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MedTech Outlook | Friday, August 19, 2022
Medical device development is a multi-stage process, generally with five main stages.
FREMONT, CA: Developing a medical device is a complex process constantly becoming more complicated. Apart from the increasingly stringent regulatory needs that must be met for FDA approval and/or EU MDR compliance, medical device manufacturers must also navigate ongoing changes across the industry, including the rise of connected devices within the Internet of Things (IoT).
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Making it from initial device discovery and conceptualization to FDA clearance and launch strategy requires a dedicated team and a risk and requirements management strategy backed by modern tools. Without those solutions in place, the high costs and major risks of developing a modern medical device become more challenging:
The average development cost under the Food and Drug Administration's Premarket Approval (PMA) program is $94 million. However, the less strict 510(k) path is still a considerable sum – $31 million.
• Product recalls are higher-priced. A McKinsey study approximated the cost of these events at as far as $600 million. Indirect losses from decreased market cap and lost revenue can run into billions of dollars.
• Medical device security is also leading in the age of the IoT. Internet connectivity can reveal devices to cyberattacks, and the healthcare industry is regularly among the most targeted sectors.
To account for the relevant challenges and zero in on corresponding solutions, let's look at the process a medical device must go through before reaching patients.
The five stages of developing a medical device
Medical device development is a multi-stage process, generally with five main stages.
A sample process – defined by the FDA itself – proceeds as follows:
Stage 1: Device Discovery and Concept
The classification of the potential device will greatly impact the product development process and necessary risk management procedures.
For instance, Class I devices are subject only to general controls like good manufacturing practices and recordkeeping requirements. In contrast, higher-risk Class II and Class III devices require additional special controls and PMA, respectively. Consequently, risk management is more complex for Class II and III devices, with higher associated costs.
Stage 2: Preclinical Research and Prototyping
The device isn't suitable for human use but is ready for testing in controlled laboratory environments. Noticing the prototype's performance under these conditions provides some early insights into how people might use it and what specific risks might accompany it.
Stage 3: Pathway to Approval
The device's classification/risk level will decide the subsequent steps.
A Class-I device such as an oxygen mask has to comply only with general controls, and many devices in this low-risk Class are exempt from any premarket submissions. However, Higher-risk Class II devices, such as pregnancy test kits, must adhere to special controls, like meeting device-specific performance criteria, on top of those general controls.
Non-exempt Class-I and Class II devices need a 510(k) Premarket Notification proving "substantial equivalence" with a legally marketed device that isn't subject to PMA. If such equivalence can't be proven, the device is placed into Class III.
Class III devices – including those nonequivalent, along with devices that sustain or support life – require PMA, which is the most complex part of developing a medical device. First, scientific evidence must be submitted showing that the device's benefits outweigh its risks and will help a significant portion of the population.
Stage 4: Regulatory Review
Once a medical device company has adequate data on how its device performs and the associated risks, it can apply for regulatory review. The accurate process will vary by device classification/risk level.
PMA applications involve a thorough review of the laboratories and facilities for production for good manufacturing practices and an evaluation of the results of related clinical and nonclinical studies. Other processes are simpler.
Stage 5: Post-Market Device Safety Monitoring
After the device achieves the market, it will be constantly monitored for possible safety and performance issues. Regulatory bodies may examine manufacturing facilities again, while consumers and medical professionals can report any issues seen through programs like MedWatch in the U.S. This would be the stage after a recall would be commenced, if applicable.
Throughout all five stages, development teams will require to maintain many different documents, including design history files for each finished device. To ascertain that their work stays on track and complies with key regulatory standards like ISO 13485, ISO 1497, and EU MDR provisions, it makes sense to create a single source of truth that supports scalable, efficient requirements management.
Updating requirements management for modern medical device development
Offering a medical device's compliance can be complex. Traditional document-driven models are not perfect for this purpose, as they can involve many discrete spreadsheets and files that take a long time to retrieve, review, and organize. The incompetence of these workflows also complicates the traceability of development activities back to demands.
In contrast, a concentrated platform with all key information in one place can offer clearer insight into design controls for device needs and related risks. In addition, teams can use Jama Connect to gain real-time visibility into how design inputs have been met and verified, providing essential evidence from the design control process for better-informed decision-making and a more efficient overall development process.
Defects can also be detected earlier and more dependably, curbing the risk of non-compliance and recalls.
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