With the development of a medical device, how do you best
achieve a balance between time to market, cost savings, and regulatory
compliance?
Joe Rotino
VP of RA/QA, Acting VP of Engineering, Pro-Dex Inc.
Approaching product development through the lens of Concurrent Engineering is
what enables Pro-Dex Inc. to achieve a balance between accelerating time to
market, cost-efficiency, complying with all regulatory requirements, and
delivering a superior quality product.
The most important part of this process is bringing in
representatives at the very start from all the cross-functional teams within
engineering, regulatory affairs and quality assurance, manufacturing,
procurement, and business development to assess the full scope of the project.
Each of these disciplines have their own needs and concerns
related to the development and manufacture of the product, so it’s important to
get multiple perspectives up front.
For example, the procurement team is concerned with what
materials are needed and the availability of them. Engineering will be looking
at material types, tolerancing, and part requirements. RA/QA is interested in
elements that could affect the final product, its classification, and
registration. Manufacturing needs an understanding of tooling and fixtures,
setups, and required programming.
Bringing these multidisciplinary insights together from day
one allows the team to create a plan with cost, compliance, and speed to market
in mind as well as effectively execute that plan, meeting project requirements,
schedules, timelines, and budgets.
W. Stephen Beversluis
Director, QA & Regulatory Affairs & Business Development, Precision
Medical Products Inc.
The medical device development process is a very detailed step by step approach
that can take an idea from concept to reality. Needless to say, it is very
important for development teams to spend the time and effort to balance “time
to market, cost savings, and regulatory compliance”. This ensures a successful
product launch that will enable your device to provide the quality of life that
you developed it for.
That being said, it is crucial that quality and regulatory
compliance take precedence over time to market and cost savings. Short cuts
taken on items required by the regulatory bodies or decisions driven by lower
cost in the end may negatively impact your success and, possibly, the health
and well being of the individual(s) being treated.
If you plan your development process intelligently and
follow the quality system requirements for design and development wisely, you
can achieve your time to market goals and be successful.
Rick Gallisa
Industry Director, Life Sciences, Apriso Corporation
When considering how to best balance time to market, cost savings, and
regulatory compliance, I would propose that design is clearly the leading
contributor. Design for efficacy is paramount; however, design for
manufacturing is the critical factor for time to market, cost savings, and
compliance.
Traditionally, the medical device industry innovated
products with modest concern about cost, anticipating that sufficient operating
margins would more than offset R&D, costly manufacturing, and compliance
costs. But, given increasing regulatory and global competitive pressures, this
strategy is simply no longer viable.
In my role at Apriso, I see an industry with pervasive focus
on manufacturing excellence. This starts with design, but quickly enters
technology transfer from R&D, pilot operations, and manufacturing scale up.
That funnel of activities dictates what efficiencies will be validated into
structured and compliant production operations.
Many of our customers are taking a hard look at their
manufacturing processes to address these pressing issues. They are putting
sophisticated systems in place to manage costs while realizing benefits, such
as accelerated new product introduction, resulting from greater consistency in
their business and manufacturing processes. Embracing this type of strategy
results in higher quality and lower costs—the balance required for
profitability.
Steve Raiken
President, RENY
Traditionally, the medical device injection molding paradigm has been prototype
then production. This has meant aluminum molds for product development, then
transfer to a manufacturing group who will oversee design and procurement of
production class A molds and validation activities.
With "speed to market" becoming more important to
improving ROI, companies are increasingly overseeing R&D efforts with
manufacturing and quality engineers. Questions are being asked, "How can
we combine the prototype, production, and validation process?"
The answer lies in hybrid "prototype to
production" injection molding. Or the use of modular hard steel components
to build standard size cavity insert sets that facilitates faster production mold
building and validation. For years, the software industry had been writing each
piece of code as a new project. Then along came C++, which allowed a programmer
to use building blocks from a library of tested code. But these libraries tend
towards specialized application. The molding industry must change from being
everything to everybody to specialization. A few companies are specializing
only in medical molding. RENY has been refining this concept. Because we are
solely in the medical device industry, we focus on the complete development
cycle of a medical device. And we have developed modular tooling systems,
pre-planning the validation requirements. Using hard steel milling to
manufacture hard tool steel inserts that are then assembled into a standardized
base results in a production mold that can be production validated while
assembly methods are being developed. Being vertically integrated with
cleanroom molding on-site allows for ready feedback between mold maker and
molder.
Using modular tooling blocks reduces the time and cost to
market and increases reliability by using tested designs and pre-manufactured
components. Hybrid molding does provide a complete solution from prototype to
production.
James Wilson
Principal, Continuum
There are a few key things necessary to achieve this
delicate balance. Three critical ones are:
Early collaboration with downstream partners—The
market, supplier pricing, and regulatory approval are not within your control.
The steps to pass regulatory requirements must be factored into the schedule
early on; to mitigate risk, test as early in the process as possible.
Create a realistic business plan—If it’s a new
product, don’t count on mature market pricing at launch; your partners are
likely to price for market risk unless you compensate them otherwise. Have
contingency funding available to keep valuable and non-contingent efforts going
if time to market is a high priority and other aspects of the program get hung
up in a period of uncertainty.
Design for success—Identify the differentiation
that matters to the people that use, sell, service, prescribe, or train people
on your product. That is your must have. Assess your regulatory path and tweak
things that don’t compromise the differentiation but improve time to market and
spend the least amount of time on cost reduction. Get the right product out fast.
Cost-savings can be iterated after release with additional time to
analyze/optimize design solutions.
John J. Smith, M.D., J.D.
Partner, Hogan Lovells US LLP
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Understanding how FDA regulates your medical device is crucial to balancing
time to market, cost, and regulatory compliance for a new product. In
situations where the regulatory pathway or data necessary to support clearance
or approval is uncertain, or if clinical or extensive preclinical data may be
needed, seeking agency feedback via the pre-IDE process is an important step
after a design is finalized and proof of principle established. Sponsors need
to be willing to adapt their marketing or regulatory strategies based on FDA
feedback, as it’s often necessary to modify the product or to seek stepwise
clearances to achieve an ultimate goal. Even where no prior discussion with the
agency seems necessary, sponsors need to be realistic with their marketing
submissions and be prepared for surprises in the form of extensive requests for
additional information or a prolonged review process. Simply put, careful
planning, good communication with FDA, flexibility, and a certain amount of
pragmatism are all part of making the process as efficient as possible.