Understanding FDA QSR for Med Devices and Laser Product Performance Standards for Medical and Industrial Radiation Emitting Devices
Leo J. Lagrotte,
Sr. Regulatory Consultant, Quality Solutions and Support, LLC
and Former FDA Consumer Safety Officer
Founder and CEO, Quality Solutions and Support, LLC
Coming soon.. Please contact customer care for new schedule
||Course "Understanding FDA QSR for Med Devices and Laser Product Performance Standards for Medical and Industrial Radiation Emitting Devices" has been pre-approved by RAPS as eligible for up to 12 credits towards a participant's RAC recertification upon full completion.
- Are you struggling with the implementation and maintenance of your medical device Quality System?
- Would you like to ensure that your company operates an effective QSR and Rad Health program which meets or exceeds regulatory expectations and industry best practice standards?
- Are your employees trained to critically identify and assess the impact new products and services will have on their overall risk assessment?
- Is your company aware of its regulatory obligations and the potential impact of non-compliance?
This highly interactive seminar will provide answers to all these questions. Many medical laser manufacturers have failed to capture regulatory requirements for the embedded laser, UV or X-Ray components within their devices, leading to serious regulatory non-compliance issues. It would be prudent to ensure your organization’s compliance program is effective and is tailored to all applicable FDA and ISO regulatory standards prior to distribution, or finding out what possible current regulatory non-compliance issues are key risk factors within your organization’s devices.
Seminar instructor Leo J. Lagrotte is an ex-FDA official having more than two decades of experience with FDA and USDA. At FDA and USDA Mr. Lagrotte received numerous national awards / recognition certificates for exemplary performance. In 2007, he was nominated by Florida District for the Patrick Pouzar Investigator of the Year Award for exceptional performance, integrity and reliability and the FDA Outstanding Service Award in 2011.
This course on medical device QSR will provide an overview of the importance of establishing, implementing and maintaining a product specific compliance program capturing all relevant topics. The attendees will learn about the risk based approach and the essential elements of an effective risk assessment in the design and development of medical and combination medical devices. Attendees will be provided with all the tools necessary to ensure their present medical devices or planned devices meet or exceed required FDA and ISO regulations. The instructor will explain testing techniques which would assist in improving a company’s overall quality system program. Enforcement actions case studies will be reviewed as part of the course and the instructor will discuss how the same could have been prevented. It will also review key internal controls that can help prevent missing out on key requirements.
Key goals of this course are:
- To provide an understanding of the key elements of a medical device Quality System under FDA regulations 21 CFR 820 and ISO 13485
- Provide an understanding of the Radiation Health Performance Standards as they apply specifically to laser/UV medical and industrial devices and short discussions on X-Ray contained devices.
- To meet/exceed regulatory expectations and to ensure the organization is prepared to manage requirements of both converging regulations
- To understand reporting requirements for medical devices containing radiation emitting devices.
- The course will focus on the following key aspects of a medical device Quality System:
- Management requirements for establishing a Quality System
- Design controls and design change controls
- CAPA and non-conformance regulations and monitoring
- Complaint handling procedures
- Adverse event reporting (MDR and vigilance)
- Production and process controls
- Recall and market withdrawal
- Document control
- The course will also discuss the Radiation Emitting Performance Standards as they refer to medical devices
- 21 CFR 1040.10 & 1040.11- laser and UV performance standards
- 21 CFR 1002- reporting requirements for all radiation emitting devices
- 21 CFR 1003; 1004 and 1005, the regulations most costly to non-compliant radiation emitting device manufacturers
- To review the key requirements to ensure your combination product meets or exceeds current regulations.
Who Will Benefit:
- Medical device manufacturers with or without radiation emitting device
- Internal Auditors
- Legal Departments
- Compliance Officers
- Program Managers
|Day One (8:30 AM – 4:30 PM)
||Day Two (8:30 AM – 4:30 PM)
Registration Process: 8:30 AM – 9:00 AM
Session Start Time: 9:00 AM
Welcome and Introductions (30 Minutes)
- Understanding the Basics (1 Hour)
- Description of Medical Devices (Leo)
Quality System (QSIT) (5 Hours)
- Classifications of Medical Devices
- Classifications of Radiation Emitting Devices
Design Controls and Risk Analysis (Steve)
- The Organizational Chart
- Management Representative
- Management Responsibilities
- Internal and Supplier Audits
Design Change Controls (Steve)
- Design Controls - Design History File (DHF)
- Design Input and Acceptance Criteria / Design Output / Verification and Validation Method
- Design Review and Acceptance
- Design Verification – Bench Testing etc.
- Design Validation – Works as Intended – Clinical Study
- Design Transfer
- Design Changes
- Risk Assessment based on ISO 14971
- D.2: Energy Hazards and contributory factors
- D.3: Biological hazards and contributory factors
- D.4: Environmental hazards and contributory factors
- D.5: Hazards resulting from incorrect output of energy and substances
- D.6: Hazards relating to the use of the medical device and contributory factors
- D.7: Inappropriate, inadequate or over-complicated user interface (man/machine communication)
- D.8: Hazards arising from functional failure, maintenance and aging and contributory factors
Document Controls and Electronic Signatures (Steve)
- Engineering Change Notice
- Impact to Risk Assessment
- Design Verification and Validation
- Labeling Changes
Complaint Handling Procedures and Customer Feedback (Leo)
- Document Change Control – Rev changes of existing documents
- Document Distribution Matrix
- Impact on Training
Corrective Action and Preventative Actions (Leo)
- Definition of Complaints
- Documentation and Control
- Who Handles Complaints
- Responsibilities and Authority
- Investigations and Root Cause Determination
- Adverse Event Reporting
- Handling the Regulator
Closing and Discussion (30 minutes)
- Responsibilities of Initiator
- Determining Root Cause and Risk Analysis
- Corrective Action
- How to determine effectiveness of corrective actions
- Transactional Risk
Welcome (15 Minutes)
- QSIT Continued (3 Hours)
- Production & Process Controls (Steve & Leo)
Quality and Production
- Validate supplier (Laser) – Most likely offshore
- Product ordering (lasers) specifications noted
- Product receiving – AQL testing – mW output
- Device Assembly – Verification check – mW output and device functionality
- Packaging and Shipping – Device Traceability
Radiation Emitting Devices (4 Hours)
- Product Realization Control
- Responsibilities and Coordination of Quality & Production
- Definitions and Classifications (Lasers) (Leo)
Conclusion/Wrap up session (30 minutes)
- What’s the Problem
- Regulations and Performance Standard Review
- Quality Controls and Requirements
- Manufacturer who utilize Laser Devices in Manufacturing of their Medical Devices.
- What Other FDA Regulations Pertain to Radiation Emitting Devices
Meet Your Instructors
||Leo J. Lagrotte
Senior Regulatory Consultant, Quality Solutions and Support, LLC
Leo J. Lagrotte is a Senior Regulatory Consultant for Quality Solutions & Support, LLC, a consulting practice offering auditing, training and advising to small, medium and large Medical Device and Radiation Emitting Device manufacturers as a follow-up to 20 plus years’ experience with the FDA and USDA. Mr. Lagrotte’s previous regulatory service was preceded by military service as a commissioned Officer in the US Army, and twenty plus years as a civilian owner/operator of retail food establishments including bakeries, restaurants and catering.
His experience with the FDA commenced as an investigator in Florida District/Tampa Resident Post in 2001 conducting inspections of predominately food processing establishments including all HACCP programs, LACF and Acidified Foods then advancing to Medical Devices in 2003 with the Level II Certified Medical Device Investigator (one of forty-four nationally) in 2005 and Southeast Regional Electro-Optics Specialist for Lasers and UV devices both with medical and industrial application in 2004. He also served on the Medical Device Inspection Cadre and conducted over thirty-five foreign inspections of Medical Device, Laser, and X-Ray manufacturers. During the course of his duties with FDA, Mr. Lagrotte conducted over 500 Establishment Inspections domestically.
Presently, Mr. Lagrotte’s focus is to assist the medical device and rad health community in meeting or exceeding compliance with all FDA regulations and Notified Bodies requirements for certifications, completing 510(k) and PMA submissions and responding to regulating officials as necessary on behalf of clients.
At FDA and USDA he received a numerous national awards / recognition certificates for exemplary performance. In 2007, he was nominated by Florida District for the Patrick Pouzar Investigator of the Year Award for exceptional performance, integrity and reliability and the FDA Outstanding Service Award in 2011.
Founder and CEO, Quality Solutions and Support, LLC
Stephen Inglese is a Founder and CEO of Quality Solutions and Support, LLC. Mr. Inglese began his Quality Systems career with Florida Power and Light (FPL) Company in South Florida. During his career with FPL, he was instrumental in being awarded the prestigious Quality - Deming Award, the first United States firm to challenge then win the award once only achieved by a firm located in Japan.
During that time, Mr. Inglese was placed in a position as a facilitator and was given the opportunity to study under the direction of Japanese Union of Electrical Scientists, then teaching those within various locations of FPL under the Quality Improvement Program. During his time with FPL, Mr. Inglese was also serving in the United States Air Force Reserve. There, as a flyer in a Combat Search and Rescue Unit, he was given the opportunity to assist in the dissemination of the Total Quality Management program to a group of 500 Airman. This quality program provided the tools and techniques to achieve a successful quality improvement process. He continued his quality carrier with the Tribune Company in South Florida as a system analyst in providing data to assist in improving circulation of the firm’s local newspaper.
Mr. Inglese then transitioned to ISO 13485 and the medical device industry. He successfully maintained the ISO / FDA quality system for several medical device manufactures in the medical laser industry. During this opportunity, he created design history files for new devices and technical files to assist in marketing the devices within the United States and off shore. He led the firm through successful implementation of the Quality System as required by FDA and foreign notified bodies, internal and supplier audits and management reviews.
Mr. Inglese founded Quality Solutions and Support, LLC in 2010 to assist firms in maintaining (or developing) their Quality System be it ISO, FDA or Medical Device Directives, Health Canada or other Notified Bodies globally. This includes establishment and maintenance of these firm’s design controls, audits (internal or vendor), technical files and 510(k)s.
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