Blog
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.
