A Regulatory Gap Analysis of FDA's Systems & Policies

Global Medical Device Podcast · 26 Jan 2022 · 53m · Episode 244

What this episode covers

Mike Drues of Vascular Sciences joins host Jon Speer of Greenlight Guru to conduct a gap analysis of the FDA's regulatory framework, arguing that the system is too reactive. Drues identifies 'predicate creep' in the 510(k) process and 'change creep' via letters-to-file as major inefficiencies, proposing a 'ketchup 510(k)' to aggregate minor changes. He also advocates for a formal mechanism to designate wellness devices, a '510(k)-like PMA' for incremental Class 3 innovations, and a dedicated pathway for personalized medicine, such as 3D printed devices.

Mentioned

Companies
Greenlight Guru, Vascular Sciences
Also
FDA, 510(k), CAPA, Custom Device Exemption, Breakthrough Devices Program, Safer Technologies Program

Other shows on the same ground, closest first.

  • Let's Combinate · 33m

    106 - FOIA, FDA Modernizing 510(k) Program, De Novo Submissions, and more databases with Michelle Lott

    Michelle Lott, founder of leanRAQA, explains how to navigate eight FDA databases, including using FOIA requests to access redacted 510(k) summaries and reviewing 483 and Warning Letter databases to identify regulatory trends. She details the recent modernization of the 510(k) program, specifically new guidance on predicate selection and clinical data, and contrasts the 510(k) pathway with the De Novo process for novel devices. Lott also outlines the Pre-Submission and 513(g) classification processes, noting their timelines and costs, while advising companies to monitor draft guidance documents to anticipate FDA expectations during submissions.

  • Let's Combinate · 35m

    079 - How FDA Reviews Combination Products, Policy, EPR's, and Harmonization with Rumi Young

    Rumi Young, Director of Regulatory Policy at Becton Dickinson (BD), explains how the FDA reviews combination products, drawing on her previous tenure as Acting Assistant Director in CDRH’s Division of Drug Delivery. She details the inter-center consult process for products like auto-injectors and smart connected devices, highlighting the manual nature of current submissions and the critical need for clear device identification in NDAs and BLAs. Young discusses the role of industry in shaping policy, advocating for updated Essential Performance Requirements (EPRs) and international harmonization through IMDRF to address the gap between evolving technologies and outdated guidances.

  • Let's Combinate · 1h 19m

    031 - "The Five Stages Of Regulatory Grief" with Michelle Lott

    Michelle Lott, founder of Lean RAQA, discusses her journey from large manufacturer Baxter Healthcare to consulting for small-to-mid-size medical device companies, highlighting the gap in practical regulatory strategy. She details the 'five stages of regulatory grief' clients experience when facing FDA interactions, contrasting the US 510(k) process with the rigorous, ongoing costs of EU MDR compliance. Lott also explains the nuances of regulations versus guidance documents, the QMSR harmonization, and her unique perspective as an elected industry representative on the FDA Device GMP Advisory Committee.

  • Let's Combinate · 46m

    211 - Inside FDA’s Office of Combination Products: History, PMOA, and What’s Next for Combination Products with Mark Kramer

    Mark Kramer, founding director of the FDA’s Office of Combination Products (OCP) and now Principal at Eliquent Life Sciences, explains the history and regulatory framework for combination products in the U.S. He details how the 1990 Safe Medical Devices Act and the 2002 Medical Device User Fee and Modernization Act (MDUFA) led to the creation of OCP, driven initially by the device industry's need to regulate drug-eluting coronary stents. Kramer discusses the Primary Mode of Action (PMOA) rule, the shift from device-led to pharma-led combination products, and current regulatory gaps such as cross-labeling and site registration ambiguities.

  • The Pragmatic Embedded Podcast · 51m

    Closing the gap between Regulatory and Development with Milton Yarberry

    Milton Yarberry, Director of Medical Programs at Integrated Computer Solutions (ICS), discusses bridging the gap between engineering and regulatory teams in medical device development. He identifies key friction points such as process lag, software stacking, and the cognitive burden on developers, arguing that regulatory processes should be viewed as support rather than compliance burdens. Yarberry advocates for a 'regulatory concierge' model where regulatory staff handle administrative overhead, allowing engineers to focus on building safe and effective products through incremental, value-driven processes.

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.