Medical Device Risk Management James Pink Requirements  The medical device industry is highly regulated and based upon a device specific risk rating for dealing.

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Transcript Medical Device Risk Management James Pink Requirements  The medical device industry is highly regulated and based upon a device specific risk rating for dealing.

Medical Device
Risk Management
James Pink
Requirements
 The medical device industry is highly
regulated and based upon a device
specific risk rating for dealing with the
level of regulation to be applied prior to
market acceptance
 All modern medical device regulations cite
ISO14971:2007 as being the standard to
apply for medical devices
Global Harmonisation requirements
 GHTF safety and performance
requirements require risk management to
be used as a basis of identifying,
evaluating, controlling and continuously
monitoring the effectiveness of risk
controls.
The need for risk management
Source GHTF Study Group 1
4
The need for risk management
Source GHTF Study Group 1
5
The need for risk management
6
Does it mean anything to me as
adrug manufacturer
 If you have a drug delivered by means of
a combination product then you are
required to ensure that the device meets
all safety and performance criteria of
medical device regulations. As a result you
are required to ensure that devices for
drug-device combinations are being
designed, manufactured, supplied and
used in a way that all risks are controlled
and the risks are outweighed by the
clinical benefit.
The need for risk management
8
Risk management process
 ISO14971:2007 requirements
9
Risk Management Organisation
•Failures in Test
•Technology limitations
•User feedback including
failures and hazards
•Summarise
knowledge with
respect to risks
Proof of
concept
10
Design
Planning
•Clinical literature
Review
•Standards
•Competitor products
• Create Risk
Management Plan
•Simulations and
Validations
•Testing results
•Supplier Part approvals
•Bench Testing
•Clinical investigations
•Risk Management
Reviews
Designing
Design
Transfer
•Process
Validation data
•Supplier
qualification data
•Manufactured
variance analysis
•Process FMEA
•Risk Controls
and Transfer
to Validation,
Complaints,
Vigilance,
Change control
and Supply
chain
•Clinical follow-up
trends
•Published articles
•Complaints
investigations
•Usability trends
•Survivorship
•Other PMS
analysis
•New Risks,
Frequencies
and severities
Clinical
Validation
Risk management process
Input
Output
New Product development
New Process introduction
Change to Product
Change to process
Significant Change
Adverse Incident trends
Adverse Manufacture trends
New markets / users
PMS Trends
CAPA Trends
Risk Management controls
Management Review analysis
Adverse trends awareness
Manufacturing limits & Controls
Supplier limits & Controls
Surgeon Training points
Post Market Clinical Follow-up
Complaints investigator training
Change control team awareness
CAPA investigator awareness
Resources
Meetings, Measures and actions
Risk Management Team
Risk Management experts
Risk Management database
Customers and Clinical leads
PMS Meetings
Product Review meetings
Supplier Meetings
Change control meetings
Intra project Risk Analysis meetings
Risk Management review meetings
Management Review meeting
Surgeon / User feedback
Clinical Evaluation updates
New Standards, risks and controls
Records
Risk Management Plans
Risk Management FMEA’s
Risk Management Reports
11
Activity
Risk management process
Example
Complaints
Analysis
New Product
Development
Change
Control
Risk
Management
Clinical
Evaluation
Validation
CAPA
A new product
development project is
initiated. The process
requires a plan, defines the
information sources and
identifies how clinical
benefit will be derived from
customers.
Risk reviews, tools and
methods are all defined
including the forms,
procedures and records
required
A Final report is written
defining residual risks,
controls and clinical benefit
12
Risk management process
Example
Complaints
Analysis
New Product
Development
Change
Control
Risk
Management
Clinical
Evaluation
Validation
CAPA
13
A change in Valve supplier
is proposed for the MDI.
The process defines what
will happen, how the
change is categorised
based upon importance
and defines the level of
process risk management,
controls and reviews
necessary.
Risk reviews, tools and
methods are all defined
including the forms,
procedures and records
required
Risk Management - Acceptability
 ISO14971:2007 requirements
THIS HAS TO COME FROM A JOINT REVIEW WITH YOU AND YOUR
SUPPLIER
14
Probability
5
4
3
2
1
=
=
=
=
=
<1 in 100
1 in 100
1 in 1000
1 in 10,000
>1 in 100,000
Based upon Surgical
procedures
15
Increasing probability of occurrence of Harm
Risk management acceptability
Severity
5
4
3
2
1
Increasing severity of Harm
=
=
=
=
=
Death
Revision / irreversible
Reversible injury
Minor Injury
Inconvenience
Probability
5
4
3
2
1
=
=
=
=
=
<1 in 100
1 in 100
1 in 1000
1 in 10,000
>1 in 100,000
Based upon Surgical
procedures
16
Increasing probability of occurrence of Harm
Risk management acceptability
Severity
5
4
3
2
1
Increasing severity of Harm
Device fails to deliver appropriate uniform dose over time
=
=
=
=
=
Critical to safety
Critical to function
Customer Image
Upset the customer
Inconvenience
Risk management acceptability
17
Risk management acceptability
18
Risk management acceptability
19
Risk management acceptability
20
Risk management acceptability
21
Risk management acceptability
22
Risk management acceptability
Tips
Ensure that you are focussed on the current state of the art with
relation to drug - device performance
Ensure that you are able to define hazardous situations based upon
the major associated failures
Be aware that the level of acceptability will be based around your
critical to safety and quality requirements. The final clinical harm
will be required so that contract design suppliers and manufacturers
are aware of the severity of failure.
23
Risk management plans
 ISO14971:2007 requirements
24
Risk management plans
Lifecycle phases
Design and
Development
Concept
and
Definition
Transfer to
Manufacture
and limited
market
placement
Post Market
If a drug manufacturer uses a device they must develop risk management
plans that will ensure all elements of risk are covered from design through to
manufacture
25
Risk management plans
Step
Step
Step
Step
Step
Step
Hazardous
Situation
Valve affects
Dose plume
26
Hazard
Mechanical fatigue
Harm
Too much drug
1
2
3
4
5
6
-
Undertake literature review
Review previous designs
Undertake Design Verification
Undertake Design Validation
Assign probability value
Include in Clinical Evaluation
Design Feature
Probability
Severity
Valve and Actuator Fatigue
?
3
5
Risk management plans
Risk Verification Report
Risk Management Meeting date 21/12/2009
1
2
3
4
Summary
Verified information source from Clinical
evaluation report C01989 issue 2
Design FMEA conducted 21/12/2008 verified
Test report T18786 revision 1 verified
Reviewed Test report and confirmed risk control
acceptable
Conclusion
Risks identified in the risk analysis coincide with
the original information sources and risk
management activities defined within the RM
Plan document D001 revision 3
Controls within Design have been reviewed and
reduction of probability is consistent with the
control
Signed ____________Date 21/12/2009
Hazardous
Situation
Valve affects
Dose plume1
27
Hazard
Mechanical fatigue
Harm
Too much drug
Design Feature
Probability
Severity
Valve and Actuator Fatigue2
?
33
5
Risk management file
 ISO14971:2007 requirements
28
Risk management file
Requirement
Risk Management Plan
Clinical Evaluation –
PHA*
Identification of
Characteristics
Design FMEA
Application FMEA
Process / Supplier FMEA
Risk Management Report
29
Risk Analysis
 ISO14971:2007
30
Risk analysis
• Failures in Test
• Technology
limitations
• User feedback
including failures and
hazards
• Summarise
knowledge with
respect to risks
Design
Planning
• Clinical / Scientific
literature Review
• Standards
• Competitor products
• Create Risk
Management Plan
• Draw up Hazards
Proof of
concept
• Simulations and
Validations
• Testing results
• Supplier Part
approvals
• Bench Testing
• Clinical investigations
• Risk Management
Reviews
Design
Transfer
• Process Validation data
• Supplier qualification data
• Manufactured variance analysis
• Process FMEA
• Risk Controls and Transfer
to Validation, Complaints,
Vigilance, Change control
and Supply chain
• Clinical follow-up trends
• Customer Performance
evaluation
• Published articles
• Complaints investigations
• Usability trends
• Other PMS analysis
• New Risks, Frequencies
and severities
Clinical
Validation
Designing
Annex G activities
MDI
MDI
Preliminary
Hazard
Analysis
31
Clinical /
Scientific
evaluation
Preliminary
report
MDI
MDI
MDI
MDI
DFMEA
Revision 1
DFMEA
Revision 3
PFMEA
Revision 1
PMCF
Revision 1
Risk analysis
32
Preliminary Hazard Analysis
 Review of FDA Guidance provides the following summary of
requirements....
Characteristic
Hazardous Situation
Potential Harm
Severity
Dose content uniformity
Insufficient Dose uniformity
- Design characteristic failure
/ Actuator / Valve
insufficient dose delivered
too high dose delivered
depends on customer / drug
depends on customer / drug
Dose content uniformity
Degradation of Dose
uniformity over time – Design
characteristic failure of
actuator / valve over the
lifetime of uses
As above
As Above
Aerodynamic particle size
Particle size is > 5Microns
- Design characteristic failure
of the MDI (Size and shape of
expansion chamber / stem
insufficient dose delivered
As above
Spray Pattern and Plum
geometry
Inappropriate spray pattern
and or plume geometry –
Design characteristic failure /
Actuator / Valve
As above
As above
Leaching
Drug chamber / contact
materials leaching polynuclear aromatics (PNAs),
nitrosamines, monomers,
plasticizers, accelerators etc.
Toxicological effects
depends on customer / drug
and patient contact
33
The preliminary clinical /
Scientific report

Description of the intended performance

Describe reasonable performance expectations

Describe indications and claims if known

Standards and Regulatory guidance review

Literature review based upon common features / exclusion and inclusion criteria

Summary of current methods and their limitations including current techniques,
instrumentation and surgical technique, current outcomes and expected clinical
benefit

Evaluation of your experiences from similar devices

Confirmation from your customer relating to some of the most important aspects for
their Drug Master file.
= Compilation of Hazards / Hazardous situations to be included in future risk analysis
= Consideration relating to risk acceptability
34
The preliminary clinical report
 Ensure that previous risk analysis are
reviewed.
 Review of Design failures (Where output
could not be achieved)
 Review of failed validations
 Review of limitations – Technology,
Process, Supply chain or Drug delivery
 Review of customer complaints relating to
similar designs or similar intended use
35
Risk analysis – PHA for MDI.
Hazard
Forseeable sequence of events
Hazardous situation
Information
Source
Harm
Mechanical
Dose content
uniformity
After several actuations the dose content uniformity
is compromised
Design
FDA Guidance
Design and Test data
on file
Insufficient dose
Overdose
No dose
FDA Guidance
Design Data on file
Toxicological /
Poisoning
[See Design FMEA for Valve and actuator
design]
Process
See Process FMEA
Use
[See usability / AFMEA]
Chemical
Leaching
Unintended leaching of toxic compounds from the
container / plastic components enter into the drug
and are delivered to the patient
Design
[Selection of the material and manufacturing
method – See DFMEA]
Process
[See PFMEA – Inappropriate moulding
parameters – incorrect material spec]
Use
[See usability / AFMEA]
36
Risk management in Design
Tip
 Ensure that there are regular reports
relating to the design progress but ensure
that risks identified and their references
are reported within the phase as this
concentrates the minds of the people
undertaking the design project
37
Risk management
documentation in design


38
Risk Management Plan

Clinical / Scientific Reports

R&D Reports

Process Validation reports

Supplier qualification reports

Design Validation reports

Usability reports
Identification of characteristics affecting safety

Design FMEA

Process FMEA

Application FMEA

Risk management summary

Post market clinical follow up and risk reviews

Transfer to manufacture risk management control plans
Risk management in design
• Failures in Test
• Technology
limitations
• User feedback
including failures and
hazards
• Summarise
knowledge with
respect to risks
Design
Planning
• Simulations and
Validations
• Testing results
• Supplier Part
approvals
• Bench Testing
• Clinical investigations
• Risk Management
Reviews
• Clinical / Scientific
literature Review
• Standards
• Competitor products
• Create Risk
Management Plan
• Draw up Hazards
Proof of
concept
• Process Validation data
• Supplier qualification data
• Manufactured variance analysis
• Process FMEA
• Risk Controls and Transfer
to Validation, Complaints,
Vigilance, Change control
and Supply chain
• Clinical follow-up trends
• Customer Performance
evaluation
• Published articles
• Complaints investigations
• Usability trends
• Other PMS analysis
• New Risks, Frequencies
and severities
Designing
Clinical literature
Design Standards
Competitor products
Recalls and advisory
Previous RA
Prelim
Hazard
Analysis
Intended Use
Characteristics
Hazard identification
Risk
Mgt
Plan
39
Design
Transfer
Clinical
Validation
Outcomes
Risk
Analysis
Reliability data
Customer feedback
Manufacturing data
Risk
Report
Typical Controls in Design.
40

Functional Testing / Bench Testing

Testing against a Standard – Validation i.e. ISO11137, ISO11607, ISO7206-4, IEC 60601-1 – FDA Guidance

Simulation – Finite Element – Wear performance

Hand Calculation

Prototype study

Choice of Materials

Choice of processes and Technology

Focus Group (Human Factor Analysis)

Clinical Literature Searches

Concept Reviews (Focus Group) – Surgeon / Clinical / User opinion

CAD Assembly / Tolerance Study

Design of Experiments

Tolerance Stack Analysis

Assembly Testing

Scientific / Engineering Constant

Review of Similar Designs

Measurement Systems analysis

Clinical Investigations

Validations

MTBF – Stability testing
REMEMBER
The control will be used
in order to give you assurance
when you are doing a test that
you have covered a risk........
Typical controls in Design
 ISO Standards
 FDA Guidance
 Customer Testing methods
 Bespak Testing methods
41
Risk Management in process
Moulding
Material
processing
Machining
Storage
Assembly
Risks
Distribution
Cleaning
Sterilisation
Labelling
Packaging
42
Risk Management in process
Validation activities
should be initiated with
risk management
Process hazards should
derive from the DFMEA
Moulding
Material
processing
Machining
Storage
Assembly
Risks
Distribution
Cleaning
Sterilisation
Labelling
Packaging
43
Risk Management in process
Hazards
How Moulding can
initiate the hazard
Moulding
Material
processing
Machining
Leaching
Storage
Assembly
Inappropriate material
Incorrect Heat and pressure
Incorrect additives
Inappropriate mould time
?????
Risks
Sequence of events
inappropriate cross linking of
polymer leads to plasticiser
free radical
inappropriate material
formulation / ingredient
selected
44
Moulding controls
Distribution
Cleaning
Sterilisation
Labelling
Packaging
Material verification
Process Validation of
Moulding parameters
Goods inwards Verification of
raw materials
QC Sampling for Leaching
Typical Controls in Process.
45

Testing Points

Trained in a SOP

Gauge R&R

Process Validation

Monitoring and Measurement (SPC Process or product parameters)

Poke Yoke Settings

Checkmate Verifications / Closed Loop Systems

Software validation

5S / Line Clearances

Identification and Traceability

Physical Location controls

Start up verifications

In process verifications

Routine Maintenance

Calibration

ISO13485:2003 / Ordinance or FDA Control requirements.

Supplier Evaluation – First Article / PPAP

Routine Audits
Risk Controls – Risk benefit
 ISO14971:2007 requirements
46
Risk controls – risk benefit
 ISO14971:2007 requirements
47
Risk Management Report
48
Typical Risk Management Report
 Summarises the Way you did risk
management
 Summarises that the risk controls have
been implemented (And verified)
 Summarises where you got the
information
 Provides a succinct summary of the results
of the activities and how controls will be
reviewed on an ongoing basis
49
Keeping risk management alive
Concept diagram - MDI
Define
Define the
the need
need
What the
clinical
benefit
would be
Reasonable
expected
performance
Hazards
relating to
the current
use,
Technology
Database
51
Define
the
Scope
Project
Define
the
Scope
ofof
the
Project
Area
MDI
Operator /
User
COPD Patient
Delivery
method
Valve / Actuator
Intended
Use
Particle Size
Number of uses
Drug type
Indications
for use
Critical to quality
requirements
Technology
Moulding /
Machining
Develop the Product
Develop the Product
Risk control
Verification
Risk
Manage
Report
Design
Validation
DFMEA
Lifecycle
Develop the Product
Place on Market
PHA
PHA
Select the Risk Management
Plan to use
Generic
RM Plan
Dev
Develop the Product
Implement Process
Customer
Acceptability
Process
Validation
Clinical
Benefit
V
Risk
Risk controls
effective?
Custom
RM Plan
Dev
change
to risk?
Lifecycle
NO
PFMEA
YES
On
Market
RM Plan
Lifecycle
Change
RM Plan
Lifecycle