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kak33 replied to the topic Management: Continuous Improvement in the forum Quality Systems Management 7 years ago
In addition to internal audits to improve quality, my company also hosts internal kaizen trainings for various process to make continuous improvements. I have never heard of a kaizen until I joined this company but it is the Japanese word for “improvement”. In business, kaizen refers to activities that continuously improve all functions and…[Read more]
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kak33 replied to the topic Management Responsibility in the forum Quality Systems Management 7 years ago
From my experience in the industry, this is a common problem in many departments. I’ve seen departments over loaded with work and the quality of the work that they are able to accomplish decreases. Sometimes people feel rushed and make mistakes. Sometimes people may try to cut corners.
Additionally when teams are over loaded with work and r…[Read more] -
kak33 replied to the topic FDA Considering Updating Quality System Requirements in the forum Quality Systems Management 7 years ago
The FDA anticipates publishing a proposed rule early in 2019 on aligning the two. The FDA was instrumental in the revision of ISO 13485, most of the Part 820 regulation requirements are covered in ISO 13485. However, there are some requirements that might not be included explicitly in ISO 13485, for example Device History Record (FDA Part…[Read more]
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kak33 replied to the topic Improving GMPs in the forum Quality Systems Management 7 years ago
My company performs a yearly review of our manufacturing practices. However, I did find a publication by the NSF about changing your quality culture and improving GMP behaviors. It steps the reader through identifying what needs to be changed, what works and doesn’t work, and what motivates people. Additionally, it describes a unique five-step b…[Read more]
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kak33 replied to the topic Process Revalidation in the forum Process Validation and Process Risk 7 years, 1 month ago
I think it can get tricky when talking about process revalidation and what is required to qualify the equipment to be used in the process. In my opinion, I don’t think you would need to revalidate the process in EVERY situation that you are relocating equipment. For example, if you are relocating a PC used in a predominately manual process, t…[Read more]
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kak33 replied to the topic CAPAs: Proactive vs Reactive in the forum Process Validation and Process Risk 7 years, 1 month ago
I think we can all agree that it is better to be proactive in MOST, if not all situations for the best interest of the business. I think it is also important to note that by definition one of the intentions of a CAPA is to prevent. I think it is up to the event owner/investigator and MRB to ensure that due diligence has been done to scope out the…[Read more]
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kak33 replied to the topic Technical Writing Skills in the forum Process Validation and Process Risk 7 years, 1 month ago
I feel that my undergraduate career prepared me to write technical reports more than protocols. I am confident in my writing abilities, however, I still feel like it is always a good idea to get an independent person to review your work.
In my short time in the industry, I’ve found that older engineers that have been in the industry for a while s…[Read more]
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kak33 replied to the topic Standard Operating Procedures (SOP's) in the forum Device Documentation 7 years, 2 months ago
I think a SOP should be used during the research phase but if not, I think it MUST be used during development. This way the engineers would be able have some sort of traceability to know that the processes used and design elements used during research to know that whatever is transferred are equivalent. For example, at my job we wanted to change…[Read more]
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kak33 replied to the topic SOP: how much detail before too much detail? in the forum Device Documentation 7 years, 2 months ago
In my experience, I add as much detail as possible to SOPs such that there is no room for interpretation because our processes are so tightly controlled. For example, right now I am developing a process to create Master and Vendor CD to ship to duplication vendors for software, media, or customer communication artwork. Much of the process would…[Read more]
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kak33 replied to the topic Does your company use ECOs? in the forum Device Documentation 7 years, 2 months ago
I currently work as a manufacturing engineer at a medical device company. My team is responsible for maintaining the on market device. We use DCPs (Design Change Process) to make any changes to the device, including labeling. People who join our team from other companies really thing that our process is more tedious and elaborate. Recently the…[Read more]
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kak33 replied to the topic Documents that are equivalent to a DSD in the forum The Design History File 7 years, 2 months ago
My company doesn’t fill out a DSD. However, we do maintain a traceability matrix that shows all of the verification and validation activities completed for each design input. I think the level of up front detail that is presented with a DSD is very helpful to document necessary information required to effectively define product design and give t…[Read more]
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kak33 replied to the topic Discussion Topic: Verification vs. Validation in the forum The Design History File 7 years, 2 months ago
I currently work in manufacturing and I see a lot of instances when a design and process needs some form of verification or validation. We use verification activities to test and confirm that product meets the specific requirements of the defined instructions. Typically we have in process checks to verify that specifications have been met during…[Read more]
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kak33 replied to the topic Discussion Topic: Is the DHF a living document? in the forum The Design History File 7 years, 2 months ago
I understand the idea of using the DHF as a living document to detail design and development plans and deliverables. However, at my company, once the product has been transferred, the DHF is sealed and any changes must be implemented via design change activities according to FDA Design Control regulations. From my understanding of regulation,…[Read more]
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kak33 replied to the topic Discussion Topic: Easier regulatory in EU? in the forum EU Regulatory Basics 7 years, 2 months ago
I found this article that relates to the topic. It digs a little deeper as to WHY it actually takes so long go get devices approved in the US. According to the article, Innovative medical devices take significantly longer to gain approval from the U.S. Food and Drug Administration because of administrative hurdles, rather than unfamiliarity with…[Read more]
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kak33 replied to the topic CE TECH File Vs 510(k) submission differences in the forum EU Regulatory Basics 7 years, 2 months ago
Another notable difference is with post-market clinical follow-up. For the FDA, PMCF is only required for the highest risk devices. For CE Marking, however, all product families are required to have evidence of post-market clinical follow-up studies or a justification for why post-market clinical follow-up is not required.
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kak33 replied to the topic Classification in FDA Vs EU in the forum EU Regulatory Basics 7 years, 2 months ago
There are differences in regulatory approach between the EU and the U.S.. Therefore; there are differences in device classification and we can not assume that meeting the requirements for the U.S. market would satisfy the EU requirements. Another example of a medical device that is classified in US and EU differently is hospital beds. According to…[Read more]
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kak33 replied to the topic Primary Mode of Action (PMOA) in the forum Introduction to Advanced Medical Device Development 7 years, 3 months ago
Beyond identifying a combination, I wanted to touch upon some of the challenges that surface when understanding the classification, and jurisdiction of these products. Common challenges include legal issues, marketing, premarket, post market, and cross labeling. Legal issues arise because there currently statutory or regulatory standards for…[Read more]
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kak33 replied to the topic Marketing Strategy- The fifth 'P' in the forum Introduction to Advanced Medical Device Development 7 years, 3 months ago
I am not very familiar with my companies marketing strategies. However, I do think we use a participation approach. At one of our all employee meetings last year a representative from the ER department of one of the largest hospitals in Ottawa came to speak. They hosted a 6 month trial with the use of our device and described their success, their…[Read more]
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kak33 replied to the topic Discussion Topic: Your Field or Profession in the forum Introduction to Advanced Medical Device Development 7 years, 3 months ago
I currently work for a Point of Care medical device company. My company focuses on the hand held type instead of the larger models. Based on my understanding of the market, PoCT is slow to launch new test types because the amount of overhead and the new product would have to offer substantially different capabilities than what is on the current…[Read more]
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kak33 replied to the topic Discussion Topic: Course conclusion and impressions in the forum Consultants and Legal Basics 7 years, 4 months ago
I think this course was very relevant and valuable. I currently work for a medical device company, so it was cool to see how things I do in practice aligns with regulation and applies to general concepts. I didn’t have the opportunity to Co Op during my undergraduate career, so I had no idea what the corporate word would be like for medical d…[Read more]
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