239 - ICH Q12: What’s Binding? Established Conditions and Post-Approval Changes

Let's Combinate · 27 May 2026 · 10m

What this episode covers

Subhi Saadeh, founder of Let’s Combinate, explains ICH Q12, a guideline for managing post-approval changes in pharmaceutical products. He details the distinction between legally binding 'Established Conditions' (ECs) and non-binding 'supporting information', and outlines the three reporting categories for changes. Saadeh also describes the role of Post-Approval Change Management Protocols (PACMPs) and the Product Lifecycle Management (PLCM) document in creating a predictable regulatory framework.

Other shows on the same ground, closest first.

  • Global Medical Device Podcast · 44m

    #389: Pre-determined Change Control Plans

    Mike Drues, President of Vascular Sciences and former FDA consultant, discusses the Predetermined Change Control Plan (PCCP) with host Etienne Nichols. Drues explains how PCCPs allow manufacturers to get pre-approval for anticipated device changes within their original 510(k) or PMA submissions, a framework originally designed for AI-based Software as a Medical Device (SaMD) but now expanded to all medical devices. He highlights the regulatory logic behind pre-validating boundaries for changes, using examples like 3D-printed knees and in vitro diagnostics, while cautioning that the process requires significant upfront data and may not always save time or money compared to traditional special 510(k) submissions.

  • 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 · 43m

    CDRH Proposed Guidance for FY 2023

    Mike Drues, President of Vascular Sciences, joins host John Spear to analyze the FDA CDRH’s proposed guidance priorities for Fiscal Year 2023, detailing the specific items on the A-list and B-list. Drues highlights key regulatory shifts regarding COVID-19 transition plans, cybersecurity for Software as a Medical Device (SaMD), and the controversial 'locked algorithm' requirement for AI/ML devices. The conversation emphasizes that guidance documents are non-binding interpretations of regulations, urging engineers to use professional judgment rather than following them blindly, and discusses how companies can leverage regulatory strategy for competitive advantage.

  • Global Medical Device Podcast · 37m

    #445: ISO 10993-1:2025: What Risk-Based Biocompatibility Means for MedTech

    Thor Rollins, a leader at Nelson Labs and convener of the ISO committee revising ISO 10933-1, explains the 2025 standard's shift from checkbox testing to a risk-based approach aligned with ISO 14971. He details new requirements for lifecycle evaluation, particularly for reprocessed devices, and the concept of biological equivalence to reduce redundant testing. Rollins also discusses the US's rejection of the draft due to lack of guidance, the upcoming technical specifications, and practical advice for companies at different stages of development.

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.