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Risk Management and Corrective Action: Identification, Transfer, Monitoring, and Mitigation Risk Management and Corrective Action: Identification, Transfer, Monitoring, and Mitigation

Risk Management and Corrective Action: Identification, Transfer, Monitoring, and Mitigation - PowerPoint Presentation

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Risk Management and Corrective Action: Identification, Transfer, Monitoring, and Mitigation - PPT Presentation

Presented by Duane Huffman ASQ CRE Sponsored By 3 HTi LLC PTC Reseller Systems Integrator www3hticom Booth 4709 What Is Medical Device Risk Management Medical Device Any equipment used to diagnose ID: 810777

management risk amp quality risk management quality amp review control analysis design capa plan process medical product windchill systems

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Slide1

Risk Management and Corrective Action: Identification, Transfer, Monitoring, and Mitigation

Presented by: Duane Huffman, ASQ CRE

Sponsored By:3 HTi, LLCPTC Reseller / Systems Integratorwww.3hti.com Booth # 4709

Slide2

Slide3

What Is Medical Device Risk Management?

Medical Device:

Any equipment used to diagnose,

treat, or monitor patient

health

Mechanical

Systems

Electronic

Systems

Software

Systems

Patient Impact

Operator Impact

Impact on others in the environment

Impact on

equipment

itself

/ other

equipment

Design

Use

Deliver

Disposal

Service

Manufacture

Test

All systems of a medical device must be analyzed for

potential risk

to patients, operators, others, and the equipment. This analysis must consider each part of the product development lifecycle.

Slide4

Risk Management Standards

Global Harmonization Task Force - SG3/N17/2008

ISO 14971Quantitative Risk AssessmentRequired in EUGuideline for “Best Practices” in US

Recognized by FDA to obtain regulatory approval

FDA, CDRH

Pre-Market Approval of certain devices requires a Risk Management File documenting Risk Management process

Risk Management File also used in support of audits

Standard

Description

ISO 14971

Defines risk management requirements

for safe, reliable medical devices

IEC 60601

Defines required safety

standards for electromedical equipmentISO/TR 80002Applies ISO 14971 to medical device software development and maintenance

21CFR Part 11Defines medical device software requirements for data security and integrity21 CFR Part 820

Requires quality policies and audits, including CAPA to investigate, correct, and prevent nonconformances.

Slide5

Defining Risk Management: ISO 14971

Risk management is the systematic application of policies,

procedures

, and practices to the task of analyzing, evaluating, controlling, and monitoring the risk inherent in medical devices

.

Standards-Driven:

Each risk must be compared to pre-defined standards of

acceptability

Iterative:

Each

new risk must be fed back into risk analysis, evaluation, and

control

Documented:

Each step must be fully recorded for the risk management file

Continuous:

Risk management must

continue through planning, design, development, testing, manufacture, use, and disposal of medical device

Slide6

Slide7

Phase 4

Control Risk

and monitor effectivenessof controls

Phase 3

Evaluate Risk

Phase 2

Identify and Analyze

Risk

Phase 1

Define Acceptable

Risk

Risk Management for Medical Devices:

ISO 14971

Step 7. Production and Post-Production Monitoring

Step 3. Risk Evaluation:

Evaluate estimated level of risk for acceptability/ unacceptability based on Risk Management Plan

Step 2. Risk Analysis:

Identify RiskEstimate Risk Level (a quantitative process)

Step 1. (ISO 14971) Risk Management Plan: Define acceptable & unacceptable levels of risk

Step 4. Risk Control:Analyze Control Options, Implement Controls,

Evaluate Residual Risk, Risk/Benefit Analysis, Review Effects of Controls, Review Completeness

Step 5. Overall Residual Risk

Step 6. Risk Management Report

Risk

Assessment

Unacceptable Risks Found?

Slide8

Methods for Risk Management

Risk Management Activity

Risk/Reliability Analysis ToolsRisk Identification & Analysis

FMEA (Failure Mode & Effects

Analysis)

Fault Tree Analysis

Risk Estimation

FMEA

Fault

Tree Analysis

Reliability Prediction

Advanced System Modeling (OpSim)

Risk Control Measures:

Analyze

Implement Evaluate

Risk/Benefit Analysis Review New Risks Completeness of Control MeasuresFMEA & Fault Tree Analysis

Reliability PredictionAdvanced System Modeling (OpSim)

Production & Post-Production Monitoring

FRACAS (Failure Reporting, Analysis, and Corrective Action System)Weibull

(Life Data Analysis)

Slide9

Slide10

Software Tools /

Relationships

Integrated Process

Outputs

Product Lifecycle Stages:

Inputs

D

P

Control Plans

Functions

Process Sequence

BOM

Effect = Effect

Severity = Severity

Cause = Mode

DFMEA Effect =

Risk Matrix Cause

DVP

Requirements

Production Planning

Detailed Design

Product Definition

Complaints

Slide11

11

Integrated Risk Management

Hazard Analysis

Hazards

Hazardous Situations

Risks

Causes

Controls

Parameter Diagrams

Functional Inputs

Functional Outputs

Hazards

Controls

Functional Hierarchy

Identify primary systems and functions

Establish Project

Define Acceptable Risk

Identify Intended Use

Harms

Hazard / Harm Tree

Generate DVP (Test Plan) against Functions / Risks

Risk Matrix

Complaints System

Requirements

Slide12

12

D

Design FMEA and Test Plan

DVP

Windchill / Relex BOM Integration

DFMEA

Slide13

13

PFMEA, Control Plans, Work Instructions

P

PFMEA to Control Plan

DFMEA to PFMEA

Dashboard Metrics to track performance

Slide14

Slide15

Audit quality

processes

Nonconforming

Product

Identify CAPA

procedures

Design

Controls

Quality Management in Medical Devices:

21 CFR 820

21 CFR 820.30

Establish design and development process

Include design Inputs, outputs, V&V, change, transfer

Establish and Maintain Design History File for each product

21 CFR 820.22

Establish audit procedures to ensure compliance with quality policy ,

Include responsibility, results of re-audit, audit report, and review

21 CFR 820.100

Identify causes of non-conformances and other quality problems Document actions taken to correct and prevent their recurrence Verify and document the effectiveness of the CAPA process

Document Control

21 CFR 820.40Document approval and distribution activities Apply Change control

21 CFR 820.90

Control of nonconforming product, segregation & dispositionNonconformity review and disposition authority

Document rework and reevaluation

Maintain Complaints files

21 CFR 820.198- Receive, review, and evaluate complaints – including verbal complaints

- Document procedures for processing, evaluating for reporting to FDA

Slide16

Nonconformance Management

Storyboard Overview

Intake

Investigation

Start

Evaluation

Disposition Plan

End

2

.

0

3

.

0

4

.

0

1.

0

Quality

MRB Review

5

.

0

Disposition

6

.

0

Evaluation - Define Investigation and Disposition activities

2

.0

Investigation

3

.0

Disposition

Plan

4

.0

MRB Review

5

.0

Rapid Nonconformance Capture

1

.0

Perform

Disposition

6

.0

Slide17

Complaints & Customer Feedback

Storyboard Overview

Intake

Execute Activity Plan

Start

Evaluation

Review

End

2

.

0

3

.

0

4

.

0

1.

0

© 2013 PTC

Quality

Complaint Intake

1

.0

Evaluate, Triage, Define Follow-up Activity Plan

2

.0

Execute Activity Plan

Return Product Analysis

General Follow-up

Regulatory Safety

Reporting

3

.0

Review Final Codification and Escalate to CAPA

4

.0

Slide18

Management Review Reporting

Storyboard Overview

Access Master Page

Setup Data Monitor

Start

Save Report

Review Reports

End

2

.

0

3

.

0

4

.

0

1.

0

Quality

Access Master Pages for any Quality Records

1

.0

If you want to run a report again you can save the criteria in a saved report

2

.0

Schedule Saved Reports or Setup Data Monitors to look for critical conditions

3

.0

Review Reports

4.0

Slide19

Windchill

MPMLink

WinchillQuality

Solutions

Windchill

PDMLink

Product / Process Quality and the PDS

A sample workflow across PDS roles and processes…

©

2011

PTC

Engineering

Manufacturing

Quality/Regulatory

Change & Configuration Mgmnt

Manufacturing Process Mgmnt

Design Validation & Postmarket Study

Corrective / Preventive Actions

Complaints & Nonconformances

Detailed Design

Receive Adverse Event

Initiate CAPA / Perform RCA

Validate Change

Make Product Design Changes

Make Process Design Changes

Close Change Request

Confirm Design Changes

Monitor Effectiveness

A Closed-Loop Process

Create Action Plan

Slide20

Process Quality with

Windchill Quality Solutions and PLM

Benefits:

© 2006 PTC

CAPA

Customer Experience Management

Regulatory Submissions

Supply Chain

Nonconformances

Change Management

Service Manuals / Instructions

Training Records

BOM

Engineering Calculations

CAPAs can be initiated from other PDS sources

Automatic flow-down of CAPAs through PDS

Windchill PDM & Process Modules:

Leverage core PLM

Windchill Quality Solutions:

Manage Process Quality

Slide21

Slide22

Issue Capture through Call Center with History Lookup

Warranty and Repair Tracking

Customer Support and Quality Investigations

Windchill Quality Solutions: Process Workflow

Verify Corrective Action

Initiate New Request

Record Data Sources

Identify Product Involved

Evaluate, Assign Issue

Determine Need for CAPA

Investigate Root Cause

Plan, Perform Corrective Action

Customer Experience Management

CAPA

Risk Analyses

Access Related Quality Inputs

Identify Root Cause

Create & Approve CAPA Action Plan Send ECRs to PLM System

Confirm and Verify Effectiveness

Identify Risks requiring Corrective Action

Escalate Risk to a Problem

Route to Approvals

Ad Hoc Reporting, Reports and Watchdogs

Slide23

CAPA (Closed Loop)

© 2008 PTC

Storyboard: Key Topics

Submit CAPA Request

1

.0

Root Cause Analysis

3

.0

CAPA Request

CAPA Review

Root Cause Investigation

1

.0

2

.0

3

.0

CAPA Plan

4

.0

End

Implement

5

.0

Confirm

6

.0

Verify Effectiveness

7.

0

Start

Implement Actions

5

.0

4

.0

Verify Effectiveness

7

.0

Confirm

6

.0

Review Data & Interrogate Lessons Learned. Determine if meets criteria for Preventive Action or Corrective Action

2

.0

CAPA Plan

Slide24

Revision

control and data stewardship

5

.0

Unique Device Identification

Storyboard Overview

Collection of Data

Review & Approvals

e-signature

Start

Creation

FDA Submission

End

Ongoing Change

&

Configuration

Mgmt

Regulatory Affairs

2

.

0

3

.

0

4

.

0

1.

0

5

.

0

PLM

Systems

ERP

Systems

Home Grown Systems

MDM

Systems

Doc & Labeling

Systems

Product “Specs”

Collection

of Products &

key UDI attributes

from Disparate

systems – Automatic bulk Creation of UDI Objects & Initiation of Workflows

1

.0

© 2013 PTC

UDI Creator applies final edits

to refines UDI submission then submits for approval

2

.0

Generate HL7 SPL,

submit

to FDA Electronic Submissions Gateway (ESG

) – Monitor Acknowledgments

4

.0

E-Signature and review/approval workflows

3

.0

Slide25

What is eMDR in Windchill CEM?

Addressing the FDA Proposed Ruling in Windchill CEM (Customer Experience Mgmt)

© 2008 PTCFDA rule that all Medical Device Records (MDRs) be submitted electronicallyThe proposed rule was published in the Federal Register on August 21, 2009 Mandated at the end of 2011 (+ 1 yr grace period

)

Ruling will become effective one year after final rule publishes in the Federal Register

What is an MDR?

Reporting of device-related adverse events by manufacturers, importers, users (hospitals, etc.)

Traditionally performed by 3500A MedWatch form sent via email or fax

How does Windchill CEM handle it?

eMDR Regulatory Reporting engine maps CEM fields to eMDR report; routes for review, editing, and approval; submits electronically to FDA and stores received messages with record

Slide26

Surgisense specializes in the design, development, testing, manufacturing, and marketing of innovative new technologies for medical devices.

Surgisense focuses on developing the next generation of “smart” sensing surgical instruments and medical devices to further enhance surgery, patient care, and patient safety

.Business Drivers:FDA Compliance for Medical DeviceSolution: Windchill Quality SolutionsDocuments

Backbone - Manage & Control all key documents AKA Document Control

Products Backbone - Provide Control of Product information AKA Design Control, DHF, DMR, BOM and BOO

Quality Backbone – Quality Activities & Processes interact with the Anchor Points for Products and Processes

3 HTi, LLC,

the authorized PTC reseller

implemented

Windchill Quality Solutions and Creo Design Software to streamline Surgisense product development process.

Slide27

Thanks for Your Time

For More Information:3 HTi, LLC

www.3hti.cominfo@3hti.com866-624-3HTi 609-303-3400