Emergency Use Authorization (EUA) 101: What Medical Device Companies Need to Know

Global Medical Device Podcast · 8 Apr 2020 · 45m · Episode 140

What this episode covers

Mike Drues of Vascular Sciences explains the regulatory framework for Emergency Use Authorization (EUA) to host Jon Speer of Greenlight Guru, emphasizing that it is a temporary pathway, not a shortcut for reduced testing. Drues details the specific criteria for EUAs, including the requirement to diagnose, treat, or prevent serious conditions when no adequate alternatives exist, and warns against the dangers of political pressure leading to ineffective devices like the 170 non-functional ventilators delivered in Los Angeles. He advises companies to prioritize safety and efficacy testing by triaging requirements based on risk, rather than treating the EUA as a way to bypass rigorous engineering standards.

Other shows on the same ground, closest first.

  • Let's Combinate · 18m

    137 - The 3 Levels of Reliability, Fault Tree Analysis, Needle Safety, Emergency Use, and Risk Management with Capt. Alan Stevens

    Capt. Alan Stevens, Global Head of Complex Devices and Drug Delivery Systems at AbbVie, and former FDA CDRH official, explains the three levels of reliability in combination products: verification data, component reliability, and system reliability. He details how Fault Tree Analysis (FTA) is used to quantify system reliability, particularly for emergency use injectors and needle safety devices, where the FDA sets specific targets like 95% or 99%. Stevens discusses the regulatory expectations for these high-risk functions and how manufacturers should determine acceptable risk levels when no specific FDA guidance exists, emphasizing the role of risk culture and design assessments.

  • Let's Combinate · 23m

    147 - URRA Draft Guidance, uFMEA's, Design Validation, HF Summative, Comparative Analysis, Threshold Analysis and Compelling Technical Arguments with David Grosse-Wentrup

    David Grosse-Wentrup, Research Director at Design Science Group, explains the FDA's new URRA draft guidance, which formalizes the use of Use-Related Risk Assessments (URRA) to justify waiving full human factors validation studies for medical devices. He details how to build compelling arguments using comparative analysis, threshold analysis, and historical data to demonstrate that a new product is sufficiently similar to an already approved reference device. The discussion covers the practical differences between a URRA and a use-related Failure Mode and Effects Analysis (uFMEA), emphasizing that the URRA is a distilled subset of the uFMEA specifically tailored for regulatory submission. Grosse-Wentrup also highlights lifecycle management strategies, noting that while the URRA is submitted to the FDA, the underlying uFMEA must be maintained throughout the product's life.

  • People of Packaging · 32m

    127 - "If we do our job, no one will know" with LeRonda Perry

    LeRonda Perry, Packaging Engineering Manager at Integra Life Sciences, discusses her career path from Michigan State University’s packaging program to roles at Medtronic and DoubleCore Medical. She details the operational challenges of medical device packaging, including supply chain disruptions, the regulatory shift to EU MDR, and the difficulty of hiring qualified staff. Perry emphasizes the critical importance of usability testing in clinical settings, illustrating how effective packaging design ensures life-saving devices function without hindering surgical procedures.

  • Let's Combinate · 23m

    207 - What 99.999% Reliability Really Means

    Alan Stevens, Global Head of Complex Devices at AbbVie and former FDA/CDRH leader, explains the FDA's 2020 draft guidance on 'five nines' (99.999%) reliability for life-saving drug-device combination products like epinephrine and naloxone injectors. He clarifies that this standard does not require testing 300,000 samples, but rather demonstrates reliability through fault tree analysis linking design requirements to manufacturing process controls and challenge testing. Stevens emphasizes that while traditional design verification (DV) remains necessary, manufacturers must use sequential challenge testing and robust process controls to meet the high reliability threshold for products where failure could result in death or serious injury.

  • Let's Combinate · 1h 16m

    012 - "Asking then Seeing" with Sara Waxberg Mcnew

    Sara Waxberg McNew, Chief Scientific Officer at Design Science, explains the human factors process for medical devices, emphasizing the distinction between formative studies and summative validation. She details how to interpret ANSI/AAMI HE75 and IEC 62366-1 standards, manage risk for combination products, and handle regulatory submissions with the FDA. The discussion covers specific challenges like testing rare patient populations, using surrogates, and conducting threshold analyses for generics.

The summary, chapters and topics are generated from the episode’s audio by this directory, not written by Global Medical Device Podcast. The episode itself belongs to its publisher.