Tag Archives: combination products

Medical Device Development – How to get the best possible return on your investment

Bringing a medical device to market requires significant investment of time, money and resources.

In our experience, the precise amounts of all three needed to successfully complete development, industrialisation and launch varies, depending on the nature, complexity and risk associated with the product.

It is not unusual for a low to moderate risk device to take 3-4 years to reach the market, supported by development investment of up to around $30million. As the device risk and/or complexity increases, so does the investment; by comparison, a complex, high risk device may take upwards of 6 years and $90 million to bring to market. There are no guarantees, of course, that the device will ever make it to the market or, if it does, that it will be commercially successful but for those that are, the rewards can be significant.

So the medical device development process can often be a perfect storm —high risks, high costs, lengthy development timelines that can eat into the revenue generation window, and potentially relatively modest returns—has created a difficult environment for medical device innovation. If you’re in this challenging environment, you’ll want to focus on strong management of process to mitigate risks and minimise time and investment, whilst ensuring your development roadmap doesn’t cut any corners.

In our experience, gained from over 25 years in device development, you stand the best chance of success if you focus on three critical factors;

  • Mitigating Risks
  • Controlling spend
  • Optimising project timescales

Mitigating Risks

To mitigate risks, first there has to be an understanding of the potential risks in the development process and secondly a plan to minimise their impact and mitigate them as far as is practical and cost effective.

Controlling Spend

Controlling spending is not just about spending wisely and getting best value, but also about making informed investment decisions (based on sound data and experience) to reduce risk by investing proactively in key areas. Sometimes, money spent in the right areas early on in the development process can save significant sums later on – the cost of quality effect.

Optimising project timescales

Optimising project timelines involves identifying key decision points and ensuring you have the data you need to make robust decisions when and where they’re needed, preventing unnecessary work or racing down a flawed development path. Creating the least impact on project timescales steps back from the fallacy of planning a “best case” project timeline, which almost inevitably falls apart at the first hurdle and ends up costing far more than budgeted and taking years longer to deliver (if at all). Instead, it looks in detail at the individual project elements and avoids the temptation of cutting corners to create a more robust, realistic, affordable and achievable plan for development through to launch and beyond.

That’s a lot to consider, no matter what development stage you’re at.

How to ensure medical device development goes smoothly

To ensure things go as smoothly as possible, when we’re brought into a project to deliver a specific piece of work we offer clients the option of a scoping day, assessing collaboration prerequisites and risk factors in a pre-collaboration checklist.

This builds the foundation for a successful working relationship, with no surprises, and enables us to help you avoid the pitfalls that can stop, stall or even derail a project completely.

The Cupboard of Shame

Many people like to be able to present a clean, well-ordered home when they are expecting visitors. Some even prefer to have their home “inspection ready” most, or all, of the time.

skeleton-closet_smallerThis goes for our work environment too, especially if these visitors are about to audit us. So it’s common during preparation for audits to tidy-up and clear out any junk or items that have accumulated for a variety of reasons. There’s nothing wrong with tidying up and audits are often a good prompt to do those annoying jobs that we have been putting off. Jobs like finding out how to dispose of some nasty chemical or how to recycle a load of plastic parts. However, as with tidying your home there can be a reluctance to throw some things away, even when you know you should, because at some point they may become useful or someone may ask for them.

A while ago, our team was supporting a client’s regulatory audit. The whole site was looking pretty good; tatty old labels and signs had been updated, benches were clean and everything was labeled to within an inch of its life, everything was looking spick and span. The site was ready.

On the first day of the audit the inspector asked to be shown around the site. The site tour included laboratories, manufacturing and packaging areas, the waste disposal area and the warehouse. The site tour was going well, people were looking happy and were able to answer the inspector’s questions satisfactorily. All was fine, until the “cupboard of shame” was discovered lurking at the back of the warehouse. Now of course the cupboard wasn’t really called that at the time, but thanks to the back-room team, the name stuck. The cupboard looked harmless enough, it was padlocked closed and was very small in size. However, when the inspector asked about the contents, signals started to be given off that something may be wrong. There was a lot of shuffling of feet and sidelong glances and it took a while to find someone who had a key.

Danger, Will Robinson!The padlock was unlocked, released and the cupboard doors swung open to reveal the contents; lots of “odds and sods” items, the stuff that really could have been disposed of long ago.

There were several boxes of a product from another site, no longer in production and years past its expiry date. There were end of reel labels and ”spare” plastic bottles, device components, plastic bags. A lot of the stuff had been kept just in case it may be useful, one day.

Now, the people who knew about the “cupboard of shame” weren’t doing anything malicious and genuinely had good intentions, they had even padlocked the door to restrict access. But none of that prevented the inspector’s discovery appearing as an observation in the final audit report.

red-light_smallerYou can bet that their “cupboard of shame” no longer exists after that unfortunate series of events.

Do you tidy up for every visit, or do you prefer to be “inspection ready” all the time?

Whichever your preference, what’s hidden in your “cupboard of shame”? You may welcome a fresh pair of hands helping to sort it out.

Three ways to smooth your path for device development

Medical Device Development routemap v5.0 narrow viewSpring of 2013 still seems recent, so I was surprised to realise that the route map for medical device development will shortly be 3 years old. If it were a child in the UK, we would be able to get 15 hours free childcare a week from this September.

Children learn and grow at an alarming rate, especially when you’re looking back over what seems like a very short time and realise that the baby you remember holding in your arms “yesterday” is now a teenager.

The route map too is growing up fast. It’s being used across the world, from Australia, through Asia to Europe and on to North America. Users have fed back great experiences. Uses ranging from a desktop aide mémoire, a teaching aid, through to a planning and design review tool!

There comes a time when a child learns new skills, and naturally integrates them into their daily lives and toolkit.

We’re proud to announce the launch of the route map for medical device development 5.0 today. Numerous user suggestions have been incorporated in this new version, along with two new tracks; Intellectual Property and Market Research.

The route map continues to help you in three ways, it;

  1. Describes the journey you’ll embark upon, from a device idea through to launch.
  2. Sets out the main activities for each of 9 disciplines, through four stages of product development.
  3. Identifies the points where there are major interactions between disciplines.

And here it is…

Click to open a pdf version you can download

Click to open a pdf version you can download

You may already see how this picture will be helpful, whether you’re working in medical devices, combination products, pharmaceuticals, aerospace, defence, electronics…..

Send me your thoughts on how you can use the route map, because having a straightforward, independent view is always valuable.

FDA finalises Human Factors Guidance – Existing products – Part 4

In this series of posts, we’re taking a look at the recently published final version of CDRH’s guidance “Applying Human Factors and Usability Engineering to Medical Devices”.

The document, published on 3 February, is the result of nearly 5 years of consultation with industry since releasing a draft guidance back in 2011.

FDA HF guidance FINALWe have covered a lot of ground already. In the first 3 parts, we heard about four of this list of the key topics covered by the Center:

  • Human Factors Engineering process
  • Risk Management and Human Factors
  • Design Verification
  • Summative Human Factors testing
  • Changes to products already on the market
  • Human Factors Engineering Summary report

In part 4, we’ll look at the Human Factors Engineering Summary report and submission of your HFE data. You may then want to think about how this may impact what you’re either already doing, or plan to do.

Changes to products already on the market

You may be wondering how this relates to devices that are already on the market? The agency has provided some guidance to help you understand when modifications to a device mean that it should undergo validation testing. The need for additional human factors validation testing should be based on risk management planning and risk analysis for the modified User Interface or Tasks, to determine the scope and nature of testing required and should focus on those hazard-related use scenarios and critical tasks. The test may, however, be limited to assessment of those aspects of users’ interactions and tasks that have only been affected by the design modifications.

The agency also recommend that for any further human factors validation testing consideration should be given to user’s comparison of the design modification to the previous design.

Human Factors Engineering Summary report

It’s often seen as the culmination of your HFE programme.

Expectations for content of the report have expanded, to require far greater information about analysis and elimination/reduction of risks and hazards associated with use of the device, critical tasks and use scenarios. Far greater detail is needed about the validation study, discussing test environments, training correspondence to real-life, data collection methods, test results, feedback, analysis of use errors, difficulties, root causes of problems and implications for risk elimination/reduction.

The Center are proposing to require submission of HFE data with your PMA or 510-K, for those devices where users performing tasks incorrectly or failing to perform tasks could result in serious harm. There’s a separately issued, draft, guidance that outlines current thinking on which devices would need this as a matter of course, which may well change between now and the final version of that document.

However, the agency has not removed the expectation that a human factors programme is present as an integral part of a robust design control system.

So you still have to do it, you just may not always need to include an HFE Summary report in your submission dossier.

When is the guidance effective?

You will have some time to assimilate the requirements…
A whole month, as they go live on 3 April 2016.
How will these changes will affect your product development?

What impact they will have upon your Human Factors Engineering programme?
Get in touch today to discuss how you can best navigate the changes and emerge with a Human Factors programme that is “just right”.