147 - URRA Draft Guidance, uFMEA's, Design Validation, HF Summative, Comparative Analysis, Threshold Analysis and Compelling Technical Arguments with David Grosse-Wentrup

Let's Combinate · 30 Jul 2024 · 23m

What this episode covers

David Grosse-Wentrup, Research Director at Design Science Group, explains the FDA's new URRA draft guidance, which formalizes the use of Use-Related Risk Assessments (URRA) to justify waiving full human factors validation studies for medical devices.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

Other shows on the same ground, closest first.

  • Global Medical Device Podcast · 53m

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

    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.

  • Global Medical Device Podcast · 40m

    Human Factors & Risk Management: What's Needed & Why?

    Shannon Hoste, President of Agilis Consulting Group and former lead of the FDA’s Human Factors Team, explains how human factors serves as a critical risk management activity for medical device development. She details the importance of the Use-Related Risk Assessment (URRA) in identifying potential use errors and high-disparity harms early in the design process to ensure safe and effective product use. Hoste discusses the evolution of ISO 62366, the challenges engineers face in understanding qualitative user needs, and the necessity of integrating human factors into the product development lifecycle rather than treating it as a late-stage compliance checkbox.

  • Global Medical Device Podcast · 36m

    Setting the Record Straight on Usability & Human Factors

    Mike Drues, a regulatory consultant for Vascular Sciences, joins host Jon Speer to clarify the distinction between usability and human factors in medical device development. They discuss how engineers often fail to test devices on actual end-users, leading to design flaws, and argue that FDA regulations are inconsistent, requiring extensive testing for simple devices while ignoring complex ones. The conversation emphasizes that usability testing should be risk-based, distinguishing between formative testing during development and summative testing after design freeze. Drues highlights the importance of realistic testing scenarios and warns against the 'tick-box' mentality that ignores off-label use risks.

  • Global Medical Device Podcast · 45m

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

    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.

  • Global Medical Device Podcast · 41m

    Tips for Being Prepared Post-EUA (Emergency Use Authorization)

    Mike Drues of Vascular Sciences joins host Jon Speer to discuss the transition plans for medical devices currently on the market under Emergency Use Authorization (EUA). They explain that EUAs are temporary authorizations with lower regulatory and quality burdens than traditional pathways like 510(k) or De Novo, and warn that companies relying solely on EUA data will likely fail to meet the higher standards required for permanent clearance. Drues advises firms to proactively conduct gap analyses and engage in pre-submissions rather than waiting for FDA termination notices, emphasizing that EUA products must be integrated into a broader long-term regulatory strategy.

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.