Regulatory Open Forum

 View Only
Expand all | Collapse all

Design Transfer for Prototypes

  • 1.  Design Transfer for Prototypes

    Posted 05-Nov-2019 23:03
    Hi everyone, 

    In the process of prototyping before design verification, is there a design transfer process? I understand that once a design has passed verification or validation, a formal design transfer process takes place to translate into production specifications. But the process of converting inputs into outputs for design verification or to make the prototype itself, is this "transfer" documented at all?  I have not seen this topic discussed. I am working for a startup so some of these questions probably have no clear-cut answers.

    ------------------------------
    Karen Zhou
    ------------------------------


  • 2.  RE: Design Transfer for Prototypes

    Posted 06-Nov-2019 06:51
    Karen,

    Well the process of design transfer is not a singular event as this can occur over a long period of time depending on the device and complexity of manufacturing.  The important thing to remember is that when design transfer is "done" then all production is typically done by manufacturing or say a contract manufacturer can now make the finished device.  A final step of the design transfer is where the Medical Device File/Device Master Record is "complete" so all component specifications, manufacturing specification, manufacturing instructions, QC test instructions, QC test records, batch record files, etc. etc. are all in place.  Wen you ask about design transfer in relation to prototype devices, this really depends.  So lets look at an example.  You have this prototype device for simplicity is made from 5 major components.  A design transfer can occur where 2 of these components are made "in production" by manufacturing personnel.  All the materials, component specifications, instructions, etc. are released for these 2 components which are made in production.  The other 3 components are still be put together by development/R&D as the component specifications are not formally released and maybe there is no manufacturing instructions exist yet.  Thus the 2 components have gone through design transfer, but the other 3 components are still waiting to be finalised from prototype testing or verification testing.  In a simple world (smile) design transfer would be completed at end of verification stage so the device has gone through all verification testing and passed.  Then design transfer is completed, so production of initial lots is performed.  Then these initial production lots are put through the validation testing.  Hope that helps, but remember design transfer is a process taking time sometimes even starting in the "prototype" area of design.

    ------------------------------
    Richard Vincins RAC
    Vice President Global Regulatory Affairs
    ------------------------------



  • 3.  RE: Design Transfer for Prototypes

    Posted 07-Nov-2019 07:41
    Hi Richard,

    I'm unsure I would pass with your explanation with our authorities.

    There are 2 parallel definitions:
    - Design Transfer is a process to get to a milestone, the
    - Design Transfer

    The Design Transfer process is also commonly called "industrialization", during which the prototype is taken to a mass-produced product (as you point out "to be taken to a contract manufacturer"). Thus, this process has to be finished to be taken to production.

    I wouldn't be permitted to run "initial lots" or perform "validation testing" AFTER a completed Design Transfer.

    Otherwise your explanation matches my understanding.
    Best regards,
    Richard

    ------------------------------
    Richard Jansky
    Wattwil
    Switzerland
    ------------------------------



  • 4.  RE: Design Transfer for Prototypes

    Posted 07-Nov-2019 12:31
    Edited by Julie Omohundro 08-Nov-2019 11:11
    In practice, all of this stuff is done many different ways, from seat of the pants to very a very formalized process.  Startups tend to do more of the former than the latter.

    Based on what we have seen in regulations and standards and what we have observed up close and personal, we all come up with something of our own frameworks and definitions, hopefully not to be confused with stone tablets, but as places to start and then help guide us through the confusions presented by an imperfect world...some parts of it being a good bit less perfect than others, not to name any names. :)

    Under my framework, you cannot take a prototype to mass production, because a prototype is by definition a contraption that was not produced with a validated manufacturing process.  At that point, it is not a medical device in any useful sense of the word.  A medical device is neither a design nor a prototype, but a set of verified technical specifications together with a documented manufacturing process that has been validated to reliably produce contraptions that meet the specifications.  This is what you can take to mass production.  It may turn out that you were able to validate the process that was used to make the prototype, so the line gets blurry, but it is still the validated process, not the prototype, that is taken to mass production. The prototype gets handed over to marketing, or to the serial CEO for further pitching.

    I can interpret "design transfer" as a process by which information regarding a design is transferred from one person or group to another, or for one use to another.  Since Karen is talking about a prototype, I think she is asking about the latter, and perhaps the former as well.  I can also interpret it as a design control under 21 CFR 820 or ISO 13485.  I'm sure the use of the term in these two documents refer to what industry (not just medical devices) has long referred to more casually as "tossing it over the fence."  This is when the design engineers finalize the technical specifications, hand them to manufacturing, wish manufacturing well, and go on to the next project.  This is an imperfect way to develop products, but it is indeed an imperfect world, and this practice has been the by far the most commonly followed in all industries for a very, very long time.

    Thus I go with "a process to get to a milestone," rather than "Design Transfer," by which I think Richard is referring to a formal design control.

    (Not sure if these musings might be helpful or confusing to others, but for me it was helpful to work through them.)





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



  • 5.  RE: Design Transfer for Prototypes

    Posted 08-Nov-2019 07:01
    Hi Julie

    that is the essence: "a process to get to a milestone" with my addition/correction that it is still a part of the design&development. Only upon its completion you get into production&service. Both ISO and FDA seem to agree on this.

    Best Regards,
    Richard

    ------------------------------
    Richard Jansky
    Wattwil
    Switzerland
    ------------------------------



  • 6.  RE: Design Transfer for Prototypes

    Posted 08-Nov-2019 11:27
    I had not thought of applying the design transfer concept to the transition from prototype to design controls, but I think it's a great idea, both in terms of assuring that all useful information about the prototype is captured and available to the design control process, and as a way to draw a clearer line between where prototyping ends and the development of an actual (reliably manufacturable) product begins.

    Just to clarify, when you say "it is still a part of the design&development," what do you mean by "it"?


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



  • 7.  RE: Design Transfer for Prototypes

    Posted 11-Nov-2019 06:45
    In the case of ISO 13485, chapter 7.3 is about "design&development". There, "design transfer" is chapter 7.3.8 implying to me that it should't be considered as an afterthought our even a part of the production (chapter 7.5). The definition of the FDA  is in my opinion even more stringent - no *correct* production specs, no production.

    ------------------------------
    Richard Jansky
    Wattwil
    Switzerland
    ------------------------------



  • 8.  RE: Design Transfer for Prototypes

    Posted 12-Nov-2019 13:54
    The processes you are describing are very interconnected and come from ISO 9001 way back in the late 1980's and are considered to be good business practices by FDA and other regulators, as well as other industries.  Medical devices require more documentation, perhaps.
     
    When developing a product, you may go through numerous prototypes, which are part of the design-development process, before establishing the final Design Outputs.  This appears to be where you may be, trying to develop the final Design Outputs. When you have arrived at the final Design Outputs, using the prototypes, perhaps you are ready to move to Design Verification to show that Design Output meets Design Input requirements. At this point, the final Design Outputs are transferred to the Device Master Record (FDA term) [Medical Device File-ISO 13485 term] which is the recipe (and includes other documents as well) to manufacture the product.  Design Transfer is the process of taking the final Design Outputs and using them and the other documents in the Device Master Record or Medical Device File, like QA procedures, equipment specifications, and work instructions for the operators to produce product that meets the Design Output specifications.  Design Transfer includes Process Validation.  Design Validation and Process Validation follow successful Design Verification, which is the activity to show that the Design Outputs meet the Design Inputs.  Design Validation may be performed on units from the PQ phase of Process Validation as they are Production Units.  FDA believes that prototypes may be used during design-development process (see Comment 85 in the Preamble to 21 CFR 820), however when reaching the phase where Process Validation and Design Validation  are conducted, you should be working with production specifications that have been though final Design Verification and producing full-scale Production product.  Anything less is very expensive.  Dr. Joseph Juran used to say the cost increases by a factor of ten at each stage of development.  It would be extremely expensive to decide that the product is not correct when you have bought tooling and developed production processes for an incorrect product.  

    So use prototypes to develop your final Design Outputs before moving forward.  Not to say that the design-development process is serial, many things will be at various stages in development at the same time.  You may have one part of the product in Process Validation and another in creating final Design Outputs.  That is ok.  But the product used for Design Validation should be the final production product.  Those who are performing the activities required in Design Validation should see the product the customer will see.  

    Unfortunately, Design Controls are not all that clear.  You might consider some training on the subject, such as the AAMI Design Control course.














    ------------------------------
    Edwin Bills MEd, CQA, RAC, BSc, CQE, ASQ
    Principal Consultant
    Overland Park KS
    United States
    elb@edwinbillsconsultant.com
    ------------------------------



  • 9.  RE: Design Transfer for Prototypes

    Posted 14-Nov-2019 14:52
    What clarifications to design controls do you think would be helpful?

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



  • 10.  RE: Design Transfer for Prototypes

    Posted 14-Nov-2019 15:35
    You might look at the discussions in the ISO 13485 handbook (not exactly the title, but it has been cited here before) published by ISO and written by the technical committee that wrote the standard, or the AAMI Compendium, both have extensive discussions of Design Controls. The AAMI publication has discussions of Design Controls written by FDA. 

    ------------------------------
    Edwin Bills MEd, CQA, RAC, BSc, CQE, ASQ
    Principal Consultant
    Overland Park KS
    United States
    elb@edwinbillsconsultant.com
    ------------------------------



  • 11.  RE: Design Transfer for Prototypes

    Posted 06-Nov-2019 16:32
    They don't have clear-cut answers at any type of company, I don't think.

    I think of a prototype as something to be used for proof of concept.  Once you have proven the concept, then it is time to begin designing (in a formal, design control kind of way) a product based upon that concept.  So there is no design to transfer.  I would recommend something more like a "pre-design control review," to confirm that you are ready to proceed with the implementation of design controls.  Going too far too fast is one of the ways startups fail because "we ran out of money."


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



  • 12.  RE: Design Transfer for Prototypes

    Posted 11-Nov-2019 18:01
    Hi Karen

    A device may go through numerous prototyping stages – an experimental prototype build to serve as proof of concept; an early stage design prototype build to allow refinement of design elements or systems integration; a pre-production prototype build to streamline the production processes or facilitate manufacturability or improve throughput yield; etc.  An experimental prototype to demonstrate concept feasibility may even be manually built or assembled, while later prototypes would follow production processes to help develop serial manufacturing and lay the foundation for production process validation where necessary.  Final V&V testing would be performed only on units built under production controls.

    Also, depending on the complexity of the device or component, there could be numerous iterations within each of these stages.  With each build, testing and review of the prototype should be documented, essentially capturing all build details (e.g. software revision or drawing version), to show development of the design.  These build reviews form part of the design development and transfer process and are captured in the technical dossier under the Design History File or Device Master Records respectively.

    Finally, to touch upon your other thread #Interim Design Outputs, the number of prototype units built in each case would depend on the purpose of the prototyping – e.g. design verification, or vendor suitability, or receiving acceptance, or establishing in-process controls, etc.  

    The above applies to Design & Development of a new product/ variant as well as to changes to a device consequent to parts obsolescence or change in vendor of custom-made parts, etc.



    ------------------------------
    Homi Dalal RAC
    Regulatory Affairs Leader
    Christchurch
    New Zealand
    ------------------------------