Agenda - Health Sciences Authority · Any warnings and precautions must correspond between clinical...
-
Upload
truongkhanh -
Category
Documents
-
view
213 -
download
0
Transcript of Agenda - Health Sciences Authority · Any warnings and precautions must correspond between clinical...
17/03/2012
1
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
HSA BRIEFING & WORKSHOP ON CLINICAL
DEVELOPMENT OF MEDICAL DEVICES
Danielle Giroud
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Agenda
Clinical Evaluation methods and
definitions
Clinical evaluation through existing data
Clinical evaluation through prospective
clinical investigation
17/03/2012
2
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Agenda
Clinical investigation design
Clinical investigation conduct
Post market surveillance
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
CLINICAL EVALUATION
METHODS AND DEFINITIONS
Part 1
17/03/2012
3
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Medical device lifecycle
Changes to the device or new design
IDEA TO PRODUCT CONCEPTION
Proof Of Concept & Risk Assessment
. .
.
. Design Engineering
Regulatory Strategy
PRELIMINARY PRODUCT FREEZE
Manufacturing
Quality Assurance
DESIGN VERIFICATION
PRE-CLINICAL VALIDATION
Toxicology Sterility
Biocompatibility
SAFETY/ PERFORMANCE EFFECTIVENESS VALIDATION
First in Man
PRODUCT FREEZE DESIGN VALIDATION
FINAL CLINICAL EVALUATION
MARKET RELEASE
POST MARKET SURVEILLANCE
Reimbursement Strategy
Pivotal Trial
MASS PRODUCTION
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Clinical Evaluation methods
Clinical Evaluation is the assessment and analysis of
clinical data pertaining to a medical device, to verify
clinical performance and safety of the device, when used
as intended by the manufacturer.
Demonstrating safety and performance is part of the
essential principles applicable to all devices.
17/03/2012
4
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Clinical Evaluation methods
Clinical evaluation through : 1. Critical review of existing data - ALWAYS
2. Prospective clinical investigation – when needed
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Defining the claims 3
Clinical Performance and safety
Clinical performance, effectiveness and safety
Performance vs. Effectiveness
17/03/2012
5
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Defining the claims 3
Clinical Performance and safety
Clinical performance, effectiveness and safety
Performance vs. Effectiveness
Clinical Performance (ISO 14155:2011) behaviour of a
medical device or response of the subject(s) to that medical
device in relation to its intended use, when correctly applied
to appropriate subject(s)
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Performance vs Effectiveness
(WHO)
‘A device is clinically effective when it produces the
effect intended by the manufacturer relative to the
medical condition.’ For example, if a device is intended for pain relief, one expects the device to actually
relieve pain and would also expect the manufacturer to possess objective, scientific
evidence, such as clinical test results, that the device does in fact relieve pain.
17/03/2012
6
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Performance vs Effectiveness
(WHO)
‘Clinical effectiveness is a good indicator of device
performance. Performance, however, may include
technical functions in addition to clinical effectiveness.’ For example, an alarm feature may not directly contribute to clinical effectiveness but
would serve other useful purposes.
‘It is easier to measure objectively and quantify
performance than clinical effectiveness.’
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Performance vs Effectiveness
(WHO)
‘Performance is closely linked to safety.’ For example, an infusion pump that does not perform properly and allows wrong flow
rate can induce serious clinical safety problems to the patient. A patient monitor that
does not perform well could pose serious clinical safety problems to the patient.
‘The safety and performance of medical devices are
normally considered closely together.’
17/03/2012
7
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
CLINICAL EVALUATION
THROUGH EXISTING DATA
Part 2
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
RA report Critical
literature review
Design dossier
Pre-clinical evaluation
report
Risk management: a continuous
process
Clinical Investigation
data
17/03/2012
8
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Risk Analysis and Management Standards
Risk management
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Risk Analysis Definitions
Risk management
17/03/2012
9
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Risk management
ISO 14155:2011 risk evaluation ‘risks associated with the investigational device shall be
estimated in accordance with ISO 14971 prior to conducting
a clinical investigation’
‘The risk analysis shall include or refer to an objective
review of published and available unpublished medical and
scientific data’
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Risk management
ISO 14155:2011 risk evaluation ‘a summary of the RA, including an identification of residual
risks shall be included in the investigator brochure’
‘residual risks from RA and those associated with the
procedures imposed by a clinical investigation plan cannot
outweigh the benefits’
17/03/2012
10
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Risk management
ISO 14155:2011 risk evaluation ‘risk analysis shall be used as a basis for identifying
anticipated adverse device effects, characterized by their
nature, incidence, severity and outcome’
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Risk management
Common pittfalls with the risk analysis: • Not existing
• Incomplete Technical only – no clinical risks considered
Clinical condition of patient not taken into account i.e. sick patients how well can
they tolerate the new treatment
• No medical/clinical judgement
• Only briefly referenced in the investigator brochure but conclusion
on residual risks is missing.
• Safety claims are not clearly identified.
17/03/2012
11
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Risk management
Clear identification of residual risks • Form the basis for safety claims
• Form the basis of safety objectives of clinical evaluation
Example 1: a bioresorbable implant presents no toxic effects during pre-clinical
validation – but no experience exists on a long term basis in humans. This may
be one of the objectives of a clinical investigation.
Example 2: a bioresorbably implant of a known material used in a different part
of the body – different intended use - . In the RA we may assume no toxic
effects, but this should be an objective of the literature search
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
A. The graphic
Clinical evaluation
Tree steps
1. Risk Assessment
a) Intended use
b) Safety claims or concerns
2. Design freeze
a) Technical characteristics
b) Performance claims
17/03/2012
12
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
A. The graphic
Clinical evaluation
Tree steps
1. Risk Assessment
a) Intended use
b) Safety claims or concerns
2. Design freeze
a) Technical characteristics
b) Performance claims
Step 1: Identify clincial data
Step 2: Appraisal of data sets
Step 3: Analysis and conclusion
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Starting point
The safety points from the risk analysis
The performance claims for a defined medical device design
Within a given intended use
Multiple intended use?
Multiple clinical evaluations
Critical review of existing data: check the methodology
17/03/2012
13
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Starting with
Objectives of a clinical evaluation through existing data
Directly in relation with the proof of compliance to the essential principles
Includes safety data points defined by the risk analysis
Contains detailed performance criteria for the device corresponding to other parts of the technical file.
Questions?:
1. do pre-clinical data indicate safety concerns that require a prospective clinical investigation?
2. Are there more cl aims in the technical file than covered in the evaluation?
3. Are all claims from the risk analysis covered by data from the literature or pre-clinical data? Did we find additional safety data?
4. Are there different performance claims found in the literature?
Critical review of existing data: check the methodology
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Starting with
Formulate the objectives of a clinical evaluation through existing data
Identify clinical data
Questions ?
1. Are data statistically meaningful to support claims?
2. Are there limitations in confirming safety in animals?
3. Have all data been taken into account? Is the search for data reproducible?
4. Is there a plausible justification for dropping certain literature resources?
Critical review of existing data: check the methodology
Small sample sizes
Products subject to warning letters
Unpublished data
Vigilance data bases
No valid conclusions
Does this apply to us?
Including negative results
Learn from the past
17/03/2012
14
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Starting with
Formulate the objectives of a clinical evaluation through existing data
Identify clinical data from
Evaluate
Suitability and quality of the data sources found
Are data meaningful to reach the objective of the clinical evaluation?
Are all applicable data sources used?
Is the strategy for handling duplicate data across multiple publications addressed?
Are data sources appropriate to define the design of a clinical investigation plan?
Critical review of existing data: check the methodology
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Starting with
Formulate the objectives of a clinical evaluation through existing data
Identify clinical data from
Evaluate
Analyze
Apply objective thought process
Use quantifiable methods
Critical review of existing data: check the methodology
17/03/2012
15
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Starting with
Formulate the objectives of a clinical evaluation through existing data
Identify clinical data from
Evaluate
Analyze
Conclude
Statistical strength of the data analyzed in relation to the objectives
Each safety point needs justification in the conclusion
Remaining risks cannot outweigh the benefits to the subjects
Possible risks and discomforts must be described in labeling
Any warnings and precautions must correspond between clinical evaluation report, risk analysis and labeling
Critical review of existing data: check the methodology
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Starting with
Formulate the objectives of a clinical evaluation through existing data
Identify clinical data from
Evaluate
Analyze
Conclude
Safety conclusions need to include consideration of pre-clinical data on the device in question
Take into account additional requirements for specific standards or guidance documents applicable to the medical device in question
Demonstration of evidence for safety and performance ?
• If yes – conclude the report
• If no – conclude the report and define further data needed
Critical review of existing data: check the methodology
17/03/2012
16
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Data from equivalent devices
Critical review of existing data: Choice of comparator?
Clinical condition
Severity and stage of disease
Body site
Patient population
Same intended use
Compare Technical properties
Design
Specifications
Physiochemical properties
Energy intensity
Deployment methods
Critical performance requirements
Principles of operations
Conditions of use
Compare Biological properties Biocompatibility of materials in contact
with same body fluids/tissue
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Clinical competence
Technical/procedural knowhow
Regulatory knowhow
Research methodology
Author free from any conflict of interest or
supported by independent review
Manufacturer
Critical review of existing data: expertise
17/03/2012
17
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
No
Yes
Yes
Sufficient data to demonstrate safety and performance?
Clinical evaluation through existing data
(literature review)
Report ready for conformity assessment
Plan post market clinical follow up as appropriate
Additional safety or performance criteria
found?
Take additional findings in consideration in risk
analysis and design file
Critical review of existing data: in summary
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
No
No
Yes
Yes
Sufficient data to demonstrate safety and performance?
Clinical evaluation through existing data
(literature review)
Report ready for conformity assessment
Plan post market clinical follow up as appropriate
Plan further actions
1. Additional literature
2. Prospective clinical investigation
Additional safety or performance criteria
found?
Take additional findings in consideration in risk
analysis and design file
Critical review of existing data: in summary
17/03/2012
18
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
CLINICAL INVESTIGATION
Part 3
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
A. The graphic
Available data
Justifies the design
Justifies the clinical investigation
Lack of data
Literature must be reviewed
Clinical Investigation:Pre-requisites
17/03/2012
19
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Open non-randomized clinical investigation
Randomized
Single
Safety and performance validation
To confirm safety and effectiveness endpoints
Double
Used to eliminate the subjectivity of data. Difficult to set-up.
Type of study
Design of a clinical investigation
Blinded
Types of clinical investigations
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Need to start with a
pilot population
Usually to confirm the
design of new device
Can help determine the follow
up time points for endpoints
Type of study
Pilot investigation
Design of a clinical investigation
Types of clinical investigations
17/03/2012
20
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Interim analysis
Problems found No problems found
Investigation goes on
Fix problems
Requires an amendment :may cause delays
Type of study
Pilot investigation
Design of a clinical investigation
Type of clinical investigations
Pilot as part of the pivotal study
Pivotal investigation
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Post market Surveillance
program
Type of study
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Types of clinical investigations
17/03/2012
21
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
CLINICAL INVESTIGATION
DESIGN
Part 4
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• Understanding the device to be studied
• Unmet need
• Phase of development
• Environment
17/03/2012
22
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• Unmet need
• Benefits, risks, importance, market
size, idiosynchracies
• Narrow down therapeutic area where
needed
• Cross Medical speciality lines i.e. who
needs to be addressed/involved
• How does the new device address the
unmet need similar or different from
standard of care?
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• Phase of development
• Prototype
• Frozen design
• Is design likely to change during the
investigation?
• Influences the timelines
• Type of study
• Need for amendments – delays
• Does your device changes standard of
care
• Usually requires more data to
convince users
17/03/2012
23
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• Phase of development
• Does your device influences/changes
surgical technique habits of the user
• If so, foresee training and
• Include sub-analysis for first use
by each new investigator.
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• Environment
• Classification of the device
• Innovative or ‘me-too’
• Impact on regulatory strategy
• Choice of control group
• Company – start up of large
multinational
• Competitors – availability of experts
• Reimbursement – payor acceptance
17/03/2012
24
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• Basis for endpoints
• Critical literature review
• Methods/results
• Define acceptable results
• Understand safety issues and
pitfalls
• Risk analysis
• Define possible safety issues
• Define possible technical issues
• Summary of safety and effectiveness
from US regulatory filings on other
devices
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• Basis for endpoints
• Clinical input from experts
• FDA website for guidance documents
• Vertical standards – product specific
17/03/2012
25
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• If control group is involved, how to choose?
• How comparable is invasiveness?
• How comparable is the procedure
involved?
• How will patients or Investigators
accept a control group?
• What are the risks involved?
• What are the pre-requisites to enter
the study – be randomized?
• Do we want to show ‘equivalence’,
‘non-inferiority’ or ‘superiority’
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• What are the parameters
• Objective
• Subjective
• Device operator
• Patient questionnaires
• When are they best measured and do
these interfere with standard patient
care
• Are measurements reproducible i.e.
variability or error in measurments
versus expected difference of control
group (if involved)
17/03/2012
26
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• Define a quantifiable change in a
parameter over a specified time or at a
specified time post procedure for a specific
percentage of patients
• e.g. how to define ‘no neurological
deficits’
• Motor vs sensory or both
• How much change is expected at what
timepoint and how long do the
symptoms last
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• Carefull with objectives such as ‘absence
of’ or ‘freedom from’ – if zero expectations
then failure is likely
• Define reasonable objectives
• IVD – set false positives and false
negatives at reasonable levels. Again zero
levels will lead to failure
• Base reasonable success criteria on early
results of pilot investigations if available
17/03/2012
27
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Post market surveillance
Design of a clinical investigation
Defining the design
Operationalise the broad strategy
• Involve statistics
• Extrapolate early pilot data to larger
scope
• Set goals for comparing endpoints i.e.
equivalence, non-inferiority, superiority
• Consider larger sample size with better
chance on success criteria versus cheaper
trials with more risk
• Avoid over-optimisme usually induced by
marketing or management. Better exceed
endpoints than fail to get approval
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Number of subjects
Statistical
significance …
… can be identified trough pilot
studies with limited subjects
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Number of subjects
Post market surveillance
Design of a clinical investigation
Defining the design
17/03/2012
28
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Duration of follow up
Follo
w u
p
Sufficient duration to reach the objectives and collect data on the endpoints.
Do not shorten timelines, need to cover the necessary follow up covering duration of device
contact with the body
Based on conclusions of the risk analysis.
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Number of subjects
Duration of follow up
Post market surveillance
Design of a clinical investigation
Defining the design
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Duration of follow up
Lon
g f
ollo
w u
p
The expected drop out rate
Severity disease Long follow up
Important drop out rate
Drop out rate can be 0% if the disease is low
risk, and follow up short term.
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Number of subjects
Duration of follow up
Post market surveillance
Design of a clinical investigation
Sho
rt f
ollo
w u
p
Defining the design
&
17/03/2012
29
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Eligibility criteria
If no data exist or limited follow up available, foresee further post market
clinical follow up data.
The patient population of a pre-market approval study is a small limited representation of the real
market population
Type of study
Objectives / endpoints
Pilot investigation
Pivotal investigation
Number of subjects
Duration of follow up
Eligibility criteria
Post market surveillance
Design of a clinical investigation
Defining the design
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Content according to ISO 14155
A synopsis
The document identification
Sponsor name and address
Identification of the participating sites
A full description of the device
The justification for the design of the clinical investigation
Risks and benefits of the investigational device and clinical investigation
Objectives and hypotheses
Clinical Investigation Plan
17/03/2012
30
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Content according to ISO 14155
Design of the clinical investigation
Devices and comparators
Eligibility criteria
Criteria for withdrawal
Point of enrolment
Total expected duration
Expected duration of subject involvement
Total number of subjects
Enrolment duration
Clinical Investigation Plan
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Content according to ISO 14155
Procedures involved
Monitoring plan
Statistical considerations
Data management and quality control of data
Management of amendments of the CIP
Handling of deviations from the CIP
Device accountability process
Statements of compliance
Informed consent process
Safety reporting
Clinical Investigation Plan
17/03/2012
31
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Content according to ISO 14155
Conditions and process for including vulnerable populations (if applicable)
Process of suspension or premature termination of the clinical investigation
Publication policy
Bibliography
Clinical Investigation Plan
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Amendments to the CIP
Some amendments are study wide applicable
Some specific amendments for a given site will lead to subgroup analysis
Clinical Investigation Plan
17/03/2012
32
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Contents need to correspond with the data in technical file
Document identification
Name and address of the sponsor/manufacturer
Current design of the device with accurate technical specifications
All pre-clinical data
Existing clinical data
Risk management
Reference to appropriate standards and guidance documents
The
Investigator
brochure
Investigator brochure
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Reflect design changes
Provide the necessary pre-clinical data for each design change
Justifies if design changes with no additional pre-clinical investigations
The
Investigator
brochure
Updates with safety data obtained during a clinical investigation
Investigator brochure
17/03/2012
33
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
The
Investigator
brochure
Foresee periodic reviews of the investigator brochure
Include review of serious adverse events and serious adverse device effects + recall
A review process must be in place during any clinical investigations
Investigator brochure
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Regulatory Authority Notification File
Clinical Investigation plan
Investigator Brochure
Informed consent in national language
Copy of the Case Report Form
Clinical Investigation Insurance Certificate (includes product liability and clinical trial insurance)
Relevant proof of Investigator qualification
CV of Principal Investigator
Certificate of competence (laboratory or other imporant ancillary departments)
Copy of favourable opinion of the IRB/EC
Identification of legal representative (foreign Sponsors)
17/03/2012
34
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Import licenses
Europe labelling ‘for clinical trial use only is sufficient’
Identification of manufacturer and sponsor (if different from manufacturer)
List of countries where the investigation is being performed
Copy of the clinical investigation agreement (between Sponsor and Investigator detailing roles and responsibilities)
FDA requires a list of IRBs and responsible persons
If devices are sold, FDA requires a justification for the price
Regulatory Authority Notification File
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
EU requires a statement of compliance to the essential requirements (MDD Annex VIII §2.2)
Must comply with ISO 13485 but certification may be pending
Copy of labelling including instructions for use
Copy of the risk analysis
Identification of institutions involved
Core labs
Centralised laboratories
Data Monitoring Committee
Critical Events Committee
Amendments of documents already submitted
Progress reports (usually every 6 months)
Regulatory Authority Notification File
17/03/2012
35
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
CLINICAL INVESTIGATION
CONDUCT
Part 5
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Initiation of the clinical investigation
Before initiation visit:
written approval / favorable opinion
of the EC
if required, regulatory approval
EC approval
Patient recruitment
Initiation visit Early start
Non-compliance
Personnel training
17/03/2012
36
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Monitoring
Monitoring plan must contain activities to
ensure compliance with
CIP
ISO 14155
Other applicable guidelines
Ethics committee and regulatory
requirements
Monitoring activities
Activities of the monitor
Frequency of the activities
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Monitoring
Monitors must be trained on
Investigational device and
procedures involved
Clinical environment, specifics of the
disease, complications etc.
Clinical investigation plan,
investigator brochure
ISO 14155:2011 and applicable
regulations
Monitors compared to pharma studies are
Much more involved in the product
handling
Must be able to provide guidance to
Investigational site personnel about
the investigational medical device
handling and procedures involved
Must be able to detect use errors,
know what to do in case of
malfunctions
Familiar with safety and device
deficiency handling.
17/03/2012
37
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Classification of adverse events
Classification Criteria
Related vs.
unrelated to
the device/ procedure
Non-serious
vs. serious
outcome
Anticipated
vs.
unanticipated
Safety reporting
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Classification Criteria
Related vs.
unrelated to
the device/ procedure
Non-serious
vs. serious
outcome
Anticipated
vs.
unanticipated
Classification of adverse events – Device related / procedure related /
unrelated
Safety reporting
17/03/2012
38
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Classification Criteria
Non-serious
vs. serious
outcome
Anticipated
vs.
unanticipated
Classification of adverse events – Device related / procedure related /
unrelated
Related vs.
unrelated to
the device/ procedure
Adverse device effect
Adverse event related to the use of a medical device
Results from:
Insufficiencies or inadequacies in the instructions for use,
the deployment, the implantation, the installation, the
operation or any malfunction of the medical device.
User error or intentional misuse.
Safety reporting
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Classification Criteria
Related vs.
unrelated to
the device/ procedure
Anticipated
vs.
unanticipated
Classification of adverse events - Non-serious vs. serious outcome criteria
Non-serious
vs. serious
outcome
The event led to:
Death
Serious deterioration in subject’s health
Fetal distress, fetal death, congenital
abnormality, birth defect
Life-threatening illness or injury
Permanent impairment of body
structure or a body function, or
In-patient hospitalization or
prolongation of existing
hospitalization
Medical or surgical intervention
to prevent life threatening illness
or injury or permanent
impairment of a body structure or
a function
Safety reporting
17/03/2012
39
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Classification Criteria
Related vs.
unrelated to
the device/ procedure
Non-serious
vs. serious
outcome
Classification of adverse events –
Anticipated vs. unanticipated
Anticipated
vs.
unanticipated
Any event which is not listed as expected in the CIP, risk analysis,
investigator brochure or instruction guidelines is unanticipated
Unanticipated is usually only used for serious device related events
Safety reporting
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Subject involved?
Classification of adverse events –
Adverse event decision tree
Yes
No
Yes
No
Yes
No
Yes
No
Yes
Un- anticipated?
ASADE
AE
ADE
USADE
SAE
Serious?
Serious?
Device Related?
Adverse event decision tree:
17/03/2012
40
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Classification of adverse events –
Adverse event decision tree
Not adverse event as nothing happened to the subject
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Timelines - Investigator
Timelines are crucial:
Investigator Sponsor and EC/IRB
Can get serious remarks from their EC
An ‘immediate’ reporting rule should be
applied
17/03/2012
41
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Timelines - Sponsor
Timelines are crucial:
Investigator Sponsor and EC/IRB
Sponsor
Regulatory authorities
Critical events committee, data
monitoring committee
May request to suspend a CI for safety reasons
Should sets up a good communication system
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Decision/
Trend
analysis
Multiple-centers reporting
Investigators
Critical events committee
(CEC)
Sponsor Data
monitoring committee
(DMC)
Guarantees the overall
continuing safety of subjects
17/03/2012
42
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
6.5.1 Documents and
documentation amendments
Justification needs to be given for any
amendments to essential documents
Amendments must be approved
between sponsor, investigator and
coordinating investigator
Amendments must be notified to ethics
committees and, where appropriate, to
regulatory authorities
Amendments must be clearly identified
by version number and date
Coordinating investigator
Investigator who is appointed by the sponsor to coordinate work in a multicentre clinical investigation.
Clinical Investigation Documents and Documentation Amendments
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
6.5.2 Documents and documentation
subject identification log
Log identifying subjects enrolled links
identification code to subject name or
other means of identification
Contains confidential data
Must remain on the site
Subject Identification Log Traceability of all subjects
17/03/2012
43
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
6.5.2 Documents and documentation
subject identification log
Written procedures
Records of compliance of all parties
Ensure auditing requirements
Justify any exceptions made to the ISO
14155 requirements
Integrate into Manufacturers overall
Quality System ISO 13485
Clinical Quality System Compliance and success
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Device Accountability
Device accountability records include
date of receipt
identification of each investigational
device (batch number, serial number
or unique code)
expiry date, if applicable
date of use with the subject’s
identification
date returned/explanted from subject,
if applicable
date of return of unused, expired or
malfunctioning investigational
devices, if applicable
In most cases written procedures are needed!
17/03/2012
44
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Final version
Based on all versions of the clinical investigation plan
Provide an overview of all amendments
Coherence between conclusions in the clinical report and
objectives and endpoints stated in the clinical investigation
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Author
Scientific competences and technical understanding of the device.
17/03/2012
45
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Notifications
Ethics committees
Regulatory authorities
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
CLINICAL EVALUATION
POST MARKET SURVEILLANCE
Part 6
17/03/2012
46
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Definition
Post market surveillance is proactive in order prevent or
minimize harm to patients.
A methodology including expert involvement in the interpretation of the
data is in place
Collection of the data is done according to a well defined plan
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Post market surveillance activities
May vary and are mainly dependent on the risk level of the product itself.
Vigilance reporting
Vigilance reporting is an output of post market surveillance
Post market surveillance activities
17/03/2012
47
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Post market surveillance activities
Post market surveillance activities – IMPORTANCE!
Decision to conduct PMS Innovativeness Severity of disease Sensitive target
population Risky anatomical
location Well known risk Lack of long term data
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
3 2
Post market surveillance plan 4
Link your post market surveillance to the risk
analysis
From pilot to mass production
Think of this as a continuous improvement process
Steps to ensure we close the loop and setup an active PMS plan
1
Risk Analysis
17/03/2012
48
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Knowledge is
essential to ensure
compliance and fast
track to market
17/03/2012
49
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Year 1 Year 2 Year 3
New / changedrequirements per year
Existing / maintainedrequirements
Continuing education
Gap!
20% increase in knowledge requirements annually.
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
• Non-compliance issues
• Risk of delayed market access
• Ineffeciency, loss of productivity
The Problem:
17/03/2012
50
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Efficiency
Velocity
Timeliness
Consistency
E-learning allows learners to cover the same material
in half the time of instructor-led training
Training can be deployed on-demand within minutes –
not weeks or even months
Learners receive what they need – when they need it
Quality of training delivered is consistent and
continuously updated
Why Online Learning?
17/03/2012
51
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Course Catalogue
Learning Center
Courses & Exercises
Quiz
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
ISO 14155: In Depth Review
The medical device industry’s most trusted source for professional online training.
7 Course Suite WMDO has created especially for medical device professionals the powerful online training suite: “ISO 14155: In Depth Review” to get you up and on the right track now. Developed by WMDO clinical expert and TC 194 WG4 convener for ISO 14155, Danielle Giroud , WMDO is proud to offer a powerful suite of seven online courses packed with 3.5 hours of valuable, up-to-date information and knowledge resources on the new ISO 14155. These seven online courses provide crucial guidance and support for medical device professionals working in clinical, quality, and regulatory roles responsible for compliance to ISO 14155. The WMDO ISO 14155 courses not only provide a description of the new standards, but also offer a practical guide on how to implement and become compliant to the new requirements, including real-life examples.
Be sure to check out the online course:
www.wmdo.org
Available now at:
17/03/2012
52
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
ISO 14155: 2011 A Summary Review
The medical device industry’s most trusted source for professional online training.
For all medical device professionals on the go who are short on formal knowledge concerning the latest revision of the ISO 14155, but who do not require the comprehensive or in-depth details as found in the 7 course suite: ISO 14155: In Depth Review, WMDO proposes this condensed yet inclusive summary review of the standard to get them up to speed. ISO 14155: 2011 A Summary Review will provide you with an understanding on when to apply the ISO 14155 requirements, what are the basics of the ethics requirements, a list of essential tasks and elements during preparation, conduct and closing a clinical investigation with a brief explanation of the main responsibilities of the sponsor and investigator.
Be sure to check out the online course:
www.wmdo.org
Available now at:
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
ISO 14155 Version 2003 vs. 2011:
Gap Analysis
The medical device industry’s most trusted source for professional online training.
The ISO 14155:2011 has been published with many new requirements
compared to the previous version and contains major changes that will have a
significant impact on the clinical quality systems and related documents such
as case report forms and clinical investigation plans, informed consents and
investigator brochures and more.
Clinical and quality assurance managers should not underestimate the work
needed to incorporate all the changes brought with the ISO 14155:2011. To
help you with this tedious exercise, WMDO has created the ISO 14155
Version 2003 vs. 2011 Gap Analysis that will clearly lead you through the
hundreds of changes across more than 175 posts between the two
documents. This comprehensive and valuable resource will help you save
significant time and effort in completing the upgrade of your clinical quality
system.
Save Time and Eliminate Errors With New Gap Analysis!
www.wmdo.org
Available now at:
17/03/2012
53
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Risk Management for Medical
Devices in the EU & US
The medical device industry’s most trusted source for professional online training.
3 Course Suite This suite has 3 courses. Course one is a review of the risk management standard ISO 14971-2007. Course two explains how to prepare a Risk Management File and which techniques apply. Course three shows how to integrate Risk Management into the Quality System. Learn to identify, implement, verify and maintain risk control measures to reduce risk associated with medical devices to an acceptable level.
Be sure to check out the online course:
www.wmdo.org
Available now at:
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Adverse Event Processes
The medical device industry’s most trusted source for professional online training.
This course provides you with an expert review of the overall regulatory requirements according to ISO 14155 and EU and US requirements. It provides a basic overview of how to consider adverse events in clinical investigations and how to effectively record, report and analyze the data.
Be sure to check out the online course:
www.wmdo.org
Available now at:
17/03/2012
54
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Safety Related Committees
Establishment
The medical device industry’s most trusted source for professional online training.
2 Course Suite Throughout the years, it became apparent that an unbiased independent approach was needed to ensure that ethics and patient protection was applied in clinical studies; hence the development of the various safety related committees: CEC and DSMB. Professionals interested in establishing a safety related committee, specifically CEC/DSMB, will find this suite of courses particularly informative and helpful as it will provide you with extensive details on not only what a CEC/DSMB is and what it does, but also how a CEC/DSMB functions; including its roles and responsibilities as well as a review of the standards and regulations by which clinical trials are conducted and CEC/DSMB database management.
Be sure to check out the online course:
www.wmdo.org
Available now at:
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Clinical Evaluation for Market
Approval and Clinical Trials
The medical device industry’s most trusted source for professional online training.
3 Course Suite Manufacturers planning to market their devices in Europe are now required to furnish clinical data in line with the new European Directives that came into effect as of March 21, 2010. This intensely comprehensive 3 course suite on Clinical Evaluation for Market Approval and Clinical Trials will empower you with the essential information, requirements and guidelines you need to successfully and accurately conduct clinical evaluation under the new European Directives. From regulatory process and compliance to literature review and conformity; get on the right track to market approval today.
Be sure to check out the online course:
www.wmdo.org
Available now at:
17/03/2012
55
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
Device-ified?
Now get certified!
The medical device industry’s most trusted source for professional online training.
The WMDO Certification Program provides a unique opportunity for medical
device professionals from around the world who are seeking formal
recognition of knowhow tailored exclusively to the specific needs of the
medical device industry.
Applications for Certified Medical Device Associate (CMDA) in clinical
evaluation are now being accepted
Pre-registration:
Candidates wishing to apply for CMDA certification in clinical evaluation may do so now by pre-registering at wmdo.org.
WMDO CERTIFICATION PROGRAM
www.wmdo.org Pre-register now at:
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
17/03/2012
56
HSA industry workshop clinical evaluation medical devices © 2012 WMDO
For more information:
www.wmdo.org
Or contact
Anytime. Anywhere. Anyone. Medical device training the way it’s supposed to be.