The
blog is about design output, another important part of design control. Another
concept that should be remembered is
Design Inputs = Design
Outputs
There
should be a procedure to handle how to deal with design output. Product design
output consists of documents, samples, models, math data, software, testing
results, specifications etc., that specify the device and its manufacturing,
packaging, labeling, installation, and servicing; as well as product acceptance
criteria. The following categories of specifications are typically, but not
limited to be included in design output:
·
Product
specifications,
·
Assembly
Drawings,
·
Specifications
for purchased products,
·
Manufacturing
process specifications,
·
Packaging
specifications,
·
Labeling
specifications,
·
Installation
specifications,
·
Work
Instructions,
·
Software
Code,
·
Quality
Assurance Specifications and Procedures,
·
Maintenance
and servicing specifications,
·
Bioburden
test results,
·
Biocompatibility
test results,
·
Result
of Risk Analysis,
·
Product
acceptance criteria (purchased, in-process and final)
Design
output documents are included in the Device Master Record (DMR). DMR is a compilation
of all records that contains procedures and specifications of a FINISHED
product.
Per
FDA Section 21 CFR 820.181 which states that “Each manufacturer shall maintain
device master records”, therefore DMR is part of a requirement.
Design
output is expressed in terms that can be verified against design input
requirements. Design verification will be blogged later.
Design
output documents are reviewed and approved before release during intermediate
and final design reviews.
Verification that
design output meets the design input requirements is important. When such
verification involves calculations or other engineering methods, it is carried
out as a design verification activity. When it is a more qualitative evaluation
and can be conducted by a design review meeting.
Ensure that individual
design output documents are complete, correct, and are not in conflict with
each other. A designated associate shall carry out this checking activities.
Results
of reviews carried out by the design review meetings are documented in minutes
of the meetings. Results of other reviews and verifications are documented by
signoffs on the reviewed documents, memos and reports.
There
should be a project manager to oversee all the design control activities. He or
she must approve and release design output documents.
Before
approving the documents, the project manager verifies that all required reviews
have been carried out with satisfactory results, and completes the reviews.
Design
output documents are controlled. Their establishment, review, authorization,
issue, distribution, and revisions are carried out in accordance with procedures which handle Control of Documents
and Device Master Record.
Approvals
of design outputs are evidenced by the project manager dating and signing the
Document Change Order releasing the design output documents. Then the
manufacturer has a finished product until there are changes which warrant
another update of the DMR and slightly change the medical device. The whole or
partial process is repeated.
Reference
|
Criteria
|
21 CFR 820.30 (d)
|
Has the company
established and maintained procedures for defining and documenting
design output in terms that allow an adequate evaluation of conformance to
design input requirements?
|
21 CFR 820.30 (d)
|
Do
design output procedures contain or make reference to acceptance criteria and
ensure that those design outputs that are essential for the proper
functioning of the device are identified?
|
21 CFR 820.30 (d)
|
Is
design output documented, reviewed, and approved before release?
|
21 CFR 820.30 (d)
|
Is
the approval, including the date and signature of the individual(s) approving
the output, documented?
|
Disclaimer:
Although
the author had exhaustively researched all sources to ensure the accuracy and
completeness of the information contained in this blog, but no warranty and
fitness is implied. I assumed no responsibility and implied warranty of any
kind for errors, inaccuracies, omission, or any inconsistency herein. No
liability is assumed for incidental or consequential damages in connection with
the use of the information contained herein. Readers should always use their
own judgment and review all related regulatory guidelines. Guidelines can
change over time.
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