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Design Control Guide Outline (1 of 2)
Page 4 Product Commercialization Process (PCP)
Page 5 Core Team and Product Approval Committee
Page 6 Core Team and PAC Contract Summary
Page 7 Core Team and Extended Team
Page 8, 9,10 Project Contract Example
Page 11 PCP Deliverables
Page 12 Types of Design Control Reviews
Page 13 Decision to Investigate (DtI)
Page 14 Decision to Commercialize (DtC)
Page 15 Design Control Purpose & Benefits
Page 16 Quality Management System (QMS)
Page 17 Design Control Regulatory Standards
Page 18 Design Control Deliverables Comprising eDHF
Page 19 Design Control Procedures
Page 20, 21, 22 Content of eDHF Deliverables
Page 23 Triple Constraint
Page 24 Verification Deliverable Requirements
Page 25 Verification vs. Validation
Page 26 Validation Deliverable Requirements
Page 27 Design Review
Page 28 Design Review Occurrences
2Design Control Guide
Design Control Guide Outline (2 of 2)
Page 29 Design Review Record for eDHF
Page 30 Design Transfer
Page 31 Process Validation
Page 32 Validation Protocol
Page 33 Validation Report
Page 35 Change Control
Page 36 Design History File
3Design Control Guide
Product Commercialization Process (PCP)
4Design Control Guide
Dtl
Decision to Investigate
•CONCEPTPHASE
Decision to Commercialize
•DEFINITION PHASE
SDC Start Development
Checkpoint
•DEVELOPMENT PHASE
SMC Start Manufacturing
Checkpoint
•MANUFACTURING
PHASE
CTC Confirmation test
Checkpoint
•CONFIRMATION PHASE
PRC Product Release
Checkpoint
•COMMERCIAL PHASE
PCC Project Closure
Checkpoint
•LESSSONS LEARNED
PCP governs how products are executed.Passing DtI or DtC is not committing to commercializing a new product.
Core Team and Product Approval Committee Product Approval Committee (PAC)
o Clearly-defined decision makers with domain experience
o Govern effective resource allocation
o Manages the development pipeline
o Selects Core Team Lead
• Core Team
• Small and cross-functional and manage their extended team members
• Posses effective communication and coordination
• Product development project focus with clear responsibility and authority
• Each Core Team Member represents extended team members having depth of technical knowledge
• Core Team Lead & Program Manager
• The Core Team Lead is responsible for the deliverables of the Core Team and manages the program
• Selects the Core Team Members
5Design Control Guide
Core Team Lead
Quality Assurance
R&D ManufacturingProduct
DevelopmentEngineering
Core Team & PAC Contract Summary
Project Parameter Target Variance
Key Performance Requirement 1 8 runs/day ≥6 runs/day
Key Performance Requirement 2 95% call accuracy >90% call accuracy
PRC Date OCT 2019 4 weeks
COGS Target $4,500 <$6,000
Resources 25 FTEs 15%
3 Year Revenue $78M 20%
Project Cost $8.9M <$10M
6Design Control Guide
Core Team operates according to agreed upon project contract with the PAC.
Core Team and Extended Team
7Design Control Guide
Core Team Lead
Quality Assurance
R&D Manufacturing Product Management
Engineering
Data Integrity
Regulatory
Trade Compliance
Supplier Quality
Hardware Design
Software Design
Research
Verification
Planning
Purchasing
Packaging
EHS
eBusiness
Marketing
Legal
Finance
Engineering
Training
Technical Support
Validation Distribution
Manufacturing
Sales
The Core Team facilitates nimble and quick decisions led and documented by the Core Team Lead.
Project Contract Example (1 of 3)Attribute Phase Review DtC
EstimateSDC Commitment
SMC Commitment
CTC/PRC Commitment
PCC Analysis
COSTS Concept $84K - - - -
Definition 122K (+38K) $71,500 $71.5K $71.5K -
Development TBD $230,863 $230.9K $276K -
Manufacturing TBD $75,625 $75.6K (±14K) $30.3K -
Confirmation TBD - - - -
Sales TBD $9,625 $9,625 (+1K) $1.3K -
Total Cost N/A $387,613 $387.6K $379.3K -
REVENUE Volume @ YR1 1,241 755 755 (-113) 755 (-113) -
YR1 ASP $260 $379 $379 (-$57) $379 (-$57) -
YR1 Margin 70% (±15%) 75.7% 76% (-11%) $75.7% (-11%) -
YR1 Revenue 323K (±195K) $286,145 $286K (-28K) $286K (-28K) -8Design Control Guide
Project Contract Example (2 of 3)Attribute Phase Review DtC
EstimateSDC Commitment
SMC Commitment
CTC/PRC Commitment
PCC Analysis
SCHEDULE DtC 03/20/2012 03/20/2012 03/20/2012 03/20/2012
SDC 11/06/2012 (+12 weeks)
03/5/2013 03/5/2013 03/5/2013
SMC n/a 06/11/2013 08/27/2013 08/20/2013
PRC n/a 10/31/2013 11/5/2013 11/5/2103
PCC n/a - 11/25/2013 11/25/2013
QUALITY CTQ1 Notes 1
CTQ2 Notes 2
CTQ3 Notes 3
9Design Control Guide
Project Contract Example (3 of 3)Attribute Phase Review DtC
EstimateSDC Commitment
SMC Commitment
CTC/PRC Commitment
PCC Analysis
RESOURCES Prog Mgt 0.05 (+0.02) 0.1 (+0.05) 0.1 (+0.05) 0.1 (+0.05) -
Prod Mgt 0.05 (+0.02) 0.1 (+0.05) 0.1 (+0.05) 0.1 (+0.05) -
R&D 0.58 (+0.2) 0.9 (+0.1) 0.9 (+0.1) 0.7 (+0.1) -
Man 0.03 (+0.01) 0.1 (+0.05) 0.1 (+0.05) 0.1 (+0.05) -
Quality 0.01 (+0.01) 0.1 (+0.05) 0.1 (+0.05) 0.1 (+0.05) -
Eng 0.03 (+0.01) 0.1 0.1 0.1 -
Total FTE/mo - 1.3 (+0.3) 1.3 (+0.3) 1.1 (+0.3) -
NPV 5 yr NPV $ - 224,553 224.6K 262.3K -
10yr NPV $ - 818,565 818.6K 912.1K -
10Design Control Guide
PCP Deliverables
11Design Control Guide
Decision to
Investigate
CONCEPT Decision to
Commercialize
DEFINITION Start Development
Checkpoint
DEVELOPMENT Start Manufacturing
Checkpoint
MANUFACTURING Confirmation Test
Checkpoint
CONFIRMATION Product Release
Checkpoint
COMMERCIAL Project Closure
Checkpoint
Program Management Project Charter
Risk Assessment
Intellectual Property
Position
Management Review
Integrated Project Plan &
Integrated Schedule
Product Requirements
Management Review
Management Review Management Review
Management Review
Management Review
Management Review
Product Management Business Plan
Customer Wants
Customer
Requirements
Design Review
Field Test Plan * (Alpha
and Beta)
User Documentation
Plan*
Management Review
Marketing Plan* Field Test Report (s) Marketing Materials
(Web, Hardcopy)
Development Technology
Assessment
Design Review
Product Specifications
Trace Matrix
Consolidated Test Plan*
Product Development
Plan*
Design Review
Verification Plan
Verification Protocol
Design Review
Verification Report
Design Freeze
Consolidated Test
Report*
Product Development
Report*
Validation Plan
Validation Protocol
Validation Report
Design Review
Operations Operations Plan* Operations Report*
Design Review
Quality & Regulatory Quality Plan*
Regulatory Plan*
Risk Management Plan*
Clinical Evaluation Test
Plan*
Risk Management
Report*
Clinical Evaluation
Test Report
Certificate of Analysis
Regulatory
Submission
Service & Support Service and Support
Plan*
Types of Design Control Reviews
12Design Control Guide
PHASE REVIEW
The purpose of the Phase Review is for a PAC to determine if the project team has completed the requirements to exit the current phase and its readiness to enter the next Phase. The Phase Review date is requested by the Core Team.
EXCEPTION REVIEW
The purpose of the Exception Review is a structured interaction between a Core Team and the PAC when the contract boundaries are violated or are likely to be violated. The Exception Review date can be requested by either the Core Team or the PAC.
UPDATE REVIEW
The Update Review is a review between a Core Team and a PAC if the 2 parties identify a need to meet even if the project is within the boundaries of the contract. The Update Review is requested either by the Core Team or the PAC.
DESIGN REVIEW
The purpose of the Design Reviews is to review technical details of the program with the Core Team, extended team, and at least one Independent Reviewer. A summary of the Design Review is given at the next Phase Review.
Decision to Investigate (DtI)
13Design Control Guide
R&D and Product Manager Lead Questions:
Customer Need-What is the hypothesized customer need (define the problem)?
Market Drivers-What market space does the customer need fit into?
Business Drivers-Comment on the strategic fit of this customer need.
User Centered Innovation (UCI)-plans to confirm the hypothesized customer need, market size, growth, and share.
Internal Technology- Do existing or potential technologies exist in development that could be applied?
Gap Analysis- What are the gaps between current technologies and the hypothesized customer need?
Baselining-Do baselining plans coincide with the User Centered Innovation Collection? What are the experimental plans & goals proposed between now and DtC/Decision to Commercialize?
Resources- What are the resource needs?
Schedule- What is the integrated schedule?
Decision to Commercialize (DtC)
14Design Control Guide
Core Team Questions:
1. Do we have the resources and skill sets required to execute the proposed solution?
2. How does the plan fit with the business strategy?
3. Does this plan outline sufficient financial return?
4. How are top priority customer needs reflected in the business plan within the proposed technology?
5. Are the underlying product technologies feasible and available to use?
6. What components of the solution have already been commercially developed?
PAC Questions:
1. Is there a strategic, financial, and technical fit?
2. What assumptions drive profitability in the financial model and was finance involved?
3. What customer input do you have that validates the customer requirements driving your financial assumptions?
4. What infrastructure and resources are needed to execute?
5. Does this program still make sense and what is the level of importance?
6. What is the regulatory pathway for this program?
Design Control Purpose and Benefits
15Design Control Guide
Purpose of Design Control:
1. The purpose od the design control subsystem is to control the product design process to assure devices meet user needs, intended uses, and specified requirements.
2. Design Control provides a common based approach to the development process which all products can follow.
Benefits of Design Control:
1. Customer satisfied with product appropriate for its intended use and meeting requirements.
2. Regulatory body satisfied.
3. Product delivered on time and repeat work minimized.
4. Efficient production processes..
5. Design History File can resolve post-launch identified issues.
6. Speedy execution with roles and responsibilities clearly defined.
7. ISO certification maintained.
8. Successful customer audits.
9. Facilitate regulatory approvals.
Quality Management System (QMS)
16Design Control Guide
Change Control
Design Control
Corrective & Preventive
Actions
Material Controls
Facility Controls
Production Controls
Customer Feedback
Design Control is part of the QMS
Design Control Regulatory Standards
RUO Products:
• ISO 9001• ISO 13485
IVD Products:
21 CFR 820 ISO 13485 CE Marked ISO 14971 IEC 62304
A Design History File (eDHF) is created based on the regulatory standards.
17Design Control Guide
Design Control Deliverables Comprising eDHFDesign & Development Planning
Design Input Design Output
Design Reviews
Risk Management
Design Verification
Design Validation
Design Transfer
Design Changes
eDHF Index & PAC Review Records
Integrated Plan & Schedule
Customer Requirements
Product Specifications
Definition Phase Review
Risk Management Plan
Design Verification Plan
Design Validation Plan
Operation sReport
References to Design Change Records
eDHF
Product Development Plan
Product Requirements
Traceability Matrix
CR Review Risk Management Report
Design Verification Protocol
Design Validation Protocol
Product Development Report
Document Approval matrix
PAC Review Records
Operations Plan PR Review Hazard Analysis Template
Design Verification Report
Design Validation Report
Consolidated Test Report
Regulatory Plan Development Phase Review
dFMEA Field Test Plan
Quality Plan Design Verification Review
pFMEA Field test Report
Service & Support Plan
Manufacturing Readiness Review
Software Hazard Analysis
Clinical Evaluation Test Plan
Consolidated Test Plan
Manufacturing Validation Review
Clinical Evaluation Test Report
Design Control Guide 18
Design Control Procedures
Guidance Documents Procedures
Risk Management Procedures
Business Plan Integrated Project Plan and Schedule
Product Risk Management
Risk Management
Marketing and Launch Planning
Design Reviews Design Transfer Product Risk Management
Pre-Launch & Launch
Traceability Matrix Software Development Lifecycle
Hazard Analysis Work Instruction
Field Test Sites Product Approval Committee (PAC) Reviews
Electronic Design History File (eDHF)
Design/Use/Process FMEA
Design Verification & Validation
Customer Requirements, product Requirements, & product Specifications
Roles & Responsibilities
Product Commercialization Process
Product Risk Management
Design Control Guide 19
Content of eDHF Deliverables (1 of 3) INTEGRATED PROJECT PLAN:
Activities & Tasks Planned PCP Phases
Planned PCP Deliverables
Identify all planned exceptions and deviations
Interfaces Key meetings and attendees
Points of contact between various groups
Resources Core Team and key extended team members
Major equipment/materials needed for the development effort
SCHEDULE: Only high level project milestones and decision points to avoid constant updating of the plan.
Field Test Plan: The plan must identify the scope and purpose of testing, how the information will be used, and identify the customers and sites.
USER DOCUMENT PLAN: A plan for all the labeling material needed (user’s manual, product insert)
PRODUCT SPECIFICATIONS: Translation of the Product Requirements into end device; describes how the product satisfies the design input requirements in the Product Requirements.
TRACE MATRIX: The tractability from CR to PR to PS with a reference to the Verification & Validation reports and any Risk Mitigations.
20Design Control Guide
eDHF Documents Content (2 of 3)
CONSOLIDATED TEST PLAN: This plan includes all planned evaluation activities; when testing will occur; who is responsible for testing; the scope of the testing; and it may consider verification testing, validation testing, stability testing, EMC/Electrical Safety testing, reliability testing, Shiping testing, Field Testing, and Clinical Testing.
PRODUCT DEVELOPMENT PLAN:
Planned Design Characterization and optimization activities;
Planned Design Reviews and their Scope
Key Development Extended Team members and their responsibilities
High level development milestones
Planned development iterations
If multi-sites are participating, what is expected form each site
Major equipment and materials needed for the development effort
PRODUCT DEVELOPMENT REPORT: captures results of the design characterization and optimization activities
OPERATIONS PLAN: Where will the product be made; Who are the critical suppliers; Who will create the DMR; How many will be built; How many will be built; How will the product be qualified; What are the dependencies; What information does Operations need from R&D or a successful transfer; How will the product be scaled up.
QUALITY PLAN: What Quality System will be followed; How will suppliers be qualified; Development team training plan;Quality metrics; Quality sustaining activities.
21Design Control Guide
eDHF Documents Content (3 of 3)
PRODUCT SPECIFICATION (PS):
Consumables: Formulation; Chemical Properties; Kit configuration; Volumes
Instruments: Optical Properties; Electrical properties; Material Properties
Software: Screen Layout; Navigation; Algorithms
Design Inputs and Outputs
22Design Control Guide
CR PR PS DMR
Verificaton Deliverable Requirements
Verification Test Plan
Traceability Matrix
Verification Protocol
Verification Report
Traceability Matrix
24Design Control Guide
Verification vs. Validation
25Design Control Guide
Verification Validation
Verify detailed requirements and specifications Validate use needs and intended use
Acceptance criteria found in PRs and PSs Acceptance criteria found in CRs
Production intent design: Design frozen and documented
Production intent design: DMR complete
Units do not have to be built by production Units built by production using final process
Verificaton: A detailed examination of aspects of a design at various stages in the development.
Validation: A cumulative summation of all efforts to assure the design will conform with user needs and Intended use, given expected variations in components, materials, manufacturing processes, and the use environment.
Validation Deliverable Requirements
Validation PlanTraceability
MatrixValidation Protocol
Validation Report
Traceability Matrix
26Design Control Guide
Design ReviewA Design Review is a systematic assessment by experts of a specific design to:
Ensure that requirements have been captured correctly;
Identify and resolve technical issues;
Examine alternative designs and provide recommendations;
Provide feedback to designers on existing or potential problems;
Ensure the design is able to meet requirements, specifications, and standards;
Ensure the design has been transferred correctly;
Confirm the activity or phase has been completed in an acceptable manner and the next activity or phase can begin.
Design Control Guide 27
Design Review Occurrences
Design Control Guide 28
CR & PR Review Product Development Review
Design Verification Review
Design Validation Review
Manufacturing Readiness Review
Are Product Requirements Clear
Are design decisions likely to meet the product requirements
What issues did verification uncover
What issues were found during he Design Validation
Does manufacturing have all the information they need to start pilot production
Are there any conflicts in the requirements
What design alternatives have been considered
How will issues be resolved
How will issues be resolved
Have all the PS items been transferred to the DMR
Have tradeoffs been resolved
How can the design be improved
Is the product designed to be manufacturable, reliable, and serviceable
What issues have been found from preliminary testing
Are test procedures known and adequate
Design Review Record for eDHF
Type of Design Review
Date
Participants and their roles including an Independent Reviewer, Moderator, and Meeting Minute Keeper
Identification of Issues
Action Taken until the design addresses the design criteria
Issues Resolved
Signatures
Design Review Record with closure of action items are placed in DHF
Design Control Guide 29
Design Transfer
Ensure the device design is correctly translated into production specifications
Link between the design team and manufacturing
Ensures items in the PS have been implemented in the DMR
The design team reviews, approves, and issues product related documents
Manufacturing:
Reviews, develops, & issues supplemental process related procedures
Validates the manufacturing process and reduces variation
Produces the product
Design Control Guide 30
Process ValidationValidation
Process
Validation Plan (VP)
Equipment Qualification
Performance Qualification
(PQ)
Operational Qualification
(OQ)
Installation Qualification
(IQ)
Process Validation
Test Method Validation
Design Control Guide 31
Process Validation means establishing by objective evidence a process consistently produces a result or product meeting its predetermined specifications.
Validation Protocol Scope
Identify Requirement Number
Acceptance/Passing Criteria
Sampling Plan
Templates
Operating Conditions
Test Method Validation
Equipment Qualification
Statistical Analysis
Training Requirements
Methods to document any deviation form the plan and who would need to approve the deviation
Design Control Guide 32
Validation Report Materials and Methods
Summary of deviations and their impact
Identification of the design
Configuration of the design
Equipment
Dates of validation of activity
Traceability and manufacturing records (Device History Record)
Training documents
All paper and electronically generated result information
Statistical analysis
Do results meet pre-determined acceptance criteria
Storage of raw data
Conclusion and recommendations
Design Control Guide 33
Change Control Formal process in which changes to equipment, system, procedures, processes proposed by
staff planning them.
Changes justified and documented
All design changes verified and validation.
Reviewed by qualified representatives
Specified reviewer determines verification or validation requirement
Changes communicate through training
With Class III (PMA) devices, after initial FDA approval and launch most changes require a Regualtory Submission and approval before implementation.
Design Control Guide 34
Design History File Design History File (DHF)/electronicDHF (eDHF) contains the evidence Design Controls
were implanted
Documents in the DHF must be approved
Approval order is important:
Plans approved prior to activities occurring
Design Inputs approved before Design Outputs
Inputs and Outputs approved before verification
Test plans approved prior to initiation of testing
Deliverables approved in the phase required by the PCP and the Integrated Project Plan and Schedule
Design Control Guide 35