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​In most regulated industries remediation is a cost of doing business.  Unfortunately the medical device industry is no different.  While remediation won’t hit every business, the fact of the matter is as regulations continue to change and or grow more companies will find themselves in a spot where they are having to change their processes and procedures in order to remain in compliance.
 
In 2021 we wrote about the keys to success, identifying six (6) key areas of focus to help one get through remediation and come out on the other end still in tact and moving forward.
 
As the medical device industry continues to evolve, so must our approach to solving problems we face.  As such, understanding the reasons why a device company may experience failure as they go through remediation is key to learning from others mistakes so we don’t repeat them when it comes our turn.
 
WHY THINGS GO SIDEWAYS
the top 11 reasons why remediation goes wrong for medical device OEMs:
 

1. ROOT CAUSE: failing to fully understand the root cause of the issue and or not adequately addressing all aspects of the problem
2. PREVENTION: neglecting to update or improve processes to prevent future issues
3. REGULATORY COLLABORATION: insufficient communication and partnering with regulatory agencies
4. BIG PICTURE: focusing on short-term fixes rather than solving the longer-term problem
5. RESOURCES & TIME: underestimating the resources and time required for remediation
6. TRAINING: neglecting to train employees on new or improved processes
7. CROSS FUNCTIONAL IMPACT: not considering potential effects on other departments or products.
8. STAKEHOLDERS: not sufficiently involving all relevant stakeholders in the remediation process.
9. END USER: Taking shortcuts or making compromises which endanger patient safety.
10. DOCUMENTATION: lack of adequate documentation, record keeping and associated outcomes
11. VALIDATION: failing to thoroughly validate the effectiveness of the remediation

 
When looking at this list the biggest take away is the starting point.  Once it has been determined remediation is necessary, whether through regulatory intervention or internal, understanding what occurred to get us there in the first place is critical.  If we misdiagnose the root cause of the problem within our operations our ability to successfully navigate through the rest of remediation is be hampered significantly.  For this reason its wise to spend as much time as possible sorting through the cause and effects of your operation to accurately determine the root cause leading to remediation.  Rushing this process will inevitably cause unnecessary challenges on the back end.
 
SOLVING THE PROBLEM
The quickest way to overcome a business challenge is to get help from those who are experienced in besting your beast!  The team at Square-1 Engineering is comprised of a variety of technical and project management professionals who are subject matter experts in NPD, Quality, Compliance (and yes - remediation) and Manufacturing Engineering.  Learn more about how we can solve your compliance problems while besting your remediation beast!

​On January 6, 2023 the European Commission, a political and regulatory steering committee consisting of a group of 27 Commissioners, known as 'the College', adopted a proposal to give more time to device OEMs to certify medical devices under EU MDR to mitigate the risk of shortages. The proposal, which now needs to be adopted by the European Parliament, could push out MDR requirements several years.  Higher risk devices such as pacemakers and joint implants would have a shorter transition period till December 2027, whereas lower risk devices, such as syringes or reusable surgical instruments wouldn't be until December 2028.

Regardless of EU Parliament's decision to potentially extend MDR, device OEMs should consider the following as we hedge through 2023:
1. Strategies for US product approval and or commercialization will continue to increase as OEMs seek alternative pathways to potentially avoid EU MDR compliance.

2. As a result of #1, support to aide OEMs in their go-to-market strategy will intensify causing a shortage for resources, while potentially lengthening the process to get to approvals (supply & demand constraints - notified bodies and consulting firms experience increases in demand causing support shortages).  This will be especially true with remediation work.

3. The idea of putting off or slowing MDR related efforts in the interim to re-focus on other activities may provide momentary relief, however it also creates a long-term liability in the business.  This liability comes with a variety of future unknowns: regulatory landscape, inflation, cost of resources, CRO and notified body constraints, etc.  If you must achieve MDR compliance our recommendation is to get it done and over with in the present. 
​
4. Work associated with achieving MDR compliance can be easily underestimated, especially if you have legacy product where your CE mark was granted pre mid 2000s.  The burden to meet MDR requirements may be steep, which is all the more reason to avoid procrastinating said efforts as outlined in #4. 

​The quickest way to overcome a business challenge is to get help from those who are experienced in besting your beast!  The team at Square-1 Engineering is comprised of a variety of technical and project management professionals who are subject matter experts in the areas of NPD, Quality, Compliance (and yes - remediation) and Manufacturing Engineering.  Learn more about how we can solve your compliance problems while besting your EU MDR beast!

Learn about Square-1 Engineering's mission and what it means to be fearless!

Our client, a Class III medical device company, was issued an FDA 483 warning letter due to product field failures and QMS issues posing life threatening risks to implant patients.

The Square-1 Engineering subject matter experts (SME team) were brought in to identify & correct systems and process issues across six (6) functional departments and two (2) manufacturing  locations domestically.  As you can guess our clients’ situation was dire due to several implant failures in the field.

We invite you to download the case study below to learn how we saved our client $4.5M while successfully concluding the remediation project.

​Want to get through your remediation project successfully?  Doing these two things helps dramatically increase your chances of success.

#fearlessmedtech #remediation #fda #medicaldevice #medtech #quality #compliance #QMS

​Remediation in the medical device industry is often described as a matter of “it’s not if it will happen, it’s when it will happen”.
 
With so many companies over the years going through major remediation efforts one would think by now most people in the business would have a good appreciation for what success looks like to navigate through FDA remediation projects.  Yet, many people will tell you the remediation projects they’ve been a part of were messy, unorganized and a galactic waste of money.  Unfortunately, when we’re faced with remediation there is no choice other than to mend our broken wings before flying home for the summer.
 
This sparks an interesting question – if I have a remediation project ready to deploy what are the things I can do to ensure it succeeds?  Regardless of the project size implementing these six keys to success will drastically help increase your ability to successful execute on your next remediation project:
 
1.       Ensure Your Entire Company (Especially Executive Management) is Onboard
Everyone in the organization, bottom up, needs to understand why this project just went to the top of the work list.  Everyone needs to be bought in and rowing in the same direction, otherwise you’ll experience cumbersome internal issues as mentioned above, which waste time, money and energy.  One can accomplish by using a tactical scorecard as described in #4.
 
2.       Establish Clear, Consistent and Easy Communication Protocols for the Project
Once your entire management team and company is onboard its time to set expectations for communication.  This is one of the most overlooked parts of any large scale project.  It’s especially important when considering cross functional company divisions and the people accountable to working towards successful completion.  When people are misinformed or don’t know what’s going on you can be certain it will slow your project down and cause further product quality and procedural issues down the road.
 
3.       Get a Lobbyist 
You’ll need someone acting as the liaison between your company and the FDA.  Typically, this person comes from your QA/ RA group, but is that the right person?   Don’t assume your de facto executive in QA / RA is the best for the job.  Ensure your company aligns itself with a proven individual who has relationships within the FDA and knows how to play the game.  If necessary get a consultant to support this effort.  This will pay off huge dividends in the end as they’ll know how to navigate delicate situations, get continuances and or leniencies where able.
 
4.       Employ a Tactical Scorecard
Remediation projects can quickly run off the rails if leadership isn’t hyper focused on tangible execution.  When projects span an entire organization involving dozens of resources and a multitude of external suppliers its easy for things to get lost in the shuffle causing delays and confusion among the troops.  To overcome this challenge utilize a tactical scorecard which everyone in management has access too along with anyone who is in a lead role for the remediation project.  It’s a project charter and Gantt Chart combined into one, just simplified.  This scorecard should breakdown the project into four or five key areas as necessary, but no more than five.  Each of these project areas act as a cost center of sorts for accountability.  Within each area you’ll have the activities coming up in the next 30 days, deliverable dates and the people who own the work.  A process like this creates transparency while providing clear direction.  The key stakeholders should meet at least monthly, if not earlier, to review the status of the project in comparison to the scorecard.  SCRUM style meetings offer a good approach for transparency and accountability.
 
5.       Learn How to Manage Cost Early On
Often companies will use a consulting group to lead or help work through their remediation efforts.  All too often the selection process for that supplier comes down to a key relationship within the company which basically side tracks any formal vetting process of other possible suppliers.  Cost becomes a 2nd or 3rd consideration over a relationship.  This can be disastrous as selecting the wrong supplier to help you with a remediation project can end up costing you thousands, if not hundreds of thousands, of dollars extra down the road.  Case in point – when you use suppliers that fly in consultants you are literally paying more than double the cost for that service just because those resources weren’t local.  Flights, housing, food, per diems, auto, travel, etc. adds up incredibly fast.  I’ll admit, sometimes the best solution is an out-of-town supplier, however be sure to do your homework before you settle on the one supplier that’s going to get your company back on track. 
 
6.       Know the Difference Between Execution & Strategy
As mentioned above, companies use consultants because it’s a good way to get ahead of a remediation project with people who have been there an done it before.  It momentarily expands your bandwidth for as long as you need.  While that sounds lovely there is a downside to the consulting and client relationship – the difference between strategy and execution.  Some consulting companies bill themselves as experts and charge big prices to boot.  What many companies find out the hard way is that these overpriced consulting firms stay up in the stratosphere where strategy is best played and seldom come down to the ground level to get their hands dirty.  This means they can put a plan together but executing on it is another story all together.  If you’re going to use a consulting firm make sure your contract includes deliverables which focus on execution and completion of work. 
 
Key Take Away:
If you’re heading into an FDA remediation project it is paramount to set up a company wide communication protocol which provides direction and project updates in real time.
 
Action Item:
Remember – it’s not ‘if’ but ‘when’ you’ll find yourself in a situation where you’re stuck going through remediation.  Therefore, you must be proactive.  Before you need the help, begin compiling data on suppliers that could help with a possible remediation project.  Compare their capabilities, learn how they would approach a potential project, how do they charge, etc.  Once you’ve done your homework you’ll then have all the necessary information upfront to make a strategic and informed decision when it comes time to dive into remediation.

​Remediation in the medical device industry often adopts a similar saying you’ll hear motorcyclists say when referencing laying their bikes down [accidents], “it’s not if it will happen, it’s when”.
 
With so many companies over the years going through major remediation efforts one would think by now most people in the business would have a good appreciation for what a successful process looks like to navigate through FDA remediation projects.  Yet, many people will tell you the remediation projects they’ve been a part of were messy, unorganized and a galactic waste of money.  Unfortunately, when we’re faced with remediation there is no choice other than to mend our broken wings before flying home for the summer.
 
One of the biggest issues with remediation projects is many people in the company look at it as a ‘quality’ issue.  Meaning, “it’s the quality departments problem, let them deal with it because we have our own projects and deadlines.”  Shocking as this may be, I literally was told this several years ago from an R&D Director whose company was going through a sizable remediation overhaul.  Needless to say he wasn’t operating as a team player and certainly wasn’t aligned with what was best for the company.
 
Which sparks an interesting question – if I have a remediation project ready to get underway, what are the things I can do in order to ensure it succeeds?  Regardless of the project size, these are the four things you must consider as a top priority in your next remediation effort:
 
1.Establish clear, consistent and easy internal communication protocol for the project
This is one of the most overlooked parts of a large scale project.  It’s especially important when considering cross functional company divisions and the people accountable to working towards successful completion.  When people are misinformed or don’t know what’s going on you can be certain it will slow your project down and cause further product quality and procedural issues down the road.
 
2.Get a GREAT ‘lobbyist’ 
You’ll need someone acting as the liaison between your company and the FDA.  Typically, this person comes from your QA/ RA group, but is that the right person?   Don’t assume your de facto executive in QA / RA is the best for the job.  Ensure your company aligns itself with a proven individual who has relationships within the FDA and knows how to play the game.  This will pay off huge dividends in the end as they’ll know how to navigate delicate situations, get continuances and or leniencies where able.
 
3.Ensure your entire company (especially executive management) is onboard
Everyone in the organization, bottom up, needs to understand why this project just went to the top of the work list.  Everyone needs to be bought in and rowing in the same direction, otherwise you’ll experience cumbersome internal issues as mentioned above, which waste time, money and energy. 
 
4.Learn how to manage cost early on
Often companies will use a consulting group to lead or help work through their remediation efforts.  All to often the selection process for that supplier comes down to a key relationship within the company which basically side tracks any formal vetting process of other possible suppliers.  Cost becomes a 2nd or 3rd consideration over a relationship.  This can be disastrous as selecting the wrong supplier to help you with a remediation project can end up costing you thousands, if not hundreds of thousands, of dollars extra down the road.  Case in point – when you use suppliers that fly in consultants to project work you are literally paying more than double the cost for that service just because those resources weren’t local.  Flights, housing, food, per diems, auto travel, etc. adds up incredibly fast.  I’ll admit, sometimes the best solution is an out of town supplier, however be sure to do your homework here before you settle on the one supplier that’s going to get your company back on track. 
 
Key Take Away:
If you’re heading into a FDA remediation project it is paramount to set up a company wide communication protocol which provides detail to everyone
 
Action Item:
Remember – it’s not ‘if’ but ‘when’ you’ll find yourself in a situation where you’re stuck going through FDA remediation.  Therefore, you must be proactive.  Before you need the help, begin compiling data on suppliers that could help with a possible remediation projects.  Compare their capabilities, learn how they would approach a potential project, how do they charge, etc.  Once you’ve done your homework you’ll then have all the necessary information upfront to make a strategic and informed decision when it comes time to dive into remediation.
 
[Note] this article intentionally does not cover the tactical approaches to FDA remediation as there are hundreds of articles and sources providing that information.  This article covers the intangible parts of projects of this nature, the ones that most often go overlooked.