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Is There Innovation in Regulatory Affairs?

  • 1.  Is There Innovation in Regulatory Affairs?

    Posted 24-May-2016 16:16

    I am planning a RAPS Chapter event around Innovation, and in the process find myself asking these questions. Please chime in and share your thoughts!

    • What is innovation?
    • Do you consider yourself an innovator?
    • Are innovators the antithesis of regulatory professionals?
    • Is there a need for innovation in regulatory strategy & thinking?
    • Do regulations hold back innovation?
    ------------------------------
    Lena Cordie
    Qualitas Professional Services
    Watertown MN
    United States
    ------------------------------


  • 2.  RE: Is There Innovation in Regulatory Affairs?

    Posted 24-May-2016 17:19

    I think of "innovative" devices modifications to existing devices, i.e., 510(k) devices, "novel" devices are new devices, i.e., De novo and PMA devices.

    I don't think anything is holding back innovation.

    ______________________________

    "Everywhere I go, I'm asked if I think the universities stifle too many aspiring young writers.  My opinion is that I don't think they stifle enough of them."  --Flannery O'Connor

    ------------------------------
    Julie Omohundro, ex-RAC (US, EU), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com



  • 3.  RE: Is There Innovation in Regulatory Affairs?

    Posted 25-May-2016 11:26
    Edited by Michael Chellson 25-May-2016 11:27

    GREAT QUESTION Lena!

    One of the limitations in the RA profession is a proclivity towards "How we've always done it".

    Just as Technical advances in healthcare and International regulatory requirements evolve daily, so should our approaches to compliance as a professional paradigm.

    Regulation creates a "WHAT Box" we must operate in, it does not limit our creativity and innovation as to "HOW" we will structure processes, decision making, and documentation to meet the WHAT of regulation. As a profession we must "get out of the box" and crate novel ways to meet regulatory requirements.

    There is always a (INSEAM) Innovative, Novel, Simple, Easy, And, Manageable way to devise and implement controls and documentation to support regulatory requirements. And it usually is NOT "The way we've always done it." 

    To that end, YES, I consider myself an innovator.

    ------------------------------
    Michael Chellson
    RAC



  • 4.  RE: Is There Innovation in Regulatory Affairs?

    Posted 26-May-2016 10:04

    In my experience, the "How we've always done it" mindset can be found everywhere; as can the alternative.  I haven't found RA to be especially more or less inclined to it than other areas.

    ------------------------------
    Julie Omohundro, ex-RAC (US, EU), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com



  • 5.  RE: Is There Innovation in Regulatory Affairs?

    Posted 26-May-2016 10:19
    Michael,

    "As a profession we must "get out of the box" and crate novel ways to meet regulatory requirements."

    Your statement is intriguing!

    May I ask what life and professional experience, etc. have shaped your thinking leading to making the statement?

    Thank you.  

    s/ David
    ______________________________________________
    Dr. David Lim, Ph.D., RAC, ASQ-CQA 
    Phone (Toll-Free): 1-(800) 321-8567



    "Knowledge is power only when it is practiced and put into action." - Regulatory Doctor

    NOTICE: This communication (including any attachments) may contain privileged or confidential information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this communication and/or shred the materials and any attachments and are hereby notified that any disclosure, copying or distribution of this communication, or the taking of any action based on it, is strictly prohibited.





  • 6.  RE: Is There Innovation in Regulatory Affairs?

    Posted 27-May-2016 08:47
    David,

    Very early in my career, (just starting actually) I was fortunate to have a true "Mentor" as a Boss.  He was a backwoods boy from Mississippi with a pronounced southern drawl.

    After one very contentious meeting with Marketing & Product development on the path to market for a new device, he and I retreated to his office.
    He closed the door...Leaned back in his chair...and looking off into space (not directly at me) said:

    "Mike, It's very easy to say NO."

    And with that dismissed me to go about our duties..

    Perplexed, I noodled that for a while and eventually came to understand his wisdom. 

    RA is a complex arena, and it requires little thought or creativity to say, "No you can't do that.", but requires a willingness to think and innovate to find a pathway to YES.  While sometimes convoluted, there is usually a way to get to YES.

    My inherently frugal nature drives me to pursue the INSEAM (Innovative, Novel, Simple, Easy, And, Manageable)  path, (emphasis on EASY).

    This perspective creates "Partnerships" with RA, who will then be viewed as a facilitator, rather than an obstacle.  Not only does this speed product innovation, but ensures early consultation in projects and programs, as RA's partners look to them to simplify their programs.

    --
    Michael Chellson
    303-519-2576

    This communication is confidential and protected by priviledge and is intended for only the parties originally addressed to. Should you have received this communication in error, immediately notify the sender via email and delete this message.





  • 7.  RE: Is There Innovation in Regulatory Affairs?

    Posted 25-May-2016 15:25

    Very interesting topic.  I'd like to address 2 of the questions:

    1. Are innovators the antithesis of regulatory professionals? No
    2. Do regulations hold back innovation? No

    If an innovator has an adversarial relation to regulations, then that only means that the innovator doesn't accept or understand the purpose of the regulations.   Regulations at heart is there to protect people and in all honesty to make your product better through the design control process.  I say this as both an RA professional and a mechanical engineer.  The innovators that do best are the ones who USES the regulation as tool in his box rather than the wall he has to climb over.

    The innovators or people who feel regulations hold back innovation, need only to look back at history when there was none.  How many people were permanently injured, died, or ended up with deformed children/unable to have children?  How many families' lives destroyed, babies cooked, or person's wealth gone from quack therapies? I challenge people to read these cases when there were no drug/food/medical device law. Please read up on those cases involving unethical clinical researches when there were no Nuremberg Codes to regulate proper conduct of research.  Please look up articles how we still read about patients/study subjects die from companies/investigators/researchers/etc. not following the rules because they consider it "red tape."

    I think a lot of issues where people see regulations as a wall has something to do with how the regulation is implemented within the company, by the regulatory agencies, as interpreted by various auditors/inspectors, etc. I'd rather focus the conversation on proper implementation of the regulation within the company or making modifications to the process FDA has or Notified Bodies has rather than saying "regulations holds back innovation."  A lot of people I've met simply doesn't understand the logic behind it and how it can help them.  Once they realize it, they have no problem with requirements and instinctively think in risk/benefit within clinical context.

    Then again, we all know at least one person with piss-poor attitude regarding regulations (and the regulatory or quality personnel who's just trying to help them).  For those people, it is now an emotional issue.  A convincing logical argument is useless on an emotional issue.  I got an advise from another engineer who is very happy where he is now in his non-regulated industry.  He told me, if you cannot see yourself in the industry and following all the rules, then you should move on, give other people a chance who actually wants to be in it.  Good advice.  I took it seriously and decided I do want to be in this world.  My personal career goal is to help companies have as many SAFE and EFFECTIVE devices pass through FDA and CE Mark so that these devices can help people, even my own family.

    ------------------------------
    Clarisa Tate
    Medical Device, RA & QA
    Bay Area, CA
    USA



  • 8.  RE: Is There Innovation in Regulatory Affairs?

    Posted 26-May-2016 16:59
    Clarisa,

    You may have elegantly stirred mentality and attitudes of those with mundane style in the pursuit of regulatory affairs in various areas! 

    Thank you.  

    s/ David
    ______________________________________________
    Dr. David Lim, Ph.D., RAC, ASQ-CQA 
    Phone (Toll-Free): 1-(800) 321-8567



    "Knowledge is power only when it is practiced and put into action." - Regulatory Doctor

    NOTICE: This communication (including any attachments) may contain privileged or confidential information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this communication and/or shred the materials and any attachments and are hereby notified that any disclosure, copying or distribution of this communication, or the taking of any action based on it, is strictly prohibited.





  • 9.  RE: Is There Innovation in Regulatory Affairs?

    Posted 25-May-2016 19:27
    Hi

    There has been much regulatory innovation in biostatistics inclusive of the following:

    • Bayes methods for design and analysis
    • Adaptive methods for design and analyses
    • Quasi-non-inferiority designs and analyses
    • IWRS featuring complex randomization plans
    • Interim look strategies: alpha spending
    • Longitudinal modeling
    • Composite endpoints
    • Multiple effectiveness endpoint significance testing
    • Type 1 error control for genetic markers 
    • Prediction modeling

    Our regulatory agency colleagues have been encouragers, contributors, and collaborators. 

    Best regards,

    Phil Lavin PhD, FASA, FRAPS

    Sent from Windows Mail






  • 10.  RE: Is There Innovation in Regulatory Affairs?

    Posted 26-May-2016 10:11

    I certainly agree that there has been much positive evolution in the application of statistical principles to product development.  I'm not clear on how this would be considered "regulatory" innovation, unless you are referring to an increased openness on the part of the regulators to these different statistical approaches?

    ------------------------------
    Julie Omohundro, ex-RAC (US, EU), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com



  • 11.  RE: Is There Innovation in Regulatory Affairs?

    Posted 26-May-2016 08:29

    Hi Lena.

    Maybe I look at this too simplistically by I have always looked at innovation as anything that disrupts the status quo.  That disruption does not need to be a "violent" disruption (like a new mega-regulation coming out of FDA [sort of like the new nutrition facts labeling rule]) but it can be anything that forces thought processes to move in one direction or the other.

    I happen to like a few of the comments that you have gotten already on this topic and I plan to introduce some of the mindset that some other have already detailed within my own organization to try to change the way we, as regulatory professionals, are viewed within my own business.  But I do think that the mindset of the business plays a huge role in how innovative the regulatory team can be.  For example, where you have people who can only seem to think in yes/no Boolean terms, innovation is going to have a hard time getting a foothold because they don't understand or have no desire to be taught the level of nuance in the industry and even in regulatory issues.  Where people are more open to discussion, negotiation, risk/benefit, etc. (whatever you want to term it) then regulatory has a real opportunity to provide that challenge to the status quo.

    Regulatory, by its very basic and not-fully understood definition of the profession, could be seen as the antithesis to innovation.  Let's be honest, we have all been in situations where there is a "playbook" on how to get things done and no one ever questions the playbook because it has always "been OK" or "worked" to get the job done.  I can provide an example from my own experience.  In the past I have been involved with companies who use Excel spreadsheets to manage their formulation development.  Now obviously none of the Excel spreadsheets met 21 CFR 11 in any way, shape or form so the company needed to manage multiple systems and scientific books, and signatures and counter-signatures along with all of the stuff they already were doing.  When I came in there had been some discussion of obtaining funding from the company to purchase a formulation tracking software that could comply with 21 CFR 11 and also could provide other modules that would allow for Quality, Operations, Package Engineering, etc. to also obtain benefit of a fully functional data management system all in one place.  My predecessor in the position wanted to hear nothing of it because the other system "worked just fine the way it was set up".   Oh, and I should mention that this person routinely worked 12-13 hour days because the system "worked just fine".  My first project when I took over the position fully was to bring that discussion back to the table.  Thankfully some other folks had also been hired in the same time period as I and they also understood the power of the use of such a system to streamline processes.  So it was a bit simpler because they understood as users what the system might afford them in terms of efficiency, simplicity and searchability that they weren't able to get from Excel.

    I personally think that there is a need for innovation in every aspect of corporate life.  Let's be honest here - those who stagnate typically will die.  So a company needs to be able to come up with new ways to improve things.  Innovation in my mind can be used to improve process, improve culture, improve costs, improve the bottom line, and all of these things ultimately improve the company and its ability to do business.  The only people I have ever truly heard arguing that they didn't need to consider new ideas or new ways to manage things were those who were so far along in their careers that they had truly forgotten just how important all these things are or who were so young in their careers that they simply didn't understand the basic truth that not all things are created equal in business and there are different ways to approach any issue to solve a problem [Note - I do count myself as one of the latter earlier in my own career!].  Being realistic, when the profession first started there was a need for some limited understanding of business principles simply to understand where the arguments might arise from upper management.  Now, I don't know of many regulatory professionals who have either been on the "business" (operational) side of the world or who have specifically tried to obtain further education in business principles (such as the Executive Development program sponsored and run by RAPS) to understand what the business needs from the regulatory team and then to also be able to discuss regulatory issues in a language that business-people can comprehend.

    And , no, EMPHATICALLY NO, regulations do not hold back the profession from being innovative.  As some have stated already in many instances the same regulator that some fear will frown on the innovative approach have been among the people and colleagues who have been the most vocally positive of the changes that have occurred.  Have there been instances where someone unfairly or unnecessarily questioned innovative ideas?  I am certain there have.  But I am equally convinced that there have been far more situations where someone (regulator) has seen the innovation and brought it up to their team as a possible best practice.  Is every innovation good?  That depends on the definition of "good" in this instance.  Will every innovation work the way it was planned without any issues?  NO.  But any innovation is good in my mind for the simple fact that someone chose to try to make a CHANGE in how we think, work, etc.  Change is good because it forces further discussion of what is going well and what is going poorly.  And discussion can never, in my mind, be a bad thing.

    ------------------------------
    Victor Mencarelli
    Sr. Manager - Regulatory Affairs
    Hain Celestial Group
    United States



  • 12.  RE: Is There Innovation in Regulatory Affairs?

    Posted 26-May-2016 10:42

    Interesting and insightful comments, Victor.  Here are my thought thus far:

    When it comes to "innovative" versus "disruptive" or "game-changing," there are forces at play in the broader tech environment that have apparently found it in their interests to define very minor changes as "innovative," and slightly more aggressive changes as "disruptive" or "game changing."  (Think how often you have seen the advertising tag line, "This changes everything" attached to a product that really changes very little, e.g. version 1.111113 of a cell phone.)

    Those forces are also at play within the medtech industry, where it sometimes seems that "innovative" can carry about the same meaning as "new and improved" on box of detergent.  The point here seems to be to have something new to promote in a market that has saturated and gone flat, not really to improve much of anything.  (If it succeeds in kick-starting sales, then I guess that could be considered "disrupting" the status quo of flat sales, but I'm doubtful that this is what you have in mind.)  I think this form of "innovation" and the typical "me too" 510(k) process are a perfect match for each other.

    Until recently, there was another crowd within the industry, laboring to develop "disruptive" (a little or a lot) devices.  These efforts were being increasingly "held back" by the regulations, which offered them a choice between a rock (the 510(k) path) or a hard place (the PMA path).

    If you want to talk about a regulatory "game changer," I think that would be the new "direct to De novo" process. It has freed the crowd that wants to "disrupt" from having to struggle to pound a square peg into a round hole.  I expect it will ultimately reshape the medical device industry.   I think it will also reshape our profession, with those steeped in the traditional "me too" 510(k) mindset going one way (or perhaps simply "away," since there is really not much "regulatory" to be found here), and those grounded in the mindset of novel devices another.

    ------------------------------
    Julie Omohundro, ex-RAC (US, EU), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com



  • 13.  RE: Is There Innovation in Regulatory Affairs?

    Posted 26-May-2016 10:47

    I must add that I've always thought of "continuous quality improvement" as a philosophy that is the opposite of "if it ain't broke, don't fix it."

    ------------------------------
    Julie Omohundro, ex-RAC (US, EU), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com



  • 14.  RE: Is There Innovation in Regulatory Affairs?

    Posted 26-May-2016 09:31

    Wow - great conversation and I agree with everything that is being said. There are no right or wrong answers to these questions but they give us an opportunity to look at our profession in a different way. WAIT - is that Innovation??

    I believe that the heart of innovation is curiosity and that it is both a nature and a nurture trait. We are all born with the inherent ability to ask questions - but why, but why, but why - from the time we are able to communicate through verbal and non-verbal ways. That is how we explore and learn about our world and ourselves. Unfortunately that natural curiosity can be stifled by answers such as "You ask too many questions", or "That's just how it is" and that causes some of us to lose the ability to question and innovate.

    Then we grow-up and find ourselves working in an industry defined by rules, guidelines, and best practices, while ironically faced with demands to "constantly improve" our processes and products. And that is when innovation must be nurtured back to life with more but why, but why, but why questions. 

    Innovation is not a trait reserved for the creative elite, the engineering magicians or the other-dimension thinkers. Innovation is looking at "something" a hundred times and finally "seeing" it for the first time; playing with it, experimenting, finding a way to improve it.

    As regulatory professionals, we must challenge our teams and ourselves to nurture our curiosity; to become innovation leaders in addition to being thought leaders; to look at rules, guidelines and best practices every day and then on the 101st day finally "see" the question that hasn't been asked.

    I believe we are up to this challenge!

    ------------------------------
    Lena Cordie
    Qualitas Professional Services
    Watertown MN
    United States



  • 15.  RE: Is There Innovation in Regulatory Affairs?

    Posted 26-May-2016 17:05
    Lena,

    Today, you seem to have unlocked your potential in a new area - writing a book!

    The book may be entitled "Regulatory Affairs 102-Setting Your Mentality and Attitude."  

    If you do, I will buy!

    D






  • 16.  RE: Is There Innovation in Regulatory Affairs?

    Posted 27-May-2016 08:50
    David,
     
    Very early in my career, (just starting actually) I was fortunate to have a true "Mentor" as a Boss.  He was a backwoods boy from Mississippi with a pronounced southern drawl.
     
    After one very contentious meeting with Marketing & Product development on the path to market for a new device, he and I retreated to his office.
    He closed the door...Leaned back in his chair...and looking off into space (not directly at me) said:
     
    "Mike, It's very easy to say NO."
     
    And with that dismissed me to go about our duties..
     
    Perplexed, I noodled that for a while and eventually came to understand his wisdom. 
     
    RA is a complex arena, and it requires little thought or creativity to say, "No you can't do that.", but requires a willingness to think and innovate to find a pathway to YES.  While sometimes convoluted, there is usually a way to get to YES.
     
    My inherently frugal nature drives me to pursue the INSEAM (Innovative, Novel, Simple, Easy, And, Manageable)  path, (emphasis on EASY).
     
    This perspective creates "Partnerships" with RA, who will then be viewed as a facilitator, rather than an obstacle.  Not only does this speed product innovation, but ensures early consultation in projects and programs, as RA's partners look to them to simplify their programs.
    ------------------------------
    Michael Chellson
    RAC



  • 17.  RE: Is There Innovation in Regulatory Affairs?

    Posted 28-May-2016 14:00

    Mike I really appreciate your insight and I am in full agreement with your last statement. Product development innovators need an innovative RA partner to help them  navigate the regulatory path that stands between their innovative products and the patient.  I've spent the last 29+ years leading the development of innovative drugs and devices in both large and small companies.  The last 7 years I also acted as head of Regulatory Affairs for a small company that pioneered a new approvable clinical endpoint for diabetic kidney disease.  Based on that experience I've made the decision to focus my career on regulatory affairs for the exact reason that you point out.  Since just about every product development activity is for the purpose of satisfying a regulatory requirement, a product development plan is synonymous with a regulatory development plan.  Without innovation and creativity in that regulatory development plan, truly innovative products will never get to the patients.  I am happy to see a definite trend in the regulatory profession towards being a facilitator of innovation rather than an obstacle to it.  I hope that trend continues and I will do my best to help.

    ------------------------------
    Bob Peterson
    Research Triangle Park NC
    United States



  • 18.  RE: Is There Innovation in Regulatory Affairs?

    Posted 30-May-2016 23:36

    "just about every product development activity is for the purpose of satisfying a regulatory requirement"

    I think that this is sadly true.

    ------------------------------
    Julie Omohundro, ex-RAC (US, EU), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com



  • 19.  RE: Is There Innovation in Regulatory Affairs?

    Posted 30-May-2016 23:34

    Michael, sounds like you won the mentor lottery early in your career.

    I would go further to say that I don't see it as Regulatory's job to say yes or no, but to figure out how.  There is almost always a way.  Whether it makes any business sense is a different matter, but I don't think this is Regulatory's decision to make.

    One place I worked, we had some pretty sharp people.  The following exchange occurred in one meeting or another on a regular basis: Can we do X?  Yes, you can, but...do you want to?

    I see Regulatory's role as figuring out how, presenting it to the team or executive management or other appropriate audience, and then letting them decide if they want to do it or not.  If you can come up with more than one option, all the better.

    ------------------------------
    Julie Omohundro, ex-RAC (US, EU), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com



  • 20.  RE: Is There Innovation in Regulatory Affairs?

    Posted 27-May-2016 13:53

    That is an interesting topic!  Not to be too nit-picky, but the answer depends on what is being innovated.  If innovation refers to innovative  products, then regulations do not stop innovation, because engineers always want to build something new and inventors are driven to realize their visions.  That said, it's likely that the regulatory environment delays patient access to innovative products (for good and not so good reasons). 

    If innovation refers to the approach one takes to the job, then yes, there can be innovation in Regulatory Land. This discussion string includes insightful comments about finding novel yet appropriate ways to get things done within the framework of regs and standards, to which I agree wholeheartedly.  I want to be clear that I am NOT advocating finding loopholes so that nefarious companies can do evil things.  What I'm advocating for is finding honest, workable solutions. 

    I would say that true regulatory innovation needs to come from the regulatory bodies themselves.  But innovation means change, and change does not come quick to bureaucracies, again for good and not so good reasons.  So until such changes occur, it is up to regulatory professionals to push regulatory bodies to accept innovative approaches which they have not considered before.

    Best of luck with your chapter event!  Sounds like a good one.

    ------------------------------
    Patrick Martin
    Seattle WA
    United States



  • 21.  RE: Is There Innovation in Regulatory Affairs?

    Posted 31-May-2016 20:45

    Hi Patrick,

    Innovative does exist in Regulatory environment and settings, in fact FDA is constantly seeking innovative ways to get safer products to the market. Here is a link:

    Innovation: News

    Fda remove preview
    Innovation: News
    We're committed to encouraging advances when it comes to the products we regulate and the scientific research we carry out. And we want to share our progress with you. Our FDA Voice blog gives FDA staff a chance to provide their unique take on policy and agency actions.
    View this on Fda >
    ------------------------------
    Lin Lewis
    Professional



  • 22.  RE: Is There Innovation in Regulatory Affairs?

    Posted 31-May-2016 21:01

    Hey, Lena!  Don't forget to come back and tell us how it went!

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com