#467: Combination Product Compliance: PMOA, 21 CFR Part 4 & QMS Alignment

Global Medical Device Podcast · 3 Aug 2026 · 35m · Episode 467

What this episode covers

Jim Fentress, Director of Regulatory Affairs at Galero (a Santa Group company), explains the regulatory complexities of combination products, focusing on how the Primary Mode of Action (PMOA) dictates FDA oversight. He details the challenges pharmaceutical companies face when integrating device Quality Management Systems (QMSR/ISO 13485) into their existing CGMP frameworks under 21 CFR Part 4. The discussion covers specific friction points like risk management alignment (AAMI TIR105 vs. ICH Q9), labeling classifications, and the critical need for transparent change control protocols between device manufacturers and pharma partners.

Mentioned

Companies
Galero, Santa Group, FDA, CDRH, CDER, EMA, Greenlight Guru
Also
AAMI TIR105, ISO 14971, ICH Q9, ISO 13485, 21 CFR Part 4, 21 CFR Part 210, 21 CFR Part 211

Other shows on the same ground, closest first.

  • Let's Combinate · 41m

    092 - Putting it all together: Drug cGMP’s 210/211/ICH and Device QMS 820/ISO13485 with Aaron Snyder

    Aaron Snyder, VP of QA at Allotex and AAMI faculty member, explains the structural differences between Device QSR (21 CFR 820/ISO 13485) and Drug cGMPs (21 CFR 210/211), noting that device regulations evolved into a full quality system including design controls, whereas pharma regulations remain focused on manufacturing and testing. He details his career trajectory from auditing at Covidien and Waters to leading QA at Fresenius Kabi and now Allotex, highlighting the specific challenges combination product teams face when bridging these regulatory frameworks. Snyder also discusses his educational initiatives, including teaching AAMI courses and running the 'Quality Systems Explained' YouTube channel, to simplify complex regulatory requirements for engineers and quality professionals.

  • Let's Combinate · 42m

    125 - Unpacking the Quality Management System Regulation(QMSR) Final Rule with Subhi Saadeh

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  • Let's Combinate · 12m

    257 - 21 CFR Part 4 Explained: CGMP Requirements for Combination Products

    Subhi Saadeh, a consultant and auditor specializing in combination products, explains the CGMP requirements under 21 CFR Part 4 for products containing both drug and device elements. She details the scope of single-entity and co-packaged products, the baseline expectation of meeting all applicable regulations, and the two compliance paths: full integration or a streamlined approach. Saadeh outlines specific ISO 13485 sections required for drug-based systems and 21 CFR Part 211 sections for device-based systems, highlighting complexities like management review differences and reserve sample storage.

  • Let's Combinate · 25m

    155 - FDA Compliance Programs, Program 7536.000: CDER vs. CDRH led Inspections, Mock PAI's, Supplier Management, and What is a Manufacturer? with Laurie Auerbach

    Laurie Auerbach, President of Compliance Prodigies, LLC, explains FDA Compliance Program 7356.000, clarifying that contract manufacturers (CMOs) and component suppliers selling bundled solutions are legally defined as combination product manufacturers. She highlights common failures in mock Pre-Approval Inspections (PAIs), particularly the misconception that drug GMPs (21 CFR 211) and ICH Q10 fully satisfy device requirements under 21 CFR Part 4. Auerbach emphasizes that sponsors often fail to audit suppliers for device-specific elements like design control, risk management, and specific supplier controls, leading to critical gaps in quality agreements and inspection readiness.

  • Let's Combinate · 17m

    217 - 5 Fixable Problems Holding Back Drug–Device Programs

    Subhi Saadeh, founder of Let’s Combinate BioWorks, outlines five critical quality issues in drug-device combination products, drawing on his experience at Pfizer, Gilead, and Baxter. He addresses documentation misalignment in design transfer, late manufacturing input, arbitrary sampling plans, unclear method transfer ownership, and supplier qualification gaps. Saadeh proposes solutions such as integrating pharma change controls with device design plans, embedding DFM/DFA reviews, and adopting PPAP frameworks for component qualification. The episode emphasizes harmonizing drug and device development processes to ensure scalable, compliant, and patient-ready solutions.

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