Importance and Regulatory aspects of Design Control

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US FDA 21 CFR 820.30 Design Control :  :

US FDA 21 CFR 820.30 Design Control :  The minimum expectations are clearly laid down in  21 CFR part 820.30  design control and Clause 7.3, ISO 13485:2016.  As per expectations design and development activity have to be performed and evidenced through DHF at the contract manufacturing site, Legal manufacturers site, design, and development firm as per the business module and it shall be continually maintained and upgraded. The design control initiates at the stage, where the manufacturer decides to make a product and start finding the marketed products already available in the market, we can call them as “Predicated devices”. The manufacturer is expected to create the “ Design Team” which shall have the Product designers, Regulatory expert, QA experts, representative of the user, manufacturing expert, marketing representative, the internal reviewer and the peer reviewer.  www.operonstrategist.com Call / Whatsapp - 9325283428

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The study of the marketed products and data collected about the characteristics of the products can be used as design inputs. The design inputs are also collected from the Initial risk analysis as per  ISO 14971 ,“ Medical devices — Application of risk management to medical devices”. Performing the usability Engineering studies as per standards, like ISO 62366 “ Application of Usability Engineering to medical devices”. The recalls happened before on similar devices is also an important study to get away from similar design flaws. All the data collected from the available studies and resources are used as “ Design Inputs”. The manufacturer shall always try to establish as much as possible the available data to create the design inputs. The design inputs shall not be ambiguous and shall be clearly defined, which helps to create adequate design outputs. It follows the philosophy of “ Garbage in Garbage out” poor design inputs creates the poor design outputs. www.operonstrategist.com Call / Whatsapp - 9325283428

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The product characteristics required to achieve the design input expectations are called “Design outputs”. The design outputs are normally in the form of the raw material specifications, finished good specifications, drawings, in-process controls, types of machinery and equipment required, process flow charts,  vendor details etc. The “traceability matrix” shall be created to demonstrate the linkage between design input and the design outputs. During all the stages of the development, the “Design reviews” of the activities shall be performed by the team members and the peer reviewers to check if the project is being moved to achieve the user needs. The comment from the reviews will determine the changes in the plan or the design and shall be circulated to all the team members. www.operonstrategist.com Call / Whatsapp - 9325283428

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The adequacy of the design output against each of the design input shall be demonstrated. It can be achieved through the set of experimentation and the activity is called “ Design Verification ”. The design verification activity shall be done by creating the test cases for each of the design output and corresponding input. The typical example of the verification studies may be technical, physical, chemical characterization or other engineering analysis, bench testing etc. The test protocols are approved before execution and are executed and data collected. The compilation of the data shall be done to interpret the results in the  “Summary report” The report shall be reviewed to check if the design output is giving the expected design input expectations. In case, design output attributes fail to achieve the desired expectations laid down in design inputs, then it may call up for the changes in the design. All the changes shall be documented through the “design change requests” which shall be approved by all the team members. Once the change request is approved, then design outputs and/or design is changed with the aim to achieve the expectations given in the design inputs. The repeat verification is performed to recheck if the expected design inputs are being achieved. www.operonstrategist.com Call / Whatsapp - 9325283428

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