Design development for medical devices: reaching the market



It is obvious that first of all you need to have an effective product. In the world of consumer products, that's the biggest part of the challenge. Not so in medical devices. In medical devices, you must thoroughly test the effectiveness of your device because, more than most consumer electronics, people's lives are often at stake. The FDA takes a gradual approach to this risk depending on the nature of the product, but in all cases the way it demonstrates the effectiveness of your device is through documented evidence. Your documentation is ultimately what will be approved or disapproved when it comes to bringing a device to market.

The general rule of the FDA is that if it is not documented, it will not happen. So, for example, if you have a product whose stated purpose is to make "x", "y" and "z", how do you show that it really does? Answer: documented evidence. These engineering tests are called "protocols" and there are several main phases that involve them in the development process.

STEP 1: Design development. Design development begins by creating a prototype. All new devices are ultimately prototypes when they are in the development phase (before being transferred to manufacturing). That said, there are often also a series of component parts within a prototype device that qualify as "prototypes." In general, any new device or component that is not a current commercial part (COTS) must first be prototyped. The amount of time the design and engineering process takes depends on how complicated your device is, how experienced your engineering team is, and how well your staff works as a team. Some devices may have hundreds or thousands of parts (both customized and COTS), assemblies of printed circuit boards (PCBA) and a large number of software to accompany them. Others may consist of only a few mechanical parts (for example, a medical stent). Development can take less than a year or a whole decade. It completely depends on the details of your project.

STEP 2: Design verification. Once your team has developed a functional prototype, the process goes to what is known as "design verification." Verification is what it sounds like: verify that the design works as intended. The process involves making sure that the device as a whole and the individual components and subsets achieve the desired results (engineering results). This is done by writing detailed test protocols and then evaluating the performance of your machine against them. An important part of the verification process is the traceability matrix. The traceability matrix is ​​a table that links different aspects of the design with the different tests that have been run to verify it. Think of it as an index for all tests and documentation of risks related to your medical device. The development of a traceability matrix is ​​the way in which it tracks all the verification work carried out during the design development process.

STEP 3: Perform risk analysis. Each device has its points of failure (things that can go wrong and possible consequences in case something goes wrong). The risk analysis focuses on identifying possible negative results and establishing controls that mitigate the consequences. One of the most structured and widely accepted methodologies for assessing and managing risk is the Analysis of failure modes and effects.
dFMEA: The "d" means "design." The Analysis of Modes and Effects of Design Failures (dFMEA) is the process of evaluating components, subsets and the largest set to identify places where things could go wrong. The idea is to assume that things will go wrong, see what the logical sequence of events would be if they did not occur, classify the magnitude of the consequences and mitigate them when they are particularly negative.
pFMEA: The "p" means "process." Process Failure Mode and Effects Analysis (pFMEA) is the process of evaluating manufacturing procedures and the human beings and / or machines that drive them to identify where things can go wrong.
Control plan: the control plan is really your mitigation plan. Controls are the various procedures, redundancies, warning signs and backup engineers implemented to mitigate the risks that have been identified.

STEP 4: Develop the device master record (DMR). The device master record is a controlled document that tells you everything you need to know about your medical device. It is the collection of part drawings, the various lists of materials (BOM), the flow chart of the manufacturing process that generally details all the procedures used to build the device, and the evidence record (verification and validation documentation) that Together they demonstrate the effectiveness of their design. If the FDA is going to audit your device, the first place they will go is to your DMR (or DMR index).

STEP 5: Presentation of 510k. Once the device has been fully examined, it is ready for submission to the FDA. This is what all your product development work is leading to. For more information about this process, read here.

STEP 6: Design transfer. After successfully examining your design with the regulatory agencies, you will transfer your product to manufacturing. The main parts of your manufacturing process will have been examined along with the device itself. These include important elements such as validation and verification (Facilities and services IQ / OQ, Equipment IQ / OQ / PPQ, Process OQ / PPQ and Validation of test methods)
Now you are ready to ...

Start production and update the design history file (DHF) as the device is built. The design history file (DHF) is a formal document created for each medical device. The DHF is a collection of several records generated in the actual production process. If you need to know something about the history of a specific device, then DHF is your destination. DHF can be physical in the case of paper or digital records in the case of electronic records (or some combination of the two). It is the main repository for finding information about the specific serial numbered device.

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