Happy New Year to you too!
Tina, in line with your post, my comments below are targeted at a small device organization with few SMEs wearing multiple hats and having little experience in the use of
standards.
If your company does not currently maintain a standards matrix that identifies all standards referenced in your technical documentation, that may be a good place to start. Identifying the relevant standards (horizontal and vertical - by industry sector or product, compliance area, specific requirements, etc) by dated version would be the first step in monitoring the sub-set of active standards, and tracking changes as and when the standard is amended. The EU Essential Requirements Checklist (or TGA/ IMDRF Essential Principles Checklist) would probably identify most frequently used standards, including any particular harmonized standards, that should certainly be monitored routinely, and would possibly require documentation of the clause-by-clause analysis you mention. Another resource for the USA would be the standards cited relevant to your Product Code and/or Specialty Task Group Area from the FDA Recognized Consensus Standards database. Other standards used for demonstrating your products' compliance with particular requirements or test methods (e.g. IEC 62366 or IEC 82304 or UL 94) may also require the same level of clause-by-clause scrutiny, but the large remainder of standards referenced may require only a periodic and high level review to determine if the changes would affect aspects of your product requirements (e.g. packaging to ISTA standards). In short, a risk-based approach to determine the effect of changes to standards on product safety and performance would help establish broad criteria for a practical and sustainable effort, depending on the product range, risk classification, market requirements, etc..
Since most standards are voluntary anyway, in demonstrating compliance the organization should consider the risks involved and commit to the least burdensome effort needed to ensure on-going product safety and performance.
Regarding a specific structure or checklist to serve as a guide in this exercise, because of the huge diversity of medical devices and the specific product range on offer from your organization, it may not be very useful to adopt an existing SOP from another organization. Better to base your internal procedures on your specific requirements, adopting a risk based approach and following best practices in risk management during the product life cycle, and especially when effecting changes.
------------------------------
Homi Dalal RAC
Regulatory Affairs Leader
Christchurch
New Zealand
------------------------------
Original Message:
Sent: 06-Jan-2019 14:26
From: Anne LeBlanc
Subject: Process for standards change management
Happy New Year!
I don't have answers, but I think you're asking the right questions.
You need the SMEs to learn to trust their judgment... When a change has minimal impact, they can document a high-level assessment to that effect in just a couple sentences. When a change is truly significant, they're likely to recognize it, and that's when a point-by-point gap assessment will be worth the effort.
------------------------------
Anne LeBlanc
Manager, Regulatory Affairs
United States
Original Message:
Sent: 31-Dec-2018 16:40
From: Tina O'Brien
Subject: Process for standards change management
Happy New Year Regulatory people! As I'm getting ready to dive back into work later this week after the holidays, I need your input on change management for device standards.
After having spent the better part of the last 20 years working for large device companies with oodles of resources, systems, and processes, I am now with a very small company with few resources, so I'm the lucky person responsible for standards compliance and maintenance.
Here's my problem... My team of standards "users" consists mostly of staff with little to no prior medical device experience, thus little to no practical experience in the use of standards. While I provide general training and guidance, I need the designated SMEs to become responsible for analysis and implementation of the technical aspects of their assigned standards. For example, the standards management SOP that I inherited when I joined the company requires that a clause-by-clause gap analysis be documented for all new standards and all revisions. IMO this is complete overkill and neither practical nor sustainable considering the other multiple hats each member of the team wears on a daily basis, so this is something I'd like to streamline and simplify in order to achieve and maintain SOP compliance.
What I REALLY need are suggestions as to HOW to best manage changes to existing standards that apply to our devices. I'd love to be able to get my hands on anything – a process flow, checklist, SOP (really, anything would help) that provides some structure and guidance for the SMEs with respect to both new and revised standards, criteria for when a full gap analysis would be warranted, best practices for documenting compliance to a standards, etc. While I do have some content of my own, I'd really like to incorporate recommendations that are proven to work. I'm also conducting a deep dive into the user features of the IHS Engineering Workbench to see what could be utilized by the SMEs to document their analysis of the standards outside of our paper-based QS.
Any info and/or advice you can share would be immensely appreciated.
Thanks!
Tina
------------------------------
Tina O'Brien RAC, MS
Director of Regulatory Affairs
Airport Oaks
New Zealand
------------------------------