Medical Device Risk Management – Hazards, Harm, & Causes

One of the most critical roles I play for medical device startup clients is that of educator. And the usual topics for those involved with medical device product development include Design Controls, Risk Management, and Quality Management System. Let me dive a little more into Risk Management with this post. Specifically, I want to help explain hazard, harm, and cause.

First, a few official definitions according to ISO 14971:

  • Harm – physical injury or damage to the health of people, or damage to property or the environment
  • Hazard – potential source of harm
  • Hazardous Situation – circumstance in which people, property, or the environment are exposed to one or more hazard(s)
  • Risk – combination of the probability of occurrence of harm and the severity of that harm
  • Severity – measure of the possible consequences of a hazard

While the definitions seem pretty clear, I can assure you from personal experience the concepts because risk management and how to capture the details can sometimes get confusing. Specifically, I’ve seen time and time again where the concepts of hazard, harm, and cause can get a little muddy.

So maybe thinking about it this way might help:

  • Harm is the potential outcome of a hazard.
  • Severity is the measure of the harm.
  • Cause is what can lead to hazard.

Bootstrapping a Quality System – Advice for Medical Device Startups

Within the past few weeks, we’ve been approached by a few early stage medical device startups requesting assistance. One of the common needs of these potential clients is a FDA / ISO compliant quality system. I’ve been asked to quote a build-from-scratch quality system. I’ve also had to educate a couple others on what a quality system is and why they should even care. I suspect some quality purists would tell these startups that it is absolutely essential to implement a fully compliant quality system ASAP.

I, however, do not agree. Especially for an early stage startup. Why not?

Hiring a resource to draft and implement quality system procedures is overhead. More times than not, the capital spent establishing a FDA / ISO quality system for a very early stage startup is not the best way to spend valuable and usually limited dollars.

Don’t misunderstand me. Yes, a compliant quality system is ABSOLUTELY necessary to have in place prior to going to market. But in the world of medical device startups, this could be a very long time. In the world of medical device startups, very few quality system elements are even meaningful during the fragile product development process.

Instead, I advise my startup friends to bootstrap their quality system. In other words, build the parts and pieces as you go and as you need them. And for a startup, there are likely only a few pieces that essential during medical device product development.

In my opinion, the critical quality system components during development are:

  • Design Control / Design & Development
  • Risk Management
  • Supplier Controls (because most startups rely on a fair amount of outsourcing)
  • Document Control / Record Management

Once the startup approaches the stage of regulatory submissions, additional elements of a quality system become more pertinent. But until then, keep the quality system bare bones. Bootstrap it and build it as you go.

If FDA Knocks, Are You Ready to Answer?

If I look back over the past couple years of business, I notice a common theme from client engagements: address FDA-related non-compliance issues. Sure, maybe this is to be expected since our business focuses on the medical device industry. Regulatory compliance is the name of the game and in our wheelhouse of services and expertise.

But I continue to be a little surprised by some of these engagements and how little the client companies are prepared in case the FDA comes for a visit.

If you are a medical device company (or other company regulated by FDA), you should ALWAYS be prepared for visit from FDA. Technically, FDA is supposed to conduct site inspections of registered companies every couple of years. And if you happen to have product issues, expect the nature of the inspection to be quite a bit more stringent.

What can you do to prepare for a FDA inspection?

  • Conduct internal audits of your processes per Quality System Regulations (which you should be doing any way).
  • Bring in an objective third party at least once a year to thoroughly audit your processes and procedures against FDA regulations.
  • Conduct management reviews annually (and I suggest semi-annually). Be critical of complaint handling, CAPA, supplier management, risk management, document control / record management, and design control processes. Be sure these processes are appropriately linked so that data from one process feeds the others.
  • Be overly conservative in decision-making processes.
  • Consider patient and end-user safety first.
  • Follow your own procedures.

Yes, if your company has adequately defined processes and procedures according to FDA regulations and you follow them, you should always be ready for a FDA inspection.

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October 15, 2010 – PDA All-Day Event

October 15, 2010 All-Day Event hosted by Lilly

Event Description

The October All-Day Event will begin with registration at 8:00 am and end at approximately 4:00 pm. It will include a catered lunch at noon. (AGENDA) The following topics will be discussed: Incoming Bombshell: FDA’s New Process Validation Guidance, Process Validation – Incorporating Quality Design and Risk Management: A Case Study, A Case Study of Process Development for a Lyophilized Vial (Manufacturing Process: Lab Trials, Up-Scaling, Clinical Manufacturing, and Process Validation), A Case Study on Registration and Stability Batches of a Biologic Drug Product, and Current Trends in Process Validation. Click here for details and list of presenters.

Registration will end on Friday, October 8, 2010.

REGISTER INDIVIDUAL

REGISTER MULTIPLE

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September 22, 2010 – Your Medical Device Software May Be at Risk

Complying with the IEC 62304 standard for medical device software requires an established software lifecycle process that includes strong support for risk management and safety assessment. However, IEC 62304 compliance does not need to slow down your medical device software development.

By applying best practices guidance and process automation, medical device companies can reap the benefits:

  • Get through regulatory approvals faster
  • Lower costs
  • Deliver safer devices

Join Dr. David Vogel, founder and president of Intertech Engineering Associates Inc., and Martin Bakal, Market Manager, IBM, at this Webcast to gain a better understanding of this standard and how best of breed tools help tie IEC 62304 into the development process.

Web event: How to Achieve Compliance with IEC 62304 for Medical Device Software Development
Date: September 22, 2010
Time: 10:00 AM PDT
Duration: 60-minutes

Panelists for the Webcast include:

Dr. David Vogel, Founder and President, Intertech Engineering Associates Inc

Martin Bakal, Market Manager, IBM

REGISTER TODAY!

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September 23, 2010 – The Growing Importance of Software in FDA-Regulated Medical Devices

The Growing Importance of Software in FDA-Regulated Medical Devices
How Medical Device Makers Can Meet Safety Requirements, Cut Development
Costs, and Achieve Time to Market Using Off-the-Shelf Solutions

This web seminar series provides a lifecycle view of software safety and the regulation of medical devices by the Food and Drug Administration (FDA). A discussion of the concepts, definitions and important points of the FDA requirements is provided. The medical device development lifecycle is described in the context of FDA regulation and other applicable software safety standards such as IEC 61508 and 62304. The web seminar will also include a discussion of FDA’s enforcement process, including inspections and product recalls, and recent enforcement action relating to medical device software.

The use of Commercial Off The Shelf (COTS) hardware and software is important for medical device manufacturers. Building customer-specific hardware and writing unique software for each device can expensive and inefficient. By leveraging COTS, medical device companies can decrease certification and development time and dedicate more time to product quality and differentiating features. The webinar will explain how Wind River’s COTS solutions and technology platforms can be integrated into safety-critical medical device development processes.

Part 1: Safety First               Sep 23, 2010 – 11:00am PDT
The first webinar introduces the current state of medical software safety and FDA’s increasing interest in software safety.

Part 2: The Regulatory Lifecycle   Oct 20, 2010 – 11:00am PDT
The second webinar goes into more detail on the medical device regulatory lifecycle. Risk management is a guiding principle in software safety, and COTS software solutions are introduced as a way to decrease product development costs and product safety risks.

Part 3: Risk Mitigation              Nov 17, 2010 – 11:00am PDT
The third and final webinar describes what happens when a facility is inspected and how to mitigate the risk of a device recall during the development of the medical device. The focus will be on inspection preparedness, including a review of recent inspections and recalls involving medical device software, and the consequences of not following proper processes and procedures.

SPEAKERS:

  • ALLISON FULTON Associate in the Food and Drug Practice, Sidley Austin, LLP
  • BILL GRAHAM   Product Marketing Manager for VxWorks,    Wind River

MODERATOR:

  • RICHARD NASS Director of Content, Medical Devices Group,Canon Comm. LLP

REGISTER HERE.

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July 27, 2010 – Free Webinar: Redefining Success for Life Science Projects

Free Webinar: Redefining Success for Life Science Projects

Starts: Tuesday July 27, 2010, 01:00PM EDT
Ends: Tuesday July 27, 2010, 02:00PM EDT
Event Type: Training/Seminar
Location: This is a virtual event.
Price:
Website: http://mscholar.com/rpstl
Industry: pharmaceuticals
Keywords: project management, risk management, PMP, CAPM, biotechnology, medical device, life science, pharmaceuticals
Intended For: project managers, project team members
Organization:

How should life science companies define program and project success? How can project managers and teams take targeted action to make their project succeed – on every level? How do we change behaviors to ensure sustainability for the longer term, including the metrics that drive critical decisions affecting the pipeline of projects?

We all know what it means to have a project fail in the traditional sense. But what about the project that has been completed, appears to do well on the surface, but has given no real value to the business? Is it still “successful”?

This webinar will introduce a foundation for redefining project success criteria for pharmaceutical, medical device and biotech companies that balances short- and longer term business needs, and allows project teams to set their project on the path to success from the start. Participants will not only learn how to build their project for the right outcomes, but also what the most important factors are that help us know, along the way, whether those outcomes are still the right ones and still achievable. We’ll explore the role of the team in making success happen, and how to get every team member focused on the right results rather than just completing a set of activities.

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June 23, 2010 – Life Science PM Group: June Meeting

Life Science PM Group: June Meeting

via Life Science Project Management by Steve on 6/2/10

Click here to register

Wednesday, June 23rd, 6:30 pm –9:00 pm
Hosted By
Franklin University of Ohio
8415 Allison Pointe Blvd.
Indianapolis, Indiana

Risk Management In the Life Science Industry
The tools for managing risk in life science projects will be shared. Examples using these tools will also be provided.

This interactive presentation will allow participants to discuss their questions and ideas with professionals facing similar challenges and opportunities. After the presentation, there will be time to network with the speakers, organizers of LSPM, and the other participants.

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April 21-23, 2010 – 30th Annual Medical Communications Conference

30th Annual Medical Communications Conference

April 21-23, 2010 Grand Hyatt Buckhead Atlanta, GA
REGISTER: registermcc@spgmeetings.com
www.medicalcommunicationsconference.com

NAMC Keynote Session:
How Did We Do With the Flu: A Look Back at the Nation’s Response to H1N1 Influenza
Hear how the top immunologists, flu and infectious disease spokespeople think the medical and media communities successfully (or unsuccessfully) dealt with a major national health issue.

Health Communication Achievement Award
Bruce Bonanno, MD President, National Association of Medical Communicators will present Andrew P. Ordon, MD, FACS NAMC’s Annual Health Communication Achievement Award.

Special Session: Health Reform — How Visible National Medical Organizations will Engage its Members

Moderator:

John Hockenberry

Money in Medicine, Sin or Salvation
The free market, which includes most practicing physicians, publicly supported biomedical researchers, and private drug and device companies, has succeeded spectacularly in delivering new medical technologies to the public. Increased interactions between doctors (physicians and biomedical researchers), epitomized by the founding of the biotechnology revolution, have and can continue to accelerate this delivery.

Incorporating Traditional Marketing Theories and Science Based Strategies to Prevention, Health Promotion and Health Protection to Create, Communicate and Deliver Health Information.
In eHealth marketing, we work to develop and market the CDC.gov Web site and interactive media projects to increase the impact of CDC science. Our vision is that people in the United States and throughout the world will live significantly longer, healthier and safer lives as a result of their regular ongoing experiences with interactive, electronic health information and interventions from CDC and the Department of Health and Human Services.

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Medical Device Risk Management Is An Enterprise-Wide Effort

I just read a blog post from AssurX “Risk Management Matures Beyond The Spreadsheet”. Great post–you should read it if you are developing and/or manufacturing a medical device. Here is an excerpt:

In conclusion, managing risk across the corporation means something different to each department yet it requires the entire organization to work together. It involves documenting and sharing risk data across the enterprise, managing workflows and tasks, while handling escalation and reporting. Yes, risk management has matured beyond the spreadsheet.

I definitely agree. I’ve written a few blog posts over the years on risk management:

What surprised me ten years ago about medical device risk management still surprises me today. Very few companies consider risk management as an enterprise-wide effort. Many companies pay lip-service to this but fail to practice it. I’m also shocked by how many companies think that:

Failure Modes Effects Analysis (FMEA) = Risk Management

It doesn’t.

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reBlog: FDA Aims To Improve Product Risk Communication Under Strategic Plan

From Medical Devices Today:

Under a plan unveiled Sept. 30, FDA aims to increase its understanding of appropriate ways to communicate with the public about product risks and to streamline its product risk communication processes.

The agency’s Strategic Plan for Risk Communication lays out dozens of planned actions intended to improve FDA communication strategies, with a focus on 14 over the next year (The Gray Sheet’ Sept. 28, 2009).

Among FDA’s goals for the next 12 months: publish an agenda for researching the best modes of public communication; design surveys to assess public understanding of, and satisfaction with, FDA communications; and create an internal database of relevant risk communication research. The agency also says it will develop template press releases to announce regularly occurring events like recalls and will start posting pictures of products affected by higher-risk recalls on the Web.

Read more

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