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Consultancy

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I have supported clients in the following areas:

 

Validation

 

Companies in the life science sector must comply with standards and regulations that include validation requirements.

Validation projects often take longer than expected.  The reasons for these delays can be;

·Protocol and report writing and approvals

·Managing unforeseen changes

·Addressing deviations

·Compiling all the evidence.

 

Validation reports should remain in an audit-ready state.  Startups and SMEs may not have a Validation Engineer, and it can be helpful to have intermittent support. My background in validation, quality management and statistical knowledge is advantageous in this area.

 

Validation of computer software used in the QMS

Medical Device Startups are juggling the pressure of designing products alongside the development of a quality management system.  I have noted that validation of computer software used in the Quality Management System is a requirement often forgotten about.  This requirement is included in both ISO 13485:2016 and 21 CFR Part 820.70.  See references below.  This includes software applications used for the design and development of products, complaint handling, CAPA, calibration, maintenance, doc control, testing, labelling, stock control and any other applications used in the quality Management System. If you require validation support, I can advise how to categorise by software type, intended use and level of risk and in turn it is possible to determine the level of verification and validation required.

 

ISO 13485 was updated in 2016 and includes a new requirement in Section 4.1.6 The organisation shall document procedures for the validation of the application of computer software used in the quality management system. Such software applications shall be validated prior to initial use and as appropriate, after changes to such software or its application. The specific approach and activities associated with software validation and revalidation shall be proportionate to the risk associated with the use of the software. Records of such activities shall be maintained (see 4.2.5).

21 CFR 820.70 (i) Automated processes. When computers or automated data processing systems are used as part of production or the quality system, the manufacturer shall validate computer software for its intended use according to an established protocol. All software changes shall be validated before approval and issuance. These validation activities and results shall be documented.

 

Validation of Sterile Packaging - ISO 11607-1 & ISO 11607-2

ISO 11607 was updated in 2019 in an effort to harmonise the standard with the new EU MDR, and further updates are being discussed.  My background in sterile barrier solutions enables me to support clients with their sterile packaging validations.  The FDA list ISO 11607-1 and ISO 11607-2 as recognised consensus standards for medical devices.

 

ISO 11607-1 covers the requirements and methods for testing the sterile barrier systems and packaging systems required to keep terminally sterilised medical devices sterile until the point of use. 

ISO 11607-2 covers the requirements for validation of processes by manufacturers to ensure the sterile barrier systems for the medical devices work as intended and keep devices sterilised until their use.

 

ISO 13485:2016 section 7.5.7 already details requirements to validate processes for sterilisation and sterile barrier systems and refers to ISO 11607-1 and ISO 11607-2

Processes for sterilisation and sterile barrier systems shall be validated before implementation and following product or process changes, as appropriate. Records of the results and the conclusion of validation and necessary actions from the validation shall be maintained. NOTE Further information can be found in ISO 11607-1 and ISO 11607-2.

 

Between 2021 and 2022, I supported a medical device manufacturer over an eight-month period with their sterile packaging validation against the requirements of ISO 11607-1 and ISO 11607-2 as part of their EU MDR remediation project; this included stability testing.  Stability testing is an area that is often overlooked.

SiMD & SaMD

Software as a medical device (SaMD) and Software in a medical device (SiMD) are the two main types of medical software reshaping the medical device sector and have the potential to impact the lives of millions of people.

Medical device software manufacturers must define and document the design and development process, and notified bodies check these requirements.

I have supported medical device startups designing and developing SiMD and SaMD (medical device wearables) through their ISO 13485:2016 stage 1 and stage 2 certification audits.  One of the biggest challenges for medical device start-ups is providing the documentation and records required to satisfy the requirements of standards and regulations such as FDA 21 CFR section 820.30,  ISO 13485 section 7.3, ISO 14971:2019 and IEC 62304:2006 + AMD1:2015. 

Lab Proficiency Testing  

Laboratory Proficiency Testing.  Participation in proficiency testing is an essential independent verification of the lab's performance.   I can explain the calculations behind the various scores clients receive from their proficiency test providers, including;

·     Z score

·     Zeta score

·     En score

·     Z prime

Clients find it helpful to understand that the result (score) is not just down to the input from your lab but will also be influenced by the other participating test labs and the proficiency test provider.  

I demonstrate how labs can check their results using appropriate statistical calculations and share helpful ways to trend them.  I believe it is essential for labs to verify these scores and to plug the data into the formula to double-check the result. 

Did you know that data from proficiency testing can also be used as part of the estimation of measurement uncertainty?

Trending of Results

A simple control chart is just a chart of the results over time.  Control charts are valuable tools for monitoring and analysing laboratory or production floor results. However, some statistics knowledge is required to determine trends within the data.   

 

Various control charts are available, and I help companies select the appropriate charts for their requirements and develop control limits. 

Quality Control charts are also used as part of test method validation and method comparison, estimation of measurement uncertainty, detection limits, checking the drift of equipment, comparison or qualification of personnel, and evaluation of proficiency tests. 

As with anything else, it's essential that you select the correct chart for your requirements and that you justify its use; otherwise, daily stacks of paper or computer-generated charts are churned out and possibly ignored.

The most common questions/statements I encounter are;

  • How do I pick a control chart?

  • Where do the limits come from?

  • How do I understand the trends, and how far do I go with corrective action?

  • We have always had control charts, but we're uncomfortable showing them to customers/auditors. 

Let me know if I can help demystify control charts.

Quality Contractor

I have supported clients as a contractor covering the following areas;

  • Complaints

  • CAPA

  • Internal audits 

  • Estimation of measurement uncertainty

  • Product, process and machine validation.   

This support can be provided part-time with some flexibility around the weekly hours.  

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