Hi,
While I agree that the way that Pharma addresses Device requirements when they have a Combination Product is less than optimal, grafting medical device experts is not necessarily the solution.
First, although these companies are "developing" a combination product, given the broad scope of these product, most are not designing, nor manufacturing the device constituent part. The pharma role in many of these cases is more of program management than device designer. Many of the systems used, expertise applied and activities executed are by the device subcontractor (or device manufacturer for co-packaged or co-labeled products) with input and oversight by the pharma company.
With regards to quality and quality engineering, I fully agree. These are concepts that are alien to many pharma companies, who are mostly staffed with clinical or commercial pharma quality experts. This is also just the right expertise to help with integration of device systems (such as risk management and Human Factors engineering as well as others required by 21 CFR Part 4), to provide oversight of a device subcontractor during development and to provide support on an ongoing basis.
However, just because someone has device expertise, does not make then qualified in a combination product environment. There are issues and elements that are unique when the drug and device are combined that must be learned by the device experts. This also means, that some pharm experts can also be taught the tenets of device quality engineering. One thing is certain, everyone must expand their outlook and go beyond their experience and training when both a drug and device are involved.
Finally, I spend all of my time in the combination product environment and follow and review all Warning letters and other that one to Amgen years ago (which was more about not following procedures than anything else), I have not seen the "warning letters galore" that you cite.
I would appreciate if you could provide a list of link to those as they would provide a great resource for learning for all in tis area.
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Lee Leichter RAC
President
Fort Myers FL
United States
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Original Message:
Sent: 09-Sep-2018 15:44
From: Anonymous Member
Subject: Organizational Structure
This message was posted by a user wishing to remain anonymous
Hi All
I was wondering what kind of org structure has worked in your experience for device experts supporting combination products in the pharma industry.
Would the typical device industry set up of having sustaining device engineers at sites work? Also having design assurance/pre market quality engineers and post-market quality engineers (supporting PMSRs, process validations, complaint/recalls, HHE etc.)?
Currently seeing that to address combination product requirements (esp those with device constituents), some pharma companies are trying to make their pharma staff device experts and adding a few lines within pharma procedures to cover device requirements and this does not seem to work. This is leading to 483 observations and warning letter galore when CDRH investigators show up with CDER and CBER....
Still there appears to be insistence that device regs are not so different from pharma regs and therefore they don't need to hire more people with device expertise. Any thoughts?
Thank you