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Let's Talk Risk!
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Добавлен 30 авг 2019
Dear colleagues, hello 👋
If you are looking for practical tips and insights about medical device risk management, you have come to the right place!
My name is Naveen Agarwal. My mission is to elevate our collective capability in risk management across the global medical device industry so we can significantly improve patient safety, accelerate innovation and reduce cost.
Let us face it - risk management is now much harder than before in the rapidly changing global regulatory environment. Medical device regulation in the EU, for example, includes references to risk management more than 250 times! The US FDA is also working on harmonizing the Quality System Regulation (QSR) with ISO 13485:2016, which has a much higher emphasis on risk management.
In practice, risk management is difficult. That is why I am creating these videos with practical tips and insights. You can also subscribe to my free newsletter at naveenagarwalphd.substack.com/ for additional resources.
If you are looking for practical tips and insights about medical device risk management, you have come to the right place!
My name is Naveen Agarwal. My mission is to elevate our collective capability in risk management across the global medical device industry so we can significantly improve patient safety, accelerate innovation and reduce cost.
Let us face it - risk management is now much harder than before in the rapidly changing global regulatory environment. Medical device regulation in the EU, for example, includes references to risk management more than 250 times! The US FDA is also working on harmonizing the Quality System Regulation (QSR) with ISO 13485:2016, which has a much higher emphasis on risk management.
In practice, risk management is difficult. That is why I am creating these videos with practical tips and insights. You can also subscribe to my free newsletter at naveenagarwalphd.substack.com/ for additional resources.
LTR 59: FDA's pre-sub program and how it can accelerate medical device innovation
“You can get a lot of valuable insights from the FDA on what your regulatory pathway is when it comes to risk, and how that impacts not only the risk of the product but how you set up your quality systems and what you need to implement in the long run. ”
In this Let’s Talk Risk! conversation (naveenagarwalphd.substack.com/podcast) , Amit Guruprasad shares how small medical device manufacturers and startups can take advantage of the free pre-sub program to get early feedback from the FDA to inform their regulatory strategy and plans for collecting data to prove safety and effectiveness in their final regulatory submission.
But it requires a strategic approach and preparation before you meet...
In this Let’s Talk Risk! conversation (naveenagarwalphd.substack.com/podcast) , Amit Guruprasad shares how small medical device manufacturers and startups can take advantage of the free pre-sub program to get early feedback from the FDA to inform their regulatory strategy and plans for collecting data to prove safety and effectiveness in their final regulatory submission.
But it requires a strategic approach and preparation before you meet...
Просмотров: 22
Видео
LTR 58: Tips for clinicians transitioning into a medical safety role in MedTech
Просмотров 8День назад
“The reality is that, today, a lot of people are studying medicine to go into industry. But if your curriculum do not include areas like risk management, cross-functional collaboration, dFMEA and all of that, then transition for that position is going to be slower.” In this Let’s Talk Risk! conversation (naveenagarwalphd.substack.com/podcast) , Dr. Juan Daccach shares his personal journey of tr...
Understanding terminology - SaMD, AI, ML
Просмотров 1714 дней назад
In this brief clip from the monthly LTR Podcast, industry expert Michael Bocchinfuso explains what Software as a Medical Device (SaMD) is and how it is different from AI/ML enabled device. ✅Listen to the full podcast here ➡️naveenagarwalphd.substack.com/p/ltr-44-aiml-devices-qara-concerns In this hour long conversation, we cover the following topics: 👉Introduction 👉Difference between hardware, ...
LTR 57: It's time to focus on supply chain resiliency not just supplier management
Просмотров 2714 дней назад
“Show me the indicators, show me the KPIs and I will show you the results.” Resiliency starts at the top. Misaligned incentives often lead to unintended and disastrous consequences. Recently, the Federal Aviation Administration (FAA) in the US grounded 171 Boeing 737-9 MAX planes following a mid-air incident where a cabin door blew open, exposing hundreds of passengers to a serious hazardous co...
LTR 56: How to communicate effectively with senior management
Просмотров 2521 день назад
“As professionals in these areas, we are so versed in regulations that we get so deep into the woods with management that 30 seconds after you start speaking, they are gone! They can’t even think about it anymore.” Know your audience, prepare your topic and respect your listener. Victor Mencarelli shares these 3 tips for effective communication in this Let’s Talk Risk! conversation. Remember, e...
Webinar: How to set up post-market surveillance for your medical device
Просмотров 33Месяц назад
💥Medical device manufacturers are required to establish an effective post-market surveillance process as part of their quality system to ensure continued safety and effectiveness of their products. 👉This proves to be very difficult in practice. One reason is that a lot of resources are taken up by the Complaints Handling process required for regulatory compliance. ❌But complaints handling is NO...
LTR 54: Start your risk analysis by first defining the intended use
Просмотров 36Месяц назад
“The first thing I do whenever I am starting design control or risk is that I make sure that the intended use and the indication of the device are as nailed down as they can be.” Yes, design control and risk management can be challenging, especially in a startup or a small medical device company. Generally, there is just one person, a “team of one”, responsible for setting up the entire quality...
LTR 53: Three big trends to watch in MedTech
Просмотров 36Месяц назад
“The regulatory landscape is changing significantly and it is too hard to keep up.” That is why Jennifer Mascioli-Tudor advises risk practitioners to be “super proactive” in following these rapid changes, understand the impact, and take a leading role in preparing their organizations. In this Let’s Talk Risk! conversation, we focus on three big trends in MedTech - the shift from Quality System ...
LTR 52: The key to success as a risk practitioner in the medical device industry.
Просмотров 342 месяца назад
“Risk management is inherent to all our roles, whether you are in Regulatory, Quality or R&D, but it is not something we spend a lot of time on”. Risk management in the medical device industry is often seen as a check-the-box activity for regulatory compliance. In this Let’s Talk Risk! conversation, Carolyn Blandford encourages us to not be satisfied with this status quo and help create a dedic...
Collaborate for success in risk management
Просмотров 192 месяца назад
The practice of risk management in the medical device industry is hard. Here is a simple tip for success - collaborate 🤝more! Because risk management is a team sport! Listen to the full podcast here: ▶️Let's Talk Risk! website: naveenagarwalphd.substack.com/p/ltr-35-tips-for-improving-collaboration ▶️Apple Podcasts: podcasts.apple.com/us/podcast/ltr-35-tips-for-improving-collaboration-in-risk-m...
LTR 50: Humility is the key to startup success
Просмотров 242 месяца назад
“The teams I see really successful are the ones that realize where their gaps lie and stive to reach out to mentors and advisors to fill those gaps”. Developing a medical device and bringing it successfully to the market is a huge challenge, especially for early stage startups. Even for large, established manufacturers, it takes a significant amount of time to launch a new device. In this Let’s...
RM roundup #3: 10 noteworthy risk-related LinkedIn posts
Просмотров 262 месяца назад
Listen to my reading of a recent LinkedIn article (www.linkedin.com/pulse/rm-roundup-3-10-noteworthy-risk-related-linkedin-agarwal-ph-d 6k5ee/?trackingId=n74/87y2T4irNJMUrZoKGw ) I published to cover 10 noteworthy risk-related posts recently published on LinkedIn. Listen to the recording and follow links below to read the original posts and continue the conversation. 🗞️A roundup of 10 noteworth...
Webinar: FDA warning letter case study
Просмотров 542 месяца назад
💥Failing to properly calculate risk can lead to a warning letter from the FDA! ✅ In this month's webinar, we review a recent FDA warning letter to a medical device manufacturer. ➡️ The problem is not necessarily miscalculation, but how it leads to an error in judgment. The result is delayed or no action, which can adversely affect patient safety. ❓We are also discussing audience questions about...
LTR 49: A clinician's view on AI/ML enabled medical devices
Просмотров 462 месяца назад
“The eyes can only see what the mind understands.” The world of medical devices is complex. There are many regulations, standards and guidance documents to read and understand, and apply them correctly during design, development and clinical investigations for regulatory success. In this Let’s Talk Risk! conversation, Dr. Emanuel Tkach encourages us to keep the big picture in mind. Engineers an...
LTR 48: Integrating purchasing controls across product lifecycle
Просмотров 303 месяца назад
“Continuous lifecycle approach to risk management is still not broadly understood or applied in the industry”. In this Let’s Talk Risk! conversation, Kevin Posey highlights a gap in the industry practice of risk management, especially in the context of purchasing controls. Starting with the recent Boeing issue, where a cabin door in a 737 Max 9 blew open during flight, Kevin shares that there i...
Webinar: How to create a master harms list using standard codes
Просмотров 863 месяца назад
Webinar: How to create a master harms list using standard codes
LTR 46: Tips to boost effectiveness of medical device post-market surveillance
Просмотров 473 месяца назад
LTR 46: Tips to boost effectiveness of medical device post-market surveillance
LTR Weekly Digest #31 - 6th April, 2024
Просмотров 233 месяца назад
LTR Weekly Digest #31 - 6th April, 2024
LTR 45: A patient's perspective on CGMs
Просмотров 233 месяца назад
LTR 45: A patient's perspective on CGMs
LTR 44: Why we need a new approach to learning medical software and medical AI
Просмотров 344 месяца назад
LTR 44: Why we need a new approach to learning medical software and medical AI
RM roundup #2: 10 noteworthy risk-related LinkedIn posts
Просмотров 264 месяца назад
RM roundup #2: 10 noteworthy risk-related LinkedIn posts
LTR 43: Tips for integrating risk analysis with design controls
Просмотров 1464 месяца назад
LTR 43: Tips for integrating risk analysis with design controls
Webinar: Benefit-risk evaluation of an AI/ML enabled medical device
Просмотров 724 месяца назад
Webinar: Benefit-risk evaluation of an AI/ML enabled medical device
RM roundup #1: 10 of my favorite risk-related LinkedIn posts
Просмотров 164 месяца назад
RM roundup #1: 10 of my favorite risk-related LinkedIn posts
State or event? A new way to think about the term Hazard.
Просмотров 305 месяцев назад
State or event? A new way to think about the term Hazard.
LTR 42: State or event? Thinking clearly about hazards will help you manage risk.
Просмотров 415 месяцев назад
LTR 42: State or event? Thinking clearly about hazards will help you manage risk.
LTR 40: A guest podcast with NAMSA - Part 1
Просмотров 195 месяцев назад
LTR 40: A guest podcast with NAMSA - Part 1
How to create reliability targets using a risk-based approach
Просмотров 245 месяцев назад
How to create reliability targets using a risk-based approach
LTR 39: Overcoming challenges in linking risk management with design controls
Просмотров 295 месяцев назад
LTR 39: Overcoming challenges in linking risk management with design controls
Barriers to collaboration in risk management
Просмотров 345 месяцев назад
Barriers to collaboration in risk management
We're not all mugs
Hi Naveen, I always love to watch you ❤. This video specially sparked me to look at 05 year back. When I have started to manage PMS activities. Thank You
5:24 "(...)Certain sequence of events may not have a very high exposure for the patient and as a result the harm may be of low severity(...)" I don't agree with this statement. I think you meant "risk" instead of "severity". The severity is not affected by the sequence of events and hazardous situation, however risk is.
'Promo SM'
Good evening sir
What FDA worksheet was shared?
Very complete Thanks
Really like the presentation and efforts to team and share us knowledge, benchmarking benefits analysis and linkage with risk level can be studied like we can apply that mechanism to all devices if possible
If only people with symptoms test themselves, the true positive rate is probably better than if a group of asymptomatic people are screened, prior to flying for example.
I'm sorry, someone here has no idea what open source means. It does NOT mean that anyone can access your data. Open Source means, making the source code available, not personal data. The questions were not about open source, they were about granting access to 1. your QMS (which if it's just SOPs etc. should not have patient data) 2. complaints 3. to do some risk assessment: 1. not a problem if your qms doesn't contain personal data or PHI, 2. I would not do it as complaints might be hard to clean from personal data automatically, and 3. was too unspecific and also unrealistic. AI is not magic. Risk assessment is highly subjective even when incorporating plenty of pms data. I assume he meant going through PMS information automatically. And again, if you have audited the open source AI you want to use for that (assuming that's what "open source" here hinted at), and that AI does not transmit anything anywhere out of your control, then I don't see a problem. Algorithms != Data. This kind of risk assessment really should be done with subject matter experts. The auditors also have a team with technical experience, that will go through your technical file way before the actual audit happens.
Hi do u provide courses for Risk plsease
Hello, please visit my website to learn more about risk management training www.achievexl.com/
Thanks
I like it. ❤
Hi Naveen, amazing lecture once again. Shree Koushik mentioned something about P1 and P2 and said that the annex H actually talks about how P2 may not be necessarily required for IVD. Is that really the case? My first look into annex H did not tap this information.
Hello Yusuf - please see Figure H.1 in Annex H for an illustration of how you could use a P1, P2 approach for IVDs. Note that it is not required to use this approach. You can estimate the probability of harm using another, more direct method. I talk about it in this webinar naveenagarwalphd.substack.com/p/webinar-estimating-probability-of-harm
Could you provide the link Ed mentioned of the Linkedin,please?
+1 on the flow chart comment, i hope 18969 gets some traction soon as i struggle with the same issues at the moment...
Hello Sir Is Severity qualitative or quantitative? And How exactly severity calculated and arrived to numeric value?
Hello, a common practice in the medical device industry is to use a 1-5 scale to assign a specific level of severity to each individual harm. It is not a quantitative scale. In case of financial risk, you could use a more quantitative scale in terms of money or other metric.
So, that means FDA would allow us to take the risk of killling 1 in 1000 if others lose significant weights ? Actually, who and when will decide that numbers? Is it kind of estimation before market, and live data at post-market? If more people get injured or damaged, then we should reconsider the risk analysis again. By the way, thank you so much for all of your videos :)
You are correct that benefit-risk is evaluated given the available information at the time of pre-market approval. You can refer to the FDA guidance referenced in this video. You are also correct that FDA's assessment may change in the post-market phase if the actual real-world safety performance is worse than the pre-market assessment.
Great session Naveen! Thank you for having me on. ⭐
My pleasure!!
What about how to use it and no phone around. Dose it need an intent?
just making sure, you have to use the app to use the test correct?
How do i do this w/o a phone?
Very stupid design. Can not be used on the easy way. Do not buy.
In case anyone needs to use this test in the future, be aware that it is single use only. And if for some wile reason the app crashes or the result is "Invalid", try tearing the cartridge down. The kit is way too expensive to trash it and try again. Use a flat head screwdriver to split it open and look at the test strip inside to see if there is a line in the test area and that the control line has worked. Twice ive had this test brand give me invalid results. No other interruptions occured, or time problems. When taken apart, test strip appears to be fine and in working order. Therefore, if you have these test kits for some reason and theyre being ridiculous on the app, tear them down and take a look at the test strip yourself. I received multiple boxes of these from the USPS, for visually impaired. I do not know how these could be beneficial to visially impaired since there are more steps in this method than others, and requires reading on a cell phone. There is a brand of strep tests that I recall using many years ago that has large plus signs that pop up, lateral flow kits, and I would assume the same could be made for covid using similar kits. Would be much better than this kit for visually impaired.
as per ISO 24971 if probability of hazardous situation leading to harm is very low or high it can be taken as 1 but is this approach is correct it is question for you sir Thank you very much My name is Chinmay Sapre I work as a quality engineer
Hello Chinmay - yes you can assume P2 as 1. This is the most conservative approach. However, make sure to use probability values and not probability levels. For example, if P1=0.01 and P2=1; then POH will be 0.01*1 = 0.01.
Hello Sir Thank you for reply While calculating P1 Should i directly use Complaints/ devices sold as P1 or any further calculation is needed can i add number of complaints and no of defective devices and divide sum by devices sold would that be a accurate prediction of P1 one more approach i am thinking is if i divide defective devices due to hazard over total sales please let me know which approach is the best
@@chinmaysapre6956 check out this article to learn more about how you can estimate P1, P2 using complaints data naveenagarwalphd.substack.com/p/using-pms-data-to-determine-changes-in-risk
Hello doctor, How is it possible that a testing machine at work tells a person that they tested positive but the same person, on the same day takes home Antigen tests five times in a row and from five different brands and has a result of NEGATIVE and then also goes to take a PCR test and test result is also NEGATIVE too. What can cause a work place machine to give someone a FALSE POSITIVE test result.?
Hi Dr Agarwal. I have a cough/sore throat. I tested positive with a very faint line on one antigen test, but negative on two others. The next day I tested negative on two additional tests. Should I consider the one positve test as being accurate?
Hello Naveen thank you for Video on Risk Analysis and question is any case study or information on risk analysis, how to identify the risk associated to Medical device...some glance on it..
no reason i need a fucking bluetooth device and an app for a home test. just crack the device and take the stick out and rub it on there for anyone wondering how to do this test
I agree with your examples. However ISO 14971:2019 Table C.3 provides examples of Hazardous Situations that encroach into the Harms territory. Their example of a Biological Hazard: Sequence of events: 1) Inadequate decontamination of anaesthesia tubing, 2) Contaminated tubing used during anaesthesia Hazardous situation: Bacteria released into airway of patient during anaesthesia Harm: bacterial infection If I understand your examples, it would be written as: Sequence of events: Inadequate decontamination of anaesthesia tubing, Hazardous situation: Contaminated tubing used during anaesthesia Harm: Bacteria released into airway of patient during anaesthesia leading to bacterial infection I would argue that the Hazardous Situation exists as soon as the contaminated tubing is available for use, without even coming into contact with a patient. Same logic for an exposed live wire or a wet floor. Thoughts?
I am trying to understand the standard after 4 years of it's revision. The insights in the video are very much helpful. I have watched other videos on let's talk risk and I find them interesting because of the practical approaches you use to explain the concepts. Please keep posting such useful information. Looking forward to much more concepts in medical device industry. Thank you for sharing your knowledge.
I missed the following information on my antibody test. Sars cov-2 IgG AB normail value Neg 23.0 AU/ml Thanks
I do not know if the following comment was submitted. Will try again. On April, 2021 I had my second Pfizer covid shot. I was age 89. The next day I went into heart failure with no apparent hope of recovery. It took many weeks to recover to a point where my health was better thanks to great care from doctors. On June 12th 2023, I had what seemed to be Covid. The test kits provided by the government tested negative. I was sick with the usual runny nose, continuous cough, weakness, etc lasting 5 weeks which did seem to be Covid despite the negative test result. We recently learned a daughter did have Covid during a visit in May/June although she had no indications. Surprisingly, an antibody high positive test result for her did show a definite recent case of Covid in the prior 4 to 6 weeks. To possibly confirm my case, I had an antibody test done. It is a positive 800. It was performed using DiaSorin Liaison (R) Sars-Cov-2 Trimeric S lgG assay. Can you please tell if this indicates my recent sickness was Covid, perhaps a variant? To my knowledge I have not had any illness between my last vaccine in 2021 and this recent illness in June. Please advise and thanks.
Many thanks sir
Great presentation! Thank you for your sharing!
i wonder during the analyzing time, if the phone turns black, what would happen. usually by default the phone is set to turn black in 30 sec or 1 min if no activity....
Hi sir, i want to know the risk management of medical device Percutaneous coronary interventions (PCI)
Brilliant, your ifu should have usability assessments as its an interface.
Hello sir.....your sessions are very informative Can you please tell us how to calculate the risk?
Hi - thank you for your comment. Subscribe to my newsletter for more practical tips on risk management naveenagarwalphd.substack.com/
Hi! I have a question. what happened if the fluid dropped on my phone, then my mom touched my phone, and she didn’t washed her hands after she touched my phone, then she touch all over the house, will this be danger? I heared the chemicals in the fluid is not safe, I am so anxious right now.
video is good, but, what a dumb test it is !!!
Ellume brand is stupid. What a waste!!! Avoid Ellume Brand and the company!
Where is the data for effectiveness against omicron?
great video, unnecessarily complex device compared to all other ones. what a waste of electronics
Thank you so much for what you do!
Stay away! It's needlessly complicated and expensive. You need a smartphone and an app. I strongly suspect it data mines. Hard pass.
2 things to share. The internals is a sensor looking for a line. The app may fail and then never be able to give you a reading but you can try to redo the test if you break open the case, take the test strip and do the same thing. The process is pretty similar to a pregnancy test. 1st line for control, 2nd is for positive or negative. The second thing is cr2032. Its a very common battery for garage door openers, some watches, gameboy cartridges, or just general electronics. Reduce e waste by salvaging these barely used batteries.
@@Inapeartree @Panda Puff Cr2032 is used in low power applications such as garage door openers that takes months or years before the battery runs out. Anyways, as I said, as long as you have enough material for the regular procedure and wet it on one end and wait 15 mins, the test works on the same principle and the sensor and app just uses a weak light sensor to detect the presence of a line. It can be pried open with a screwdriver but the case will break. My original point was saying its irresponsible to make such a disposable piece of tech, especially with batteries inside of them that would otherwise be single use. If you have a bunch to spare, just try one and see if you think its worth it to buy similar ones or even order it if its covered by your insurance.
Thank you Naveen ji for sharing it with crisp & clear ...quite helpful
This test is awful, I do not want to download any apps nor give my personal info. I just want the simple test that I can read myself in minutes, leave my phone out of it.
Dont forget to take out the battery and use it for something else like tea light candles or your tamagatchi.
Thank you stay safe and healthy 🧘♀️