • Acquired by Sotera Health in 2021

 

About Sotera Health

 

The name Sotera Health was inspired by Soteria, the Greek goddess of safety, and reflects the Company’s unwavering commitment to its mission, Safeguarding Global Health®.

 

Sotera Health Company, along with its three best-in-class businesses – Sterigenics®, Nordion® and Nelson Labs®, is a leading global provider of mission-critical end-to-end sterilization solutions and lab testing and advisory services for the healthcare industry. With a combined tenure across our businesses of nearly 200 years and our industry-recognized scientific and technological expertise, we help to ensure the safety of over 190 million patients and healthcare practitioners around the world every year.

 

We are a trusted partner to more than 5,800 customers in over 50 countries, including 40 of the top 50 medical device companies and 8 of the top 10 pharmaceutical companies.

 

Commitment to Quality

 

Our Certificate of Registration demonstrates that our Quality Management System meets the requirements of ISO 9001:2015, an internationally recognized standard of quality.

 

To begin the Regulatory Compliance Associates® scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. 

 

Postmarket Surveillance: Leveraging Outsourcing

Posted on by Brandon Miller

Companies within the life sciences industry have been increasing their use of third parties to manage postmarket surveillance activities in recent years. If you are thinking about outsourcing some of your company’s more time-consuming tasks, it’s important to keep in mind that there are both advantages and disadvantages to this method.

 

Interested in Outsourcing your Postmarket Surveillance activities? Contact RCA Now →

 

Below, we will discuss some of the pros and cons of outsourcing so that you have the knowledge to make the right choice for your business.

 

Pros

 

  • Reduced costs: Outsourcing your post market surveillance activities will improve upon your overall business functions, thereby reducing operating costs and increasing profits. You can use those savings to foster growth for your company.
  • Leveraging resources: While cost is one of the main benefits to outsourcing quality assurance, the advantages offer so much more. For example, you can use the time and effort you save on post market surveillance to leverage your talent and resources on other high-value tasks. By delegating less complex work to a team of compliance experts, you can make the most of your valuable employees with riskier responsibilities.
  • Taking advantage of core competencies: What are your team members’ strengths in relation to your customers’ needs? This question will weigh heavily in your decision to outsource, especially if your internal resources lack the qualifications necessary to handle regulatory affairs. Outsourcing allows you to focus on your own core competencies while using a third party’s core competencies to increase productivity.
  • Improved speed and efficiency: If a task falls outside your core competency, it will take longer to complete it, with a greater risk for error. However, outsourcing to an expert speeds up your processes and helps create a more efficient work process for all parties involved.

 

Cons

 

  • Less direct control: When you outsource business processes, you release direct control you might otherwise have over those processes. It’s important to keep this in mind if you know that a mistake or failure of a task could have serious implications on the business.
  • Pressure on supplier management control: Outsourcing places pressure on your supplier management controls, which could result in losses for your company if poorly handled. As a result, you will need to establish a co-governance plan that allows you to retain some control.
  • Quality of the process: Potential negative impact on quality of the process outcome or services and its impact on profitability and customer satisfaction.

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. 

 

DHF & Design Controls

Posted on by Brandon Miller

 

When you scale your Design Controls appropriately to the complexity and size of your company, it makes it easier to manage the scope of everyday work needed to keep your files current. Things to remember when scaling your Design History Files (DHF):

 

  • One size does not fit all
  • All classes of devices need design controls
  • The process is scaled based on the complexity of the device and the size of the company
  • Don’t wait for the regulators to identify any gaps

 

Also, identifying your gaps up front, closing them upon identification, then wrapping them into your entire DHF process with your team or with a third-party consultant like RCA helps ensure you have a rock-solid DHF and that you will be prepared when the regulators ask questions.

 

Click to listen to RCA’s full DHF & Design Control podcast Here!

 

FDA Design Control

 

RCA offers medical device consultants who will help you navigate through new product development and remediating legacy Design History Files (DHF). Our life science consultants have a thorough understanding of the specific design history requirements for U.S. and international medical device industries. We’ll support your team’s ability to ensure regulatory compliance and accelerate medical device DHF best practices.

 

In addition to DHF content, development, and management, download our handout to view more of our DHF-related support services, including:

 

  • FDA design control requirements
    • Quality System Regulation, 21 CFR Part 820
    • Design control medical device CGMPs and 21 CFR 820.30
    • Device Master Records (DMR)
    • Device History Record (DHR)
  • ISO 13485 design control
    • Design control procedures
    • Design control process evaluation
    • Design control documents
    • Design quality control
  • The EU’s Medical Device Regulations (MDR) including Technical File / Design Dossier
  • Risk management (ISO 14971) for medical devices including risk analysis, FMEA, risk evaluation, and risk controls through Corrective and Preventive Action (CAPA) plan and design control requirements
  • IEC 60601-1-11 (2010) including Programmable Electrical Medical Systems (PEMS) (Clause 14)
  • Total product life cycle (TPLC)
  • AAMI design control

 

 

 

To begin the Regulatory Compliance Associates® scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. 

Crisis Management Playbook

Posted on by Brandon Miller

crisis management playbookDeveloping a crisis management playbook designed for the challenges of the pharmaceutical industry sector is vital to ensuring long term business continuity. Below are a few critical risk management elements you should consider for your team during crisis handling & developing a crisis management playbook.

 

Risk Management

 

Being able to identify factors that impacted product safety or regulatory compliance is one of the most important elements during the risk assessment phase. During RCA’s risk management services process, operational risk management is one of the first remediation steps to consider.

 

Identify Risk

 

Being able to identify the product hazards that caused the crisis is critical to understand scenario planning. Conduct due diligence to ensure that your product design outputs include no risks that are unnecessary to the consumer. Hazards that do include one or more risk factors must be analyzed why the patient benefit exceeds the financial risk.

 

Measure Risk

 

During scenario planning, identify the critical elements to measure your team and results by via a risk management framework. A risk profile for each product in question can support evaluating, reporting and monitoring adverse events. Systemic risk should be analyzed for product risk profiles with longer term, reoccurring events or specific pharmacovigilance indicators identified as proactive crisis control.

 

Mitigate Risk

 

Being able to work clearly and concisely with your regulatory agency is critical for the due diligence solutions presented for review. Examining all hazards that have been identified during the risk mitigation phase is essential to success during the risk management process. Consider any of the threats that are regarded as acceptable with known risks and document unusual activity in your risk management plan.

 

Crisis Management Communications

 

An initial step recommended by RCA’s medical device consulting team is to identify and evaluate the regulatory compliance dangers and situations. For example, assessing the vulnerability of medical device cybersecurity must consider internal and external threat modeling. Any type of cyber breach that might impact your operations team, business reputation, or stakeholder relationships should have a detailed communication strategy.

 

Crisis Communication Plans

 

A veteran RCA medical device consultant suggests developing a universal shared space where team members can bookmark & access the crisis comms document. A communication strategy would then be shared with communication partners engaged in the public relations and crisis management campaign.

 

Risk Management Communications

 

Inside a successful crisis communication team, everyone knows their role and responsibilities. RCA’s regulatory consulting Experts often designate a process leader who clearly understands the team stakeholders and functions they represent. Refine your approval process so that messaging not only meets external approved communications from these stakeholders, but also legal concerns.

 

Crisis Control

 

A detailed risk management communication plan helps specify different examples for sharing risk messaging to either internal audiences or external stakeholders. Design your communication plan templates so that information is easy to understand for multiple audiences. Different types of tactics to be considered for templates (e.g. press release, social media) to confirm the messaging reliability of the crisis communication strategy.

 

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

GMP Inspection

Posted on by Brandon Miller

GMP inspectionHealth Canada, Therapeutic Goods Administration (TGA), and Medicines & Healthcare Regulatory Agency (MHRA) recently launched an innovative, new pilot focused on Good Manufacturing Practices (GMP). The Single Inspection Program is designed to help rationalize the number of inspections needed to increase efficiency during the regulatory process.

 

A primary objective is to maintain regulatory standards by eliminating redundancies and providing a more “global approach to GMP inspections of third-country manufacturers”. Additionally, the program design is intended to increase existing collaborative GMP arrangements to allow for:

 

  • More efficient inspection reliance processes
  • Reduced regulatory burden on healthcare industry
  • Enhanced regulatory oversight of global supply chains

 

Regulatory Authorities

 

In a proactive step toward harmonization, the three regulatory bodies will begin accepting a single inspection for a Canadian, Australian and British regulatory application (based on the drug establishment license, or DEL). The long-term strategy includes leveraging the inspection assets of each regulatory authority to collectively collaborate when additional data is available.

 

Additionally, by maximizing the global regulatory reach of multiple agencies, the pharmaceutical industry will benefit from fewer inspections needed at the same site or manufacturing facility. This should increase both the speed of the regulatory process and patient access to medical products. Both are a win-win for the life science industry as the regulatory process becomes more streamlined than previously experienced.

 

GMP Practices

 

All three regulatory bodies are members of the Pharmaceutical Inspection Co-operation Scheme (PIC/S). PIC/S is an international, non-binding cooperative between Regulatory Authorities in the field of Good Manufacturing Practice (GMP). Additionally, PIC/S membership is focused on companies that develop medicinal products for human or veterinary use, and over 50 countries from around the world currently participate. 

 

Finally, the mission of the current membership is to lead the “development, implementation, and maintenance of harmonized GMP standards and quality systems”. A more efficient inspection process will allow drug manufacturers to reduce any type of disruption to operations that multiple audits may induce. 

 

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage.