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BN5208

Biomedical Quality and Regulatory Systems

Mrinal Kanti, PhD


Department of Biomedical Engineering
National University of Singapore

Email: biemkm@nus.edu.sg
Office: E1-05-24
My bio…

Ph.D: Biomedical Engineering; University of Texas Medical


School in San Antonio

Senior Research Scientist: New York State University


Medical School (SUNY), Brooklyn, NY

Consultant, Medical Affairs/Information, Johnson and


Johnson, APAC and ASEAN Regional office in Singapore

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What this module is about:
In this module we will dive deep into regulatory and other
related aspects on medical devices.
Each lecture will have its own learning objectives and
outcomes as well as take home messages.

What this module is not about:


This module is not about pharmaceutical regulation…

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Suggested Text Books/Readings

1. Handbook of Medical Device Regulatory Affairs in Asia


Author: Jack Wong.
Publisher: Taylor and Francis
2. Global marketing authorisation of biomaterials and medical devices
Author: Tobin JJ.
Publisher: Woodhead Publishing
Module’s Global Objectives:
In this module you will learn:
• Introduction to the regulatory profession
• Role of the regulatory professional
• Medical devices vs. Medicinals
• FDA classification of medical devices
• How medical devices are regulated in some countries including US, EU
and Singapore (we will also touch upon other countries)
• Medical device development process
• Approval of medical devices
• Quality system regulation and Quality management systems (QMS)
• Documentation and risk analysis of medical devices
• Commercialization of medical devices
• Ethics and medical devices
• Being in the shoes of a medical device regulatory professional

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Learning Outcomes

After completing this module students should be able to:


1. Understand and analyse the medical device development process from design to post
market obligations
2. Comprehend the various risk-based classification strategies adopted in various
countries
3. Identify and understand the various 'Ethical' contexts as relevant to medical devices
4. Critique and discuss various case studies, including on safety, quality management
and post market obligations for medical devices
5. Demonstrate and evaluate the qualities needed to be a good medical device
regulatory professional

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Week Topics covered Comments
1 Introduction, what is and what is (not) a medical device, Role and characteristics of a Regulatory professional
2 Project discussion, FDA classification of medical devices, FDA classification of Tissue Engineered product Elearning through Zoom

3 Guest lecture by Industry expert Elearning through Zoom

4 Med device regulation in other jurisdictions (Singapore, EU)

5 Project management, Ethics in device regulations (case studies) Gp presentations 1-3

6 Conformity assessment, AI in medical devices Gp presentations 4-6

Recess week No lectures

7 Commercialization of medical devices, audits, Gp presentations 7-9


Post market obligations and processes; surveillance and vigilance
8 Quality system regulation, compliance and risk analysis and management, product recall Gp presentations 10-12

9 Medical device development process , Approval of medical devices, global regulatory strategy; Gp presentations 13-15

10 NUS well being day No lectures

11 CA Quiz (MCQs and open book)

12 Presentation

13 Presentation and Report submission (Please verify through Turnitin)

• Timetable subject to change


• Presentation topics will be disclosed the week before, thus all teams will have about the same amount of time to prepare. Gp
presentation to be 10-12 minutes.
• Teams would consist of 4 members, please choose your team members and we will finalize next lecture
• From now on lecture slides will be uploaded few days ahead of schedule so that you may do some self reading ahead of time
100% CA, No final Exam…
This module is 100% Continuous Assessment (CA) for
ongoing formative learning
• Active class participation: 10%
• Peer assessment: 10% (to discourage non-contributing-peers and encourage
team learning)
• Post lecture discussions: 10% (including ethics case study discussions)
• CA quiz (open book): 40%
• Final report: 20 %
• Final project presentations: 10%

Teaching-learning format
• 1-1.5h of lecture followed by group presentations/case studies
• I will upload the topic few days in advance (latest by Tuesday), so that you have
sufficient time to prepare
• Absolutely NO memorization…but you must have the fundamental concepts
clear…hence all ears, eyes, brain (essentially all senses) during lecture and tutorials…
Other housekeeping stuff…

Numerous avenues to ask questions and clarify doubts and


get instant feedback:
• During the lecture itself if you have a question on a particular slide being
discussed
• During the mid-lecture break
• After the lecture
• Through e-mails…
• Extra help and office consultations with appointment

Whenever I introduce a new term/word, I do define and explain it, but none-the-less
if you think you are not yet clear and want to discuss more, you are welcome to seek
further explanation…

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At the end of this lecture
you should be able to:

• Define medical device


• Appreciate the wide variety of medical device
• Identify major sectors and top companies of the medical
device industry
• How they are different from pharmaceuticals/medical
products
• Define regulatory affairs
• Evolution of regulatory profession
• Define the scope of the profession, what medical device
regulators do…

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Medical devices

Examples of some
common medical devices:
• Prosthetics
• Heart valves
• Cardiovascular stents
• Catheters
• Contact lenses

Just to name a few…

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Which of these are (not) medical devices…

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How can we make your cell phone a medical device…???

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Are bioreactors medical devices…???

But before that what


exactly is a bioreactor…

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Definition
‘Medical device’ means any instrument, apparatus, machine, appliance,
implant, in vitro reagent or calibrator, software, material or other similar
or related article:

…. And

which does not achieve its primary intended action (function) in or on


the human body by pharmacological, immunological or metabolic means
…but which may be assisted in its intended function by such means

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…. specific purpose(s) of:

• diagnosis, prevention, monitoring, treatment or alleviation of disease or


compensation for an injury

• investigation, replacement, modification, or support of the anatomy or of


a physiological process, …

• supporting or sustaining life,

• disinfection of medical devices,

• providing information for medical or diagnostic purposes by means of in


vitro (IVD’s) examination of specimens derived from the human body

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Top device companies
Company ~Market Cap ($B) Device type HQ location
262 Various New Brunswick, NJ
60 Various Chicago, IL
59 Various Minneapolis, US
30 Orthopedics Dublin, Ireland
36 Various Deerfield, IL
32 Surgery Dublin, Ireland
47 Diagnostics Waltham, MA

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Why regulate medical devices ?...The Billion
($$$) dollar question…

We regulatory medical devices to ensure:


1. Safety
2. Efficacy
3. Quality
4. Performance

Intended to safeguard the health and safety of:


• Patients
• Medical professionals
• Manufacturers

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Medical devices go through a complex and long process
from conceptualization to marketing and thereafter either
for therapeutic or diagnostic use.

This module acts as a lexicon for medical devices and takes


you through a journey into their regulation and life cycles

• Med devices are significantly different from medicinals


• Combination products and are regulated through a
different and more complex pathway.

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Rationale for Regulatory Guidance

• Consistent harmonised definition of term “medical


device” for use in global regulatory model
• Benefits to manufacturer, user, patient, regulatory
authorities
• Support global convergence of regulatory systems
• Eliminating differences allows patients earlier access to
new technologies and reduces costs of regulatory

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Medical Devices and Medicinals:
How do they differ?
Mode of action defines and distinguishes a
medicinal/medical product and a medical device

• If the primary mode of action is pharmacological or


metabolic it is a medical/pharmaceutical product or a
drug and if the primary mode of action is by physical
means it is a medical device

Converging medical technologies: The distinction becomes more


complex and more important as “borderlines” become less distinct with
new technologies

Medical Medicinal
Device product/Drug

This gap is gradually decreasing with advent of new technologies… 22


Medical Devices Medicinal/medicines
Product nature Pure molecules; based on
Physical objects; complex components and pharmacology and chemistry; now
assemblages; encompassing biotechnology,
generally based on mechanical, genetic engineering, etc.
electrical, and materials engineering
Most act through physical interaction Administered by mouth, skin, eyes,
with body or body part lungs, or by injection; act through
metabolic, pharmacologic, or
immunologic means
Localised “site of action” treatment Typically systemic effect
effect
Duration and nature of exposure Short half-life in body
varies widely
Typically durable; available for study Consumed by use
after use
Focus on biocompatibility of Focus on systemic and local toxicity
materials
Relatively limited populations of Large populations of exposure
exposure
Not metabolized… Most undergo ‘first pass’ mechanism
Medical Devices Medicinal/medicines
Heterogeneous group; range from Tend to differ only in molecular
tongue depressors to artificial hearts structure, active site, and mode of
Application/action
Technologies, forms, and modes of Usually in forms of pills, solutions,
action very diverse aerosols, or ointments
Industry composition Very large multi-national companies
Over 80% small and medium sized dominate
enterprises
Few “generic” devices Significant “generics” industry

Intellectual property concerns Extensive R&D of a specific


Continuous innovation and iterative molecule; many years for new drug
improvements based on new to enter product pipeline
science, new technology, and new
materials
Short product life cycle and Intensive patent protection needed
investment recovery period; little due to long product life cycle
patent linkage possible and long investment recovery period
Medical Devices Medicinal/medicines
Product development Discovered in lab-based research
Invented and designed; often with processes
involvement of physician users
Designed to perform specific Development by discovery and trial
functions
Regulatory approval on basis of Regulatory approval on basis of
safety and performance safety and efficacy
Constant iterative design and Stable formulation
process changes over product life
Short market life (~ 18-24 months) Long market life

Use and post-marketing Patient may choose to stop use


Most intended for professional use
Device malfunction Drug interactions

Use error Wrong drug or dose

Adverse events most often local in Adverse events may be widespread


nature
In vitro diagnostic (IVD) medical
device
In Vitro Diagnostic (IVD) medical device’ means a medical device,
whether used alone or in combination, intended by the manufacturer
for the in-vitro examination of specimens derived from the human
body solely or principally to provide information for diagnostic,
monitoring or compatibility purposes”

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In vitro diagnostic (IVD) medical
device

IVD medical devices include reagents, calibrators, control materials,


specimen receptacles, software, and related instruments or
apparatus or other articles and are used, for example, for the
following test purposes: diagnosis, aid to diagnosis, screening,
monitoring, predisposition, prognosis, prediction,
[or]determination of physiological status.”

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What do regulatory professionals do…

• Play pivotal roles in all aspect of product development from


conceptualization, product lifecycle, clinical trials, to post approval and
even post marketing

• Keep track of ever evolving regulatory landscape

• Advisory on all legal and scientific aspect of the medical device including
collecting, collating and evaluating scientific data eventually leading to an
approved product ready for market

• At times the connecting link between various departments

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Challenges for the Regulator

• Breadth of product offerings


– Impact of Specialization
– Keeping Up with Technology
• New burdensome regulations
– New Laws and the Downstream Impact on Hiring
Regulators (POLITICS!)

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Challenges for the Regulator…

• Many masters
– From the inside (e.g. R&D, Mfg.), RA/QA = “The police”
– From the outside (e.g. the Regulators) , RA/QA = “The
crooks”
– From management, RA/QA = “What Do We Do Next?”,
“Delays”?
• Each device is different and requires a unique approach
• Released products don’t go away; need constant
revisions

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The Regulated Component

• Integrate Regulatory Requirements early in the


Process!(talk to regulators early)
• Technical File = summary of design history and
evaluation
• Reporting
– Post Market Surveillance (PRO-ACTIVE vs RE-ACTIVE)
– Vigilance
– Field Safety Corrective Actions

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The Regulated Component…

• Sales & The Customer


– Reimbursement
• Reporting to Competent Authority
– Complaints
– Feedback (different than Complaints!)
– Injuries (Vigilance)
– Recalls
• Marketplace Awareness

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The Regulated: SME vs. MNC

• Unique personality for each


– SME: implementer, jack-of-all-trades
– MNC: “caretakers”, specialized
• As much on knowledge as it is on personality
and soft skills

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The Regulated: Life in MNCs

• System already established


• Role is as a caretaker
• Resources of a large department
• Likely single/few product lines
• Focus is on following a “recipe”
• Specialization

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The Regulated: Life in SMEs

• Create Management Systems from scratch


• Often working alone and without a net
• Focus is on establishing a precedent
• Multi-disciplined; likely to have overlap with other
department(s)

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… And Then, the Day-to-Day?
• Rely on your systems
– Personal
– Professional (e.g. networking)
– Organization
• Familiarization, never Memorization!
– Rely on the Supporting Documents
• Conservative Personality Traits
– Consider Impacts on Public Health (Ethics !)
– Consider Impact on Organization (profitability !)
• Aggressive Personality Traits
– New technologies
– Project Costs & Deadlines

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Some take home points:
• Medical devices interact mechanically with a patient to affect a cure or
diagnose a condition
• Johnson and Johnson is the largest device company in terms of market
capitalization
• Lack in regulatory oversight may result in device failure and other ethical
and legal issues
• Safety, efficacy, quality and performance are critical consideration of
device success
• With advent of new technologies the distinction between medicinals and
medical devices are becoming more important
• Accessories are components of medical devices
• For a regulatory professional product and regulatory knowledge is as
important as personality and soft skills

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References:
• https://www.fda.gov/

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