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

Let's Combinate · 5 Jul 2023 · 41m

What this episode covers

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.

Most relevant to

established companies

Topics

Mentioned

Companies
Allotex, Fresenius Kabi, Molnlycke, Waters Corporation, Covidien, Cardinal Health, General Electric, Pfizer, Merck, Mölnlycke Healthcare
Products
Hepincoded catheter
Also
AAMI, Quality Systems Explained, FDA, CDER, CBER, Primal Video

Other shows on the same ground, closest first.

  • Global Medical Device Podcast · 35m

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

    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.

  • Global Medical Device Podcast · 38m

    #380: Navigating the Complex World of Combination Products with Subhi Saadeh

    Subhi Saadeh, host of the Combinate Podcast and expert in combination products, discusses the regulatory complexities of integrating drugs, devices, and biologics, including the differences between US FDA and EU regulatory pathways. He explains the definitions of single entity, co-packaged, and cross-labeled products, and addresses common misconceptions about the differences between drug and device quality systems. Saadeh also shares his journey of starting the podcast to maintain consistent learning and production, highlighting the importance of lifelong learning and leveraging coaching to balance technical and business aspects of the MedTech industry.

  • Global Medical Device Podcast · 48m

    QMSR: The Future of FDA's Quality Management System Regulation for Medical Devices

    Mike Drues of Vascular Sciences and George Zack of Two Harbors Consulting discuss the FDA's proposed Quality Management System Regulation (QMSR) to align 21 CFR Part 820 with ISO 13485:2016. The panel argues that the transition is a small leap for compliant companies, focusing on paperwork rather than engineering changes, and questions the value of constant regulatory updates. They highlight the tension between compliance and actual product quality, noting that while harmonization is a step toward global standards, true global regulatory harmonization remains unlikely due to differing national protections.

  • Global Medical Device Podcast · 19m

    #438: QMSR Mythbusters Episode

    Host Etia Nichols from Greenlight Guru explains the FDA's new Quality Management System Regulation (QMSR), which replaces 21 CFR Part 820 and incorporates ISO 13485:2016 by reference, with a mandatory enforcement date of February 2, 2026. Nichols debunks the myth that the Device Master Record (DMR), Design History File (DHF), and Device History Record (DHR) are being eliminated, clarifying they are mapped to the Medical Device File (MDF), Design and Development File (DDP), and Batch or Lot Record respectively. She highlights three critical shifts: the explicit integration of lifecycle risk management as the 'DNA' of the QMS, the loss of audit privilege making internal records inspectable, and retained US-specific requirements like UDI in complaint records and extended record retention.

  • Global Medical Device Podcast · 54m

    #329 The Right Way to Start a QMS: When, How, & What

    Rob MacCuspie, Manager of Regulatory and Quality Affairs at Proxima Clinical Research, explains how to build a Quality Management System (QMS) by balancing investor cost concerns with FDA regulatory requirements. He argues that a QMS is not just a document management system but a culture driven by management responsibility and people, using a 'highway vs. mountain road' analogy to describe risk-based rigor for different device classes. MacCuspie details the phased implementation of QMS components, the specific challenges of Software as a Medical Device (SaMD) regarding labeling and testing, and the operational efficiency gains of moving from paper to compliant electronic systems like Greenlight Guru.

The summary, chapters and topics are generated from the episode’s audio by this directory, not written by Let's Combinate. The episode itself belongs to its publisher.