Beruflich Dokumente
Kultur Dokumente
Pietzsch
Department of Management Scienceand
Engineering,
Stanford University,
380 PanamaWay,
Stanford, CA94305-4026;
Wing Tech Inc.,
9916 Newhall Road,
Potomac, MD20854
Lauren A. Shluzas
Department of Management Scienceand
Engineering,
and Department of Mechanical Engineering,
Stanford University,
380 PanamaWay,
Stanford, CA94305-4026
M. Elisabeth Pat-Cornell
Department of Management Scienceand
Engineering,
Stanford University,
380 PanamaWay,
Stanford, CA94305-4026
Paul G. Yock
Department of Bioengineering,
Stanford University,
James H. Clark Center,
318 Campus Drive,
E-100,
Stanford, CA94305-5428
John H. Linehan
Department of Bioengineering,
Stanford University,
James H. Clark Center,
318 Campus Drive,
E-100,
Stanford, CA94305-5428;
Clinical and Translational Sciences Institute,
Northwestern University,
750 North LakeShoreDrive,
Chicago, IL 60611
1 I ntroduction
1
Medical devices contribute significantly to the continuous improvement of healthcare. With product lifecycles that are sometimes as short as 18 months, patients benefit from a continuous
stream of innovation that hinges heavily on successful needs assessment and the experience and skills of engineers and other
professionals involved in the innovation process. Yet, bringing a
new product successfully from the bench to the bedside is highly
complex and depends heavily on the implementation of rigorous
processes. These processes need to allow developers to optimally
1
In the context of this study, medical devices are defined as technologies used in
the diagnosis, cure, mitigation, treatment, or prevention of diseases or conditions that
do not achieve their primary treatment effect by pharmacological, immunological, or
metabolic means.
Manuscript received May 12, 2008; final manuscript received May 3, 2009; published online June 17, 2009. Review conducted by Paul A. Iaizzo.
phase development, testing, and other activities, and to successfully execute on the manifold requirements of third parties, including regulators and payers. These additional requirements set
medical device development apart from the development of other
products.
The objective of the empirical study presented here is to give a
detailed overview and model representation of the medical device
development process and its various activities and decisions. The
motivation for this work is twofold. First, a thorough understanding of the multiple streams of activities and responsibilities in
device development can help engineers and other professionals to
execute the bench-to-bedside process of product development
most effectively. By understanding the intricacies and challenges
of development and commercialization, the development team can
better anticipate external requirements and their implications for
decision-making. This can contribute significantly to successful
product innovation, especially in light of the many startup companies that provide innovation in the medical device industry. Second, the ongoing efforts by regulators and policymakers to design
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2 Background
2.1 Product I nnovation and Development Process M odels.
Product innovation and the successful management of new product development has been the focus of both academic research and
managerial concern for more than 2 decades !1,2". At the heart of
these efforts is the development of an understanding of the factors
responsible for new product success, and the desire to drive new
products from idea to market faster and with fewer mistakes. This
also involves research on the optimal alignment of the New Product Development #NPD$ effort with the strategic objectives and
competencies of the firm !3", and more recently, questions of optimal product portfolios for innovating companies !4".
One of the most notable contributions of the last 2 decades has
been the development and implementation of stage-gate processes
for product development !5". These models are both conceptual
and operational tools to move a new product from idea to launch,
and recognize that product innovation is a process that can be
managed !5". A stage-gate system divides the innovation process
into a predetermined set of stages, separated by gates characterized by a set of criteria to be met before the product can advance
in the process. Each stage, in turn, is composed of a number of
prescribed activities that are in many cases related and that can
occur in parallel. Typical stages in a new product development
process involve preliminary assessment, detailed investigation,
actual development, testing and validation, and full production
and market launch #compare Ref. !5"$. The rigor of a stage-gate
process facilitates formal descriptions of various activities and
decisions. These descriptions are often summarized in standard
operating procedures and can be useful to define best-practice
approaches to development.
While applications of formal development processes and similar models have been described for a number of industries, including the automotive industry, no comprehensive process model for
new product development has been published for the medical device industry. Rochford and Rudelius !6" outlined a number of
stages and successes for the development of medical products, but
do not provide a comprehensive process description or summary
of activities and decisions. Kaplan et al. !7" described several of
the key activities of medical device development from prototype
to regulatory approval, but do not provide a model of the device
development process.
2.2 Existing Process Representations Associated With
M edical Device Development. A number of graphical representations have been published that delineate various aspects of the
medical device development process. They range from represen021004-2 / Vol. 3, JUNE 2009
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2.2.4 Development Cycle Representations. Several development cycle models exist. One of the most prominent devicelifecycle representations has been created at the FDA by Feigal
#Fig. 7$. The development aspect is covered in the first part of the
cyclic model #design through clinical sciences$. The model emphasizes the role of customer feedback and learning from one
generation of a device to the next, and shows the intertwined flow
of information. Comparable model representations can be found
in the literature, among them a representation by Califf et al. !19"
that emphasizes the clinical and quality aspects in the therapeutic
development cycle. The measures of quality and clinical outcomes
are particularly relevant for all health-economic and outcomesoriented considerations.
2.2.5 Regulatory and Reimbursement Representations. Several model representations of the device development and commercialization process exist to describe its regulatory and reimbursement aspects. These aspects are highly relevant for
development because they can have significant implications for
the design and testing of a new technology.
To represent the different regulatory pathways for medical devices, several flowcharts have been created. A comprehensive representation of the United States regulatory process presented by
Helmus !20" is shown in edited form #Fig. 8$. The figure outlines
the decision process that determines whether a device can be
brought to market via the 510#k$ premarket notification path, or
the alternative premarket approval #PMA$path. Note that exempt
devices #class I$ are not shown in this representation, and neither
are the product development protocol #PDP$ or humanitarian device exemption #HDE$ paths. Additional background and a detailed review of United States medical device regulation can be
found in Ref. !21". A detailed overview of the European device
regulation is given in Ref. !22".
3 M ethodology
The purpose of the present study was to construct a comprehensive representation of the medical device development process by
conducting a field study #between October 2006 and September
2007$ based on in-depth interviews of experts actively involved
with the development, regulation, and use of medical devices.
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Fig. 4 Schematic overview of clinical research in the product development cycle based on Ref.
15
Fig. 5 Schematic representation of the risk management process according to ANSI/AAMI/ISO 14971:2000
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4 Results
4.1 Constr ucted Development M odel. As outlined in Sec. 3
of this paper, construction of the device development model relied
significantly on insights acquired during the sequence of in-depth
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Fig. 8 Regulatory pathways for medical devices representation based on Ref. 20. Legend: QS
Regulation: QSR; IDE: investigational device exemption; IRB: Institutional Review Board
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Table 1
Deliverables and decisions at decision gates for Phases IIV of development model
Fig. 10 Needs-fi nding funneling process and relationship to product development model
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animal studies, to test the physical performance of a device. Continuous interaction among engineers and future device users is
critical during prototype development, in order to ensure that the
new device will satisfy end-user requirements. Likewise, as a device becomes more refined through multiple prototype iterations
and feasibility studies, the IP landscape is continually reviewed,
and potential legal and liability risks are assessed. Throughout
Phase II, R& D will often hold design reviews #per 21 CFR
820.30$ with all cross-functional team members in order to systematically assess a devices design progress. It should be noted
that many companies begin prototyping efforts as early as Phase I
to inform their financial planning and support definition of their
product development strategy.
Design risk analysis/risk management
Risk management is a critical component of the analysis, prototype, and design development phases. The FDA expects companies to have a complete risk management plan and system in
place, which consists of the two aspects of risk analysis #identification and quantification of risks$ and risk management #mitigation of the identified risks$. Several years ago, the industry supported the creation of ISO 14971, which covers risk management
for medical devices and outlines specific methods to identify and
address risk. This standard is now cited in many other standards
and has been recognized and adopted in many countries.
A number of tools exist that are commonly employed to conduct risk analysis and management during Phase II: Design Failure Modes, Effects, and Criticality Analysis #dFMECA or
dFMEA$is used to recognize and evaluate the potential failure of
a product or process and its effects !26". dFMEA is also used to
identify and prioritize actions that could mitigate the chance of a
failure. FTA is another common risk assessment tool. FTA uses
logic block diagrams that display the state of a system #top event$
in terms of the states of its components #basic events$. It can be
used to capture failures resulting from both human errors and
hardware failures. Risks are mitigated to an acceptable level
generally as safe or safer than existing devices used for the same
purposes. Actual mitigation of risks needs to be verified as part of
the design process. In the remainder of this paper, the term risk
analysis is in several instances used as a short form for risk
analysis and risk management. It explicitly includes risk mitigation efforts.
Design for manufacturing
Initial design for manufacturing #dFM$ efforts begins in Phase
II, in parallel with device concept and prototype development
!12". dFM involves developing an initial plan for how fixtures will
be made, how tooling will be developed, what machines should be
used for the devices manufacturing process, and whether or not
molds need to be created in order to build prototypes for verification and validation testing. For devices that build on existing devices on the market, a significant portion of manufacturing work
can be performed at this early development stage. However, for
breakthrough products, manufacturing largely supports R& D prototype efforts during Phase II, while contributing suggestions as to
how proposed devices can be manufactured for high-volume production.
Regulatory and reimbursement strategies
The initial regulatory and reimbursement strategies that were
initiated in Phase I are further developed during the concept and
feasibility stages of development. Different options are examined
regarding which regulatory path to pursue #for the United States
market, for example, 510#k$ versus PMA; for Europe, different
routes to CE marking; etc.$and whether or not clinical studies will
be required. The reimbursement team assesses whether or not existing reimbursement codes #for the United States market, e.g.,
CPT3 and DRG,4 for international markets, the codes used in the
3
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tems Regulation$. A process plan involves a protocol for an installation qualification #IQ$, operational qualification #OQ$, performance qualification #PQ$, and product performance qualification
#PPQ$ !28". After a design is frozen at the end of Phase III, a
process validation plan is often executed by the teams manufacturing engineer and quality engineer in Phase IV. Process excellence tools such as Lean Six Sigma are commonly employed in
this phase and the subsequent phase of the development process.
Regulatory and clinical
During Phase III, several additional activities are conducted by
members of the regulatory and clinical departments. Regulatory
activities include submitting design and test data to the FDA for
review and regulatory approval. FDA submission is a major milestone in the device development process. Preparing for a submission requires a strong collaboration among several crossfunctional areas, such as clinical, R& D, quality, and regulatory.
The regulatory group of a product development team generally
includes a Regulatory Affairs associate who handles submissions
and market clearance, and a Regulatory Compliance associate
who administers the quality system. A teams regulatory group
oversees the completion of requirements needed for international
product use, such as the European CE mark mentioned earlier. If a
device requires clinical trials for regulatory submission, the teams
regulatory group submits an investigational device exemption
#IDE$ to allow the device to be used in a clinical study !25".
Regulatory associates will also oversee the clinical trials, analyze
results, and submit data required for regulatory submission. Clinical trials are of substantial importance for the successful commercialization of medical devices, and thus need to be carefully
planned and conducted. A detailed discussion of the various considerations for clinical trial planning is beyond the scope of this
paper. Additional background and information on this topic can be
found in pertinent textbooks !2931".
Patent review and reimbursement update
The patent review process is continued in Phase III #sometimes
also earlier, in Phase II$to ensure that initially filed IP is sufficient
to protect the developed technology, and to perform a second
check on possible conflicts that could limit the companys freedom to operate !32".
The devices reimbursement strategy is further established in
Phase III, as reimbursement codes and part numbers are assigned
to the new device.
Phase III: Deliverables and decision gate
The major deliverables of phase III and key decisions to be
made at the decision gate are summarized in Table 1.
4.1.2.5 Phase IV: Final validation - product launch
preparation. Phase IV of the medical device development is characterized by the creation of formal design prints, final product
verification and validation, sales launch preparation, and regulatory approval.
Final design drawings and specifications
Once a design is frozen, formal manufacturing prints are generated for the new device, consisting of both component and
assembly-level drawings. Final prints must conform to geometric
dimensioning and tolerancing #GD& T$ standards to ensure that
design requirements are effectively communicated to suppliers
and manufacturers. The same holds for final specifications of electronic components. Tolerance stack-ups are also conducted on the
final design to ensure that there are no mating part interferences
within a device, or between a device and another instrument with
which the device interacts !12". Material specifications, packaging
drawings, and marking and labeling specifications are also finalized during Phase IV.
Design and process validation
Closure of recommended risk mitigating action items per the
companys risk management system #compare earlier comment
Journal of Medical Devices
about ISO 14971$ occurs during the final verification and validation phase of device development. These accompanying design
control deliverables are living documents, which remain active
throughout the life of the device. A process validation/
qualification plan, which includes an IQ, OQ, PQ, and PPQ, is
executed by a quality engineer and a manufacturing engineer in
Phase IV. The IQ documents that a correct manufacturing instrument was received and installed properly, an OQ tests that an
instrument meets specifications in the user environment, and a PQ
tests that the system performs the selected application correctly. A
PPQ demonstrates that the process has not adversely affected the
finished product and that the product meets its predetermined
specifications and quality attributes !33". In Phase IV, manufacturing efforts are often scaled-up in preparation for high-volume
development, although not all production efforts require highvolume scale-up. Statistical process control #SPC$ standards are
established !26" during this phase of development, and a number
of specific indices are commonly used in this context. The socalled Cp is an indicator of process capability !12". Cpk, the
process capability index, involves the adjustment of Cp for the
effect of noncentered distributions. That is, Cpk measures how
close a process is running to its specification limits, relative to the
natural variability of the process !34".
Sales launch preparation
Several sales and marketing activities must take place prior to
the launch of a new medical device. A critical decision that must
be made at the outset of this process is the choice of the appropriate distribution channels, and whether internal or external sales
representatives will be used. A teams marketing associate must
prepare and equip sales representatives with items such as a surgical technique guide that defines how the device is used, videos
illustrating product use, and sample product kits for physicians.
The device is often advertised in medical journals and then showcased at a large meeting or medical conference for physician customers. Sales rep training sites are established, and a training protocol is created for both sales reps and physicians. Specific
hospitals, often referred to as limited market release #LMR$sites,
are identified for initial product release. Product branding occurs
in Phase IV, as marketing works with the legal department to
conduct trademark searches in an effort to determine an appropriate product name. Also, an artist or marketing communications
firm is often hired to create a new logo for the device. Finally,
marketing must communicate with manufacturing and operations
to ensure that product inventory/launch quantities will be available to fulfill projected sales forecasts.
FDA approval, quality systems, and reimbursement
A key requirement that must be fulfilled before a medical device can be launched in the United States market is regulatory
approval/clearance by the FDA. This requirement includes the development and implementation of a working quality system. Also,
a companys reimbursement strategy for the new device must be
finalized in Phase IV. Clinical validation continues before and
after FDA approval has been granted in order to continue monitoring device performance and possibly expand a devices indications for use.
For new medical devices, establishing a quality system is a
large critical task. If the product is a line extension to an existing
device or product family, then a quality system may already be in
place and working well. The quality system starts with defining,
documenting and formally approving and releasing %90% of the
business document/systems, both product specific #product spec$
and administrative #purchasing controls$. This is a resource intensive, time consuming task on a scale similar to the development
process. It is normally done in parallel with the product development, and cannot be done retrospectively.
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5 Discussion
Several activities within the device development process have
been represented as schematic models in the past, among them the
quality function deployment, risk management, and regulatory approval processes. Similarly, a number of overarching models of
the development and commercialization process have been published in the past, for example, the FDAs waterfall model or the
representation of the commercialization process of PMA devices.
None of these representations, however, document comprehensively the medical device development process.
The feedback and responses obtained from interviewees during
the model building process led to a relatively rapid convergence
toward the final linear stage-gate structure presented here. In conjunction with the diverse empirical sample, this suggests that the
constructed model applies to a broad range of medical technologies and innovation settings.
The stage-gate process is comprised of five phases from
initiation/opportunity and risk analysis to postlaunch and postlaunch surveillance. Some minor process differences exist for devices requiring clinical studies #the so-called IDE process for
PMA devices and 510#k$ devices that require clinical data$, and
for non-IDE devices #the technologies not subject to clinical
evaluations during development$. The model presented in this paper embodies the more complete process by including clinical
studies.
The apparent uniformity of the development process across devices and types of companies can be explained by the promulgation of the very detailed and comprehensive Quality Systems
Regulation #QSR-21 CFR 820$ by the FDA. The QSR prescribes
the elements of the design process, including definition of design
input, design output, specification development, testing, risk
analysis, process qualification, etc. A review of the document
shows that significant aspects of the development process are governed by, or at least subject to, regulatory requirements. Regulatory requirements substantively impact the manner in which medical devices are developed and brought to market and, by
impacting the time to FDA approval, largely determine when the
device can brought to the clinic. By standardizing the development process, the public is assured that critical elements of good
design practices are not omitted. But standardization does not always permit streamlining developmental processes where it would
make sense.
Transactions of the ASME
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It should be appreciated that nonadherence to regulatory requirements #and thus, nonadherence to a systematic development
process as the one outlined in this study$ can lead to significant
delays or even the discontinuation of device development. As
such, knowledge about the regulatory requirements and a rigorous
quality system and documentation process are essential success
factors of any device company. In the public discussion, their
impact might sometimes be underestimated, as the focus of discussion is often limited to the regulatory pathways to approval and
the associated data requirements. Early, innovation-oriented technology assessment during development #see, for example, Ref.
!37"$that takes these requirements and the expected performance
of the technology into account, may present an opportunity for
both industry and regulators in further streamlining the innovation
process.
Despite the benefits associated with a rigorous process and
clearly defined procedures, innovation often occurs in a nonlinear,
less structured way, sometimes under unexpected circumstances.
In implementing development processes in organizations, it is
therefore necessary to strike a balance between sufficient process
rigor and enough room for flexibility and creativity. It can be
argued that evolutionary product development benefits from structure, while revolutionary product development is catalyzed by a
less rigorous process environment. Striking the appropriate balance presents a continued challenge for any organization inventing and developing technologies, and will often require adjustment of general process structures to the individual requirements
of an organization. Complexity in process management is added
when innovation is not a purely internal process within an organization, but requires outside collaborations, in-licensing and integration of new technologies, processes, or competences. This is
often the case in medical device development.
Drug-device differences and their implications
Several important differences exist between medical devices
and pharmaceuticals in general, and their development processes,
in particular, #compare, for example, Refs. !38,39"$. These differences need to be understood to appreciate the inherently different
development processes and regulatory requirements between devices and drugs. Drug-device differences are also important to
understand since they help elucidate the challenges associated
with the development of combination products, which increasingly blur the distinctions between medical devices and pharmaceuticals.
Discernable differences between classic devices and drugs
#not considering cells and biomaterials$ include the following:
The phrase device heterogeneity refers to the wide differences in mode of operation, and the wide variety of technologies
with attendant indication-specific design features #ranging from
tongue depressors and implantable joints to implantable defibrillators and artificial corneas$. Among other factors, heterogeneity
leads to a much wider variety in the way devices are tested #e.g.,
wide differences in the types of bench studies performed$ and
regulated. While all new drugs are subject to a single approval
process, medical devices can be approved through various regulatory pathways with differing requirements that influence the duration and complexity of the development process. A major reason
Journal of Medical Devices
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6 Conclusions
The linear stage-gate model gives a comprehensive description
of the various activities and decisions associated with the development of medical devices. A good understanding of this process
can benefit all stakeholders in the bench-to-bedside process of
device commercialization: investors, who need to allocate their
resources in the most efficient way, and who need to understand
the funding requirements of different types of development
projects; engineers and researchers who aim at improving the design and benefit of a technology; and regulators who need to ensure the safety and effectiveness of new products in the most
efficient way.
The process mapping presents several opportunities for the development of quantitative models to support decision-making at
various levels. First, information can be used to create early-stage
technology assessment and risk management models to inform
engineering and funding decisions. These models can subsequently be integrated into more comprehensive lifecycle risk management models that allow for continuous updating of failure risk
and the expected performance of new technologies, information
that can be very useful to both industry and regulators.
As discussed in this paper, the medical device development
process differs substantially from the development process for
pharmaceutical products. An appreciation of these differences is
essential to the appropriate design of future development models
and regulatory requirements for various types of combination
products that cross the line between devices, pharmaceuticals, and
biomaterials.
Acknowledgment
This paper was written based on the research performed by the
authors as part of a study Medical Device Development Models,
funded by the Institute of Health Technology Studies #InHealth$.
The authors gratefully acknowledge the financial support by InHealth.
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