Author: Brandon Miller

Cytotoxicity Testing

Posted on by Brandon Miller

 

In this soundbite from RCA Radio, Dr. Helin Raagel and Dr. Matthew Jorgensen from Nelson Labs explain why the Cytotoxicity test during a biocompatibility evaluation is the most important test you will run.

 

cytotoxicity

What is Cytotoxicity? – Cytotoxicity is the degree to which a substance can cause damage to a cell. A substance or process that causes cell damage or death is referred to as cytotoxic, “cyto” meaning cell and “toxic” meaning poison. (Will the device kill or harm the cells it comes in contact with?)

 

There are three reasons why the cytotoxicity test is the most important test you run during a biocompatibility evaluation.

  1. The test can be run quickly.
  2. It is the most cost-effective test in an evaluation.
  3. Most evaluation concerns come from the cytotoxicity results.

 

Listen to the full episode “What is Cytotoxicity?” now!

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

Cyber Awareness for Consumers

Posted on by Brandon Miller

Click now to listen to RCA’s Susan Schniepp and Steven Lynn, in this RCA Radio audio update:

 

Personalized Medicine

 

Software as medical device (SaMD) continues to emerge in consumer products, including diabetes and sleep management. When it comes to FDA cybersecurity, every device developer knows the ecosystem is more likely to be wifi-connected than ever before. Cyber awareness involves using design controls to consider a variety of consumer SaMD applications & how they connect to smartphone operating systems and open network solutions. By scaling efficacy technology, or personalized medicine, developers are addressing a rapidly growing segment of healthcare treatment.  

 

FDA Cybersecurity

 

How can regulatory compliance help protect consumers from hackers when forwarding patient info between sources is involved? During a risk assessment, a SaMD consultant might end up looking at every step between the health system provider and convenience of not visiting a clinical environment. Further, as industry leaders who understand how technology can increase the speed of personalized medicine to market, what types of cyber awareness becomes more critical to protecting patients?

 

Home Dialysis

 

One SaMD cybersecurity focus Schniepp has already identified is in the Home Dialysis industry. Medical device manufacturers are continuing to evolve with the demand for smaller prototype devices in general, which may enhance cyber convenience becoming a competitive advantage. However, the commercial cyber threat is permanent and even the largest organizations in the dialysis industry can be a target. 

 

Combination Products

 

Lynn agrees & understands that an FDA combination product strategy will continue innovation by means of software and drug delivery. This fundamental mindset change requires extending the definition of “users” of these connected medical devices. It includes patients and HCPs — but also FDA inspection roles needed during during regulatory compliance (e.g. biomedical engineers, IT engineers).

 

Fixed Dose Combination

 

Any combination device would include cyber awareness practices between medical devices & connected facilities that demonstrate and prove trust. Do the relationships between healthcare infrastructure increase or decrease exposure to disruption? Further, where could any attack surface breach trust and cause harm to the patent (e.g. disrupting a patient dosing device). Cyber awareness understands that intended use of the device must also address the perspective of an unwanted attacker.

 

Regulatory Compliance

 

Lynn & Schniepp both agree on one topic: patient compliance. Any type of medical device software that increases patient adherence during a healthcare routine will be applauded by FDA consultants. FDA SaMD guidance lists the ISO standards and QMS regulations needed for the submission. Accelerating the intended use through increased compliance is a regulatory strategy that can be presented via clinical evidence.   

 

About Susan Schniepp

 

Regulatory Compliance Associates® Distinguished Fellow and the Parenteral Drug Association® (PDA) Chair of Board of Directors, Susan Schniepp, will be presenting a tech talk at INTERPHEX® in April 2023 where you can learn about contamination control strategy, how to identify and assess risk, prepare mitigation pathways, and defining preventive actions associated with contamination in sterile product manufacturing.

 

Sue is the knowledge leader for RCA® and is Chair of the Parenteral Drug Association (PDA) Board of Directors. Sue’s background includes cGMPs, audit readiness, change control, investigations, supplier quality, and batch record review.

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

Medical Device Cybersecurity Guidance

Posted on by Brandon Miller

The International Medical Device Regulation Forum (IMDRF) recently published updated cybersecurity guidance for the medical device industry. The medical device cybersecurity working groups at IMDRF have been busy lately, publishing multiple final documents about medical devices & software as medical device (SaMD). 

 

Regulatory Compliance

 

IMDRF’s medical device guidance provides steering assumptions for both regulatory compliance & medical device cybersecurity, which are appropriate for sponsors developing medical devices. Further, a primary objective of the guidance is simultaneously increasing patient safety & reducing external threats for providers and HCPs.

 

Global Harmonization

 

The guidance begins with harmonization concepts that could affect multiple departments inside a medical device manufacturer. Additionally, key areas for harmonization programs highlighted by the cybersecurity guidance include:

 

  • Product design
  • Risk management activities
  • Device labelling
  • Regulatory submission
  • Information sharing
  • Post-market activities

 

Product Life Cycle (PLC)

 

IMDRF’s cybersecurity guidance continues on with a deeper evaluation of risks associated across the product life cycle. It is recommended for potential vulnerabilities to be considered for any product life cycle stage, especially considering legacy devices that may be vulnerable to strategic risk. 

 

 

Product Design

 

Product design considerations include the initial phases of medical device development and continues until the end of support (EOS) once a product is discontinued. The four product design stages the cybersecurity guidance refers to when it comes to total product life cycle:

 

  • Development Stage
  • Support Stage
  • Limited Stage
  • End of Support

 

Development Stage (Stage 1)

 

The Development Stage occurs during the pre-commercialization phase before a medical device is approved by a regulatory body. This is when medical device manufacturers begin to incorporate security into the product concepts being designed. Design controls are critical in this stage for medical device manufacturers to leverage when considering how to mitigate risks.

 

Finally, an important deliverable of the Development Stage is product-related security documentation. The documentation is designed to help unfamiliar users to understand how to securely operate the medical device. 

 

Support Stage (Stage 2)

 

The Support stage is during the initial post-launch phase and may continue for many years. Medical devices in this stage are:

 

  • Currently used for providing patient care
  • Available for purchase on the open market
  • Contain major software, firmware, or programmable hardware components
  • Support for software, firmware or components is provided by the medical device manufacturer

 

Additionally, medical devices in the Support stage should receive full cybersecurity support. This support often includes software patches, software updates, hardware updates, and incremental support the manufacturer considers appropriate.

 

Limited Support Stage (Stage 3)

 

Medical device manufacturers continue to provide cybersecurity support during Stage 3. However, as product development transitions to a more current medical device design, different constraints are involved with the transition. Medical devices in Stage 3 often require additional network controls compared to medical devices in Stage 2:

 

  • Third-party components or software may be used more frequently than internally developed updates or patches
  • Cybersecurity best practices integration is often governed by the ease of following support practices outlined in the Stage 2
  • Medical device manufacturers must explain to users the existing limitations that are now recognized in the devices and services affected
  • Healthcare providers using the medical device should begin to take more of an active role in unmitigated features of security defense.

 

End of Support Stage (Stage 4)

 

Medical devices in Stage 4 are considered more vulnerable than any of the other stages. They may still be in use for providing patient care, but they have been publicly identified as no longer being supported by the medical device manufacturer. Each of these scenarios result in a medical device that cannot be consistently defended against modern cybersecurity dangers.

 

Critical facets healthcare information technology departments should look for include:

 

  • Medical devices that have been declared EOS by the medical device manufacturer
  • Medical devices that are not actively marketed or sold by the medical device manufacturer
  • Medical devices that contain software, firmware, or programmable hardware components no longer supported by software developers
  • Medical devices with known risks to device safety and effectiveness that are unmitigated

 

Risk Management

 

risk managementFurther, the guidance calls for a risk management approach to product lifecycle management featuring:

 

  • Security risk analysis
  • Security risk evaluation
  • Security risk control
  • Security risk acceptability

 

The cybersecurity guidance expands on product design and how security is incorporated and maintained through the product life cycle. This can be accomplished through using risk control and a secure development framework.

 

Risk mitigation recommendations for medical device manufacturers include:

 

  • Security design and controls based on intended use of the medical device
  • Security risk assessments across the risk management process
  • Threat modelling to help determine operational risk

 

Security testing and communication for medical device manufacturers include:

 

  • Customer facing product security documentation & communication
  • Post-market monitoring of cybersecurity vulnerabilities
  • Identification of vulnerabilities in third party risk management
  • Vulnerability risk identification based on the device security design, controls, and mitigations

 

Ensuring availability of security patches & mitigations based on device risk:

 

  • Coordinated and clear communication to all affected users
  • Description related to the vulnerability and its corresponding mitigations
  • Identification of other mitigation options when a security patch is unavailable

 

Data Integrity

 

One of the core principles the guidance stresses is cybersecurity information, data integrity and the importance of information sharing. IMDRF encourages medical device industry stakeholders to implement a proactive pre- and post-market approach to cybersecurity information sharing.

 

Moreover, timely information can help the industry recognize threats, evaluate associated risks, and react quickly as needed. An increase in industry transparency could directly benefit healthcare providers, medical device users and medical device companies.

 

Security Updates

 

An important section of the medical device cybersecurity guidance details stakeholder responsibilities related communications, risk management, and transfer of responsibility. Specifically, it is important that medical device manufacturer communications are comprehensive & identify types of documentation needed and when the medical device user may need it. 

 

Product Security Documentation

 

Medical device manufacturers should ideally provide PLC documentation about security or support changes early in the Support stage. This helps HCP risk management during both the procurement & deployment of medical devices. Types of life cycle support for product security documentation includes:

 

  • Manufacturer disclosure statement for medical device security
  • Software Bill of Materials (SBOM)
  • Security test report summaries
  • Third-party security certifications
  • Customer security documentation

 

Product Life Cycle Documentation

 

Medical device companies should communicate the strategic life cycle milestones to their customers. Further, these interactions would include cybersecurity EOL and EOS dates if available. This helps to support HCPs during both the procurement & installation process.

 

Additionally, medical device manufacturers should provide this information as far in advance as possible. The goal is at least 2 years in advance to best support healthcare professionals with the following information:

 

  • Affected medical devices
  • Medical device operating system(s)
  • Version of medical device deployed
  • Medical device software components
  • Expected date of medical device service changes
  • Extent of medical device maintenance after a service change occurs
  • Additional design controls that help all involves parties

 

Vulnerability & Patching Information

 

If a vulnerability is uncovered, medical device companies should provide related vulnerability information. Further, the guidance specifically mentions the importance of both the appropriate mitigation or available software patch. Additionally, the guidance stresses an elevated priority be placed on high-risk vulnerabilities where timely communication is required. This communication is designed to help prevent both patient injury or device interruption.

 

Finally, the mitigation method and implementation instructions should be provided to the medical device operators. These security updates include both an over-air update or deployment of service personnel to help install the remedy.

 

Proactive Communications for Third-Party Components

 

Medical device software and other digital components within a medical device will reach EOL/EOS before the product itself does. In these cases, risk can increase based on the lack of support for these elements. To help compensate for these security risks, the cybersecurity guidance suggests medical device companies should:

 

  • Validate the list of third-party components used in medical devices
  • Track support status updates of third-party components used within their device
  • Assess the risks that exist when third-party components become unsupported
  • Communicate new risks and available risk mitigations to healthcare providers

 

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Brownfield vs. Greenfield Facilities in Pharma

Posted on by Brandon Miller

The onset of a global pandemic and other factors are causing many U.S.-based pharmaceutical and medical device companies to evaluate whether to bring back manufacturing facility operations they’ve previously outsourced to other countries. In a time where ensuring quality is paramount, insourcing has the potential to allow these organizations to implement more stringent quality control standards. Deciding between a brownfield and greenfield strategy also optimizes logistics networks and reduces transportation costs, provided raw material suppliers are readily available.

 

A primary consideration when onshoring manufacturing is deciding whether to select a brownfield or greenfield site.

 

What Is a Brownfield Facility?

 

A brownfield manufacturing process utilizes a suitable existing facility and infrastructure. In many cases, the manufacturer will either purchase or lease the structure and perform any modifications required to complete the “fit-out”. In many brownfield projects, production is already occurring and personnel who are familiar with the projects and compatible quality control systems are in place. This may even be an existing facility within the corporate structure of the company. 

 

The most obvious advantage of choosing a brownfield site is a faster implementation. There’s no need to wait for the construction of a new facility, which could take a year or longer. If executed correctly, the transition to a brownfield facility can be quick and seamless, reducing downtime and minimizing disruptions that negatively impact service. Additionally, these sites may have legacy tech systems (ERP, eDoc, CAPA etc.) that can integrate the new operational processes.

 

brownfield greenfield

On the downside, brownfield facilities may have some production limitations due to the nature of the existing infrastructure. Scaling the operation may also pose significant challenges. As these structures are often older, they may have some operational inefficiencies and require more maintenance and upkeep. Some systems may even require replacement or considerable overhaul.

 

If you’re exploring the possibility of moving into a brownfield site when onshoring manufacturing processes, it’s essential to evaluate its current validation status. Transferring a new product into an existing facility often triggers a regulatory inspection and could lead to inspectional observations surrounding existing operations.

 

What Is a Greenfield Facility?

 

A greenfield site entails the construction of a manufacturing facility from the ground up. The manufacturer has more flexibility to customize the structure’s design to the project’s unique requirements. With proper planning, the site can also accommodate future growth more efficiently. Maintenance costs are usually lower than with a brownfield facility, as the building, equipment and machinery are typically brand-new and in peak operating condition. 

 

One drawback to opening a greenfield site is time. It may not be a viable option if the manufacturer must act quickly to keep up with customer demand or bring a new product to market when there is an immediate need. Hiring new staff and onboarding can also introduce a significant learning curve and lengthen the time frame until operations are up to speed. 

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

Compliance & Product Launch

Posted on by Brandon Miller

Why has product launch become more complex after the pandemic & how have the “roots of compliance” changed the EU regulatory environment?

 

 

In this sound bite from RCA Radio, host Brandon Miller is joined by Kinga Demetriou, an Expert Certifier at BSI, as they discuss how the pandemic changed the “roots of compliance” in the EU regulatory environment.

 

  • Since the pandemic, quick routes to market such as EUAs have been stopped leading to market servaliance company’s putting more scrutiny on products (e.g. PPE masks)
  • Manufactures have found out that offering a products in different markets take a lot of recourses to understand the roots of compliance depending on the location
  • Different market access requirement have been introduced depending on geography
  • New rules and certifications are in place making it more complex to launching products in multiple markets

 

Listen to the full Podcast on Global Regulatory Trends –> Click Here

 

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Addressing Troublesome Design Protocols

Posted on by Brandon Miller

What should you do if you are having trouble executing your design protocols? 

Listen to this highlight from RCA Radio where Walter Mason explains what needs to be done if you have troubles executing your design protocols even after training.

 

 

Listen to the entire episode where we take an in-depth look at protocols for biologics and their importance. RCA Radio Episode 13.

 

What can you do?

  • Go to the developer and let them know that it is not working for you
  • Talk through the design protocols in general
  • Procede step-by-step through the design protocols process
  • Look back at the FDA guidance documents
  • Get feedback on your design protocols
  • Implement changes in your training or to the protocol itself

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].