This blog talks about design review, another important part of design control. Design Project Plan shall schedule when to have the design reviews. Design review is an important milestone in the design process of medical device.
Should
there be a minor upgrade to an existing device, may be a single review is
warranted.
For
a whole project or a substantial changes to an existing device, several design
reviews are warranted. Design review must be done logically, in detail and be
recorded.
The second portion
shall review design verification phase and the review purpose is to ensure
design input meets design output requirements and perhaps to finish continuing
risk management and to review the design output.
The last portion of
the review should deal with the completion of production trial runs and design
validation. The purpose of this portion of design review is to ensure the
device meets user and production requirements. An evaluation of the final risk
management report is also be reviewed.Of course, the above
sequence of design review is just a suggestion.
The project manager can decide
what portion of design review can be started based on priority or need. For
example, for more complex design, the project manager can schedule additional
design reviews to ensure the design review was done in focus, thorough and in
compliance.
How about Label and
Document Review? A review of the label and document should also be part of the
design review. A review of the labeling include manuals, instruction for use,
chart, package insert and labels and they should all be reviewed
methodologically and ensure to be compliant to all pertinent guideline like 21
CFR 820 and ISO 13485, for example.
The portion of this review may be part of
the Final Design Review. This can be a separate review because it may involve a
wider range of participants like regulatory affairs, finance and marketing.
After all the documents are reviewed, they will be released in the Device
Master Record.Project manager
should have a Design Review Checklist (DRC) to identify the project and the
phase being reviewed, the date, time, place, the participants, the review
topic, any documents reviewed and outstanding action items. DRC should be
distributed prior to the meeting to ensure participants prepare for the review.
Depending
on the review topic, participants should involve project manager, process
engineering, quality assurance, regulatory affairs, marketing and consultants etc.
Results
of design reviews are recorded in minutes of the meetings prepared. Examples of
the record includes:
·
Copy
of the agenda for the meeting.
·
Place,
date, time and list of participants with their name and signatures.
·
Disposition
of outstanding action items and the actions necessary to resolve them. Detail
of disposition is warranted.
·
Notes,
results and conclusions for each reviewed item,
·
Requested
corrections and changes, and actions necessary to implement them,
·
Approvals
and consents with signatures and date.
·
Risk
Analysis Report.
·
Engineering
Drawings and Specifications.
·
Clinical
Trial Report.
·
Instruction
For Use.
Finally,
all records pertain to design reviews are placed into the Design History File
both hardcopy and softcopy.
Reference
|
Criteria
|
21 CFR 820.30(e)
|
Does
the company establish and maintain procedures to ensure that formal
documented reviews of the design results are planned and conducted at appropriate
stages of the device's design development?
|
21 CFR 820.30(e)
|
Do
the procedures ensure that participants at each design review include
representatives of all functions concerned with the design stage being
reviewed and an individual(s) who does not have direct responsibility for the
design stage being reviewed, as well as any specialists needed?
|
21 CFR 820.30(e)
|
Are
the results of a design review, including identification of the design, the
date, and the individual(s) performing the review, documented in the design
history file (DHF)?
|
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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