#450: Human Factors vs. Clinical Trials: Why Your MedTech Submission is Stalling

Global Medical Device Podcast · 9 Mar 2026 · 53m · Episode 450

What this episode covers

Staci Miller, a Human Factors and UX Strategist at GenUX, explains why medical device submissions stall when human factors (HF) is treated as a late-stage box-checking exercise rather than an integrated part of ISO 14971 risk management. She distinguishes between Use-Related Risk Analysis (URRA) for novel devices and User Failure Mode and Effects Analysis (uFMEA) for established products with post-market data, emphasizing that clinical trial efficacy data cannot replace usability validation unless premeditated in the study protocol. Miller warns that ignoring the 'use environment' and design inputs leads to FDA rejections, as regulators require a cohesive safety story that maps user interactions across diverse contexts like ambulances or radiology suites.

Other shows on the same ground, closest first.

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    147 - URRA Draft Guidance, uFMEA's, Design Validation, HF Summative, Comparative Analysis, Threshold Analysis and Compelling Technical Arguments with David Grosse-Wentrup

    David Grosse-Wentrup, Research Director at Design Science Group, explains the FDA's new URRA draft guidance, which formalizes the use of Use-Related Risk Assessments (URRA) to justify waiving full human factors validation studies for medical devices.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.

  • Let's Combinate · 36m

    104 -New FDA Guidance, HF vs. Design Validation, Critical Tasks & Pre-IND HF Studies with Sara McNew

    Sara McNew, Chief Scientific Officer at Design Science, discusses the new FDA Guidance on Human Factors for Combination Products, clarifying the distinction between human factors validation and broader design validation. She explains that pre-IND studies must demonstrate that clinical trial participants can use the device correctly to ensure accurate pharmacokinetic data, requiring a hybrid of formative and summative rigor. McNew details how critical task definitions now include administration and dosing errors, not just serious harm, and emphasizes the importance of submitting comprehensive Use Related Risk Assessments (URRA) alongside HF summaries.

  • 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.

  • Let's Combinate · 34m

    258 - Combination Product Quality: Human Factors, CDMO Scorecards, ISO 14971 vs. ICH Q9, with Ben Locwin

    Ben Locwin, Vice President at Reliant Life Sciences, and Subhi Saadeh, Founder of Let's Combinate, discuss the divergent quality philosophies of pharmaceutical and medical device industries, focusing on combination products. They explain how human factors studies must account for different user types (HCP vs. lay) even with platform devices, and how CDMO scorecards often fail to reflect operational reality due to subjective weighting. The conversation details the differences between ISO 14971 and ICH Q9 risk management, emphasizing the need for FMEA as a living document updated with real-world data.

  • Let's Combinate · 46m

    049 - "What Does the Data Say?" with Shannon Hoste

    Shannon Hoste, President of Agilis Consulting and former FDA reviewer, explains the regulatory framework for combination products, detailing the distinct roles of CDRH, CDER, and DMEPA in human factors reviews. She clarifies the critical distinction between design validation and human factors validation, emphasizing that the latter focuses specifically on safe and effective use rather than all user needs. Hoste also discusses the methodology for summative evaluations, including the rationale for the N=15 sample size per user group and strategies for recruiting representative participants to identify use errors.

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