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Before the submission of a 510(k) premarket notification, the purpose of which is to notify the FDA of the manufacturer’s intent to market a medical device,[i] there is a provision for acceptance review. This review serves as a method to assess whether a submission is administratively complete and includes all necessary information for FDA to determine substantial equivalence under section 513(i) of the Federal Food, Drug, and Cosmetic (FD&C) Act (21 United States Code (U.S.C.) § 360c(i)). To establish substantial equivalence under this provision, FDA must find the same intended use as the predicate device and either have the same technological characteristics as the predicate device or appropriate clinical and scientific data necessary to establish that the device is safe and effective as the predicate device. If the Authority is unable to determine substantial equivalence due to insufficient information, it may request for additional information to make that determination. Therefore, as a part of the acceptance review, the FDA staff follows the acceptance checklist[ii] to ensure that the application is administratively complete. These administrative elements are identified as RTA items and are required to be presented. The purpose of conducting the acceptance review is for the Lead Reviewer to determine whether the 510(k) submission meets the minimum threshold of acceptability and should be accepted for substantive review.[iii]
Last week, I touched on the idea of involving and empowering all employees in the workplace through the corrective and preventive actions process by fostering taking initiative and a problem-solving (refer to blogpost ‘The Art of Addressing Non-Conformances in Operations’). To expand on this concept a bit further, we’re going to be looking at Kaizen–a continuous improvement strategy in which employees at all levels are also empowered to solve problems towards big gains.
The pandemic has been a challenging time for all industries including the Food and Drug Administration (FDA). The FDA had to alter the manner in which it conducted its operations. One set of tools adopted by the FDA in response to COVID-19 was the remote regulatory assessment (RRAs).
At one point or another, you likely took care of a non-conformance within your operations. Non-conformances in quality management are deviations from a specification, standard, or expectation. For example, a primary packaging label with illegible print or an out of specification quality control measurement.
Following are some popular views about the cars mentioned related to quality management systems, above. Substitute the descriptions of the cars for descriptions of a company’s QMS and you’ll realize what the CEO is actually asking for in the conversation.
No matter what our perspectives may be or how they may differ, time is the one thing money cannot buy. It matters how we spend it. Quality 5.0 is coming2 and, although formative, it speaks of massive integration between humans and machines, digital neural interfaces, levelling of the economic playing field, increased longevity, global quality of life, ecological healing, and prolonged existence of humankind off-planet. I want to be ready for that!
Studies are indicating the increasing use of electronic nicotine delivery systems (‘ENDS’) products, particularly amongst current smokers,[i] warranting an evaluation over the need for these products and if they have the potential to do less harm, if not no harm. Some in the public health community have advocated for the harm reduction approach emphasizing on the use of ENDS as an alternative combustible to tobacco products that may contain more harmful or potentially harmful constituents.[ii] Regulating and controlling tobacco use in the era of e-cigarettes has therefore not been an easy task.
Clinical trials, when conducted with great care, are the safest and fastest way in having a treatment approved for use to improve public health1. A clinical trial is an investigation conducted under a protocol which assesses the efficacy and safety of a treatment in humans.
It is no surprise to anyone in the medical device industry that the transition from EU MDD to EU MDR has seen quite a few hiccups over the past couple of years. The most recent obstacle, however, comes in the form of delays from Notified Bodies. The scale of the bottleneck coming from Notified Body capacity to review EU MDR applications has not been a secret, but a recent industry poll sheds light on the growing concern.
A ‘CS’ was to be a ‘Common Specification,’ intended to satisfy the EU MDR requirements. If you were working to comply with the EU’s Regulation on in vitro Diagnostic Medical Devices ((EU) 2017/746)2, or EU IVDR, the equivalent to a CS was referred to as a ‘CTS’ (“Common Technical Specification”).
What makes teams successful, based upon a study of employees working within process improvement teams for each of six large corporations, led to a list of approaches for achieving organizational quality, albeit one improvement project at a time. When I parsed these lists together with a focus upon leadership to achieve organizational quality, I was able to place the key concepts into the seven categories listed below.
Coronavirus (COVID-19) has been prevalent in the United States for over 2 years, on July 6th, the Food and Drug Administration (FDA) modified the Emergency Use Authorization (EUA) for Paxlovid for COVID-19 treatment. Paxlovid is a co-packaged, nirmatrelvir tablet and ritonavir tablet for oral use to assist with the treatment of COVID-19 in adult and pediatric patients with positive SARS-CoV-2 testing1. The nirmatrelvir inhibits the SARS-Cov-2 protein to stop the virus whereas the ritonavir slows down the breakdown of nirmatrelvir to help it remain in the body for a longer period.
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