Adhering to a robust design and development process results in a quality medical device that is safe and effective. This installment examines general requirements, and design and development planning of Design Control.
Adhering to a robust design and development process results in a quality medical device that is safe and effective. This installment examines general requirements, and design and development planning of Design Control.
The FDA’s requirements for personnel are delineated within Section 820.25. In fact, Section 820.25 appears to be one of the more innocuous requirements and in the opinion of Dr. D, one of the most important. Can you say training, training, and more training? Regardless, compliance to the requirement is mandated by the regulation. That said, Dr. D would probably suffer from some compunction if I failed to cover all aspects of the regulations as part of this current series. As always, my goal is to enligh…
The Food and Drug Administration (FDA) will evaluate the effectiveness of your internal quality audits and review the corrective actions pursued as part of the overall quality audit system. If a nefarious approach to executing quality audits is pursued, the reward will be a Form 483. If the FDA feels the violation is egregious, a warning letter will be forthcoming. In monopoly speak, “do not pass go and do not collect your two hundred dollars.” Warning letter violations As you can see by the abundance o…
I begin this edition of Devine Guidance (DG) by reinforcing the importance of DG Rule #1 – Compliance to regulations is not optional, compliance is mandatory and dictated by law. In my belief, management responsibility is what the doctor likes to call the “catch-all requirement.” What does that mean Dr. D? Simply put, if your organization fails to comply with any part of the QSR, rest assured, the reward will be in the form of a Form 483 for the specific transgression, by the agency. Additionally,…
If a supplier scored well on their original selection assessment, or scores well on repeat maintenance assessments—say, a score of 90 percent or above for argumentative sake—and your organization is receiving 100 percent conforming product (yes, imagine a perfect world), what is the value of performing an annual or regularly scheduled maintenance assessment? Dr. D does not see any upside. Now I could write a philippic (yep, look up time again) that takes medical device organizations to task in regards t…
Welcome back to this sixth installment of Devine Guidance . I am not one to assume a Panglossian view (time to pull out the dictionary again) when dealing with problem suppliers and the need to pursue corrective action. However, at times the ugly SCAR becomes unavoidable. In fact, evidence of effective corrective action, as it pertains to suppliers is a requirement and the FDA, notified bodies, and other regulatory bodies will verify the effectiveness of the approach pursued by your organization. Additi…
Since the concept of writing a weekly blog and actually having a following is somewhat foreign to me, I was not sure what to expect or the reception I would receive writing a weekly column. So far, the support and responses have been overwhelmingly positive; and for that, I would personally like to thank the readers. Additionally, I will continue to write about and provide relevant information associated with supplier quality (four installments remaining) and will eventually begin addressing quality and…
If you are a returning visitor, welcome back to this 4th installment of Devine Guidance. If this is your first time, I hope you have a chance to read the first-three installments of my blog. In this installment, I will continue with the defensive-receiving inspection theme, a process that I feel “has limited-value.” That said,…
To those who have decided to return for another episode of Devine Guidance , thank you! Once again, I hope you find some reading enjoyment and value in this third installment. For this adventure, I plan to dive into the importance of a clear and concise specification to support the design, development, and procurement processes.
To my colleagues who have decided to rejoin me for an ongoing exploration into the trials and tribulations of effective supplier management for the medical device industry, thank you for returning. I hope you will be able to glean some useful information from the compilation of current industry practices, concepts extracted from my doctoral dissertation, and an overall common-sense approach to supplier quality. It is my personal belief that pursing the ideas presented within this paper, and scheduled to…
