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E-Health Services: The New Boon

E-Health services and wireless, wearable devices are spawning new products regularly. Last year monitoring devices grossed $2.9 million and is expected to grow to $17.1 million over the next five years. There is increasing demand for expanding the old point of care paradigm from the traditional hospital/doctor’s office setting to a more mobile medical environment. With this expansion, come new challenges with compatibility, wireless performance, security and compliance with the somewhat fledgling regulations.

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Recalling the Difference

Last year the FDA issued a draft guidance to clarify the difference between a recall and a product enhancement. Only voluntary recalls are in scope and whether they are performed by the manufacturer or at the request of the FDA is irrelevant. The difference is important as a recall requires the submission of a correction and removal report to the FDA. These reports become part of public record and thus may not put the company in a positive light. What may be considered recalls can include updates to instructions or changes to components or labeling.

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Choosing a Contract Manufacturer- It's All in the Family

With increased scrutiny on the supply chain and rising complexities, finding a dependable manufacturing partner is critical. Outsourcing to a contract manufacturer may seem like an easy thing to do if your company does not have the expertise, equipment or capacity to manufacture a product. You turn to a distant family member to fill in the gaps and move on to something else. However, if not sufficiently evaluated or controlled, the solution becomes the crazy aunt you wish would go away. Ultimately, the sponsor company is accountable to ensure that the contract manufacturer is compliant with cGMP and applicable Quality System Regulations.

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Device Design Transfer - A Smooth Hand-off

Getting a new product into the customers hands as quickly as possible is critical to medical device manufacturers. Perhaps during the rush to hand off a product to the manufacturing floor, corners are cut. The end result can be manufacturing delays that prevent the product from going out the door - or even defective product reaching the customer.

Paying attention to the details up-front can save time in the long run. Resolving issues early in the process lends itself to a seamless transfer in house or to a contract manufacturer.

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Not Obstructing the FDA - Be Reasonable

A little over a year ago, the FDA issued a draft guidance document (Circumstances that Constitute Delaying, Denying, Limiting, or Refusing a Drug Inspection) regarding the types of actions that would be considered to obstruct an FDA inspection and potentially lead to a supposition of adulteration. Last month, the final guidance was issued. The document attempts to define what behaviors are considered to mean an intentional delay or refusal. The FDA has the authority to enter any facility under the jurisdiction of the FD&C Act at reasonable times and conduct inspections.

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MDR Perils –Avoiding Entanglement

The purpose of MDR reporting is to provide a means to collect data that may indicate the presence of a safety problem. MDR reporting can be confusing and it is certainly an area where mistakes are abundant. Some mistakes however will garner more scrutiny from the FDA. In extreme instances incorrect reporting or lack of appropriate reporting can lead to criminal charges.

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Building a Culture of Quality- More Than Words Can Say

When questioned if their company has a focus on quality, most managers and employees will say yes. This might be because at a minimum, it is the right thing to say. They may also believe that since they have some procedures or a quality policy that this suffices and that quality practices will just fall in to line. Under further scrutiny, however the differences between perception and reality become apparent.

The view from higher levels in the company may be that it has a well disseminated quality culture. But as you travel down the organization chart, the response may not be so positive. A culture of quality is a full time commitment to quality. It is not just referencing standards in a few SOPs. Everyone should understand who the customer is and what they expect.

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Medical Device Reporting - Getting it Right

The goal of each medical device manufacturer is to produce safe and effective products. These manufacturers are responsible for carrying out postmarket surveillance activities to monitor and collect the performance of their products. In the current regulatory environment, companies are under scrutiny for their complaint procedures and their ability to react and respond.

The FDA annually receives hundreds of thousands of medical device reports of serious harm, deaths or malfunctions. These are not only from the manufacturers but also the end users. The regulation provides a means for the FDA to monitor significant issues regarding medical devices.

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Risk Management for Life

The risk device companies assume is great. This requires a comprehensive planned approach. A policy on paper is not enough. It must be inherent in the day to day activities throughout the organization. Risk is constantly assessed and appropriate and timely decisions made. The goal is a reasonable assurance of safety and effectiveness of the product. In the simplest terms risk management results in the following:

  • Identifies hazards
  • Evaluates /estimates risk
  • Determines risk acceptability
  • Controls risks 
Risk can take many forms. Certainly, the most concerning is the risk to the patient but risk to an operator or employee must also be considered. There are regulatory and legal considerations and finally, there are issues that propose a business risk. Continue reading "Risk Management for Life"

Excellence By Design

A high quality product is the goal of most Life Sciences companies. Quality by design is touted in many industries. If you build it correctly from the very beginning, there will be fewer problems once the product is in a customer’s hands. To this end, a managed process for developing a product is employed. This contains interrelated procedures that make the core of the development process. Design controls make discrepancies more evident and ensure that once the product is transferred to production it will consistently meet requirements.

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