Category Archives: Stay Current

MEDICAL DEVICE STANDARDS- Can we shed a little light?

Sometimes identifying the standards that apply to your medical device can seem like looking down a dark tunnel.  Is that a light at the end, or a train coming towards you?  It could be both! 

Long ago and far away, clearance of a US device with FDA did not depend upon conformity to a standard.  FDA, believe it or not, didn’t recognize “voluntary” standards and according to regulation, only FDA could issue a “performance” standard. Some years back, the ice broke and certain standards for evaluation of a device became “recognized”.  One of the earliest was for the evaluation for biocompatibility (ISO 10993 Part 1), which took the place of the old “tripartite agreement”; and now we have a deluge of standards to consider for any new medical device. Soon the trickle became a roar and regulatory bodies began to see the wisdom of recognizing certain “peer reviewed” standards.

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WELCOME BACK MEDICAL ALLEY!

Congratulations to Shaye Mandle, President and CEO (formerly known as LifeSciences Alley) and the board of directors for their sound decision to recapture the trade name:  MEDICAL ALLEY.  We were not happy when the name was changed about 10 years ago.  Theoretically the organization was supposed to benefit from a more inclusive name.  The change diluted the bragging rights of local medical device company members, since MEDICAL ALLEY served as the model for similar trade organizations supporting the medical device industry across the country! The name and the innovators associated with that organization are recognized in the Smithsonian, for crying out loud.   Before the name change, MEDICAL ALLEY had been the “go to” group for the FDA and Congress when the voice of the industry was to be heard.  A few of the well remembered events in MEDICAL ALLEY history included a visit by the Dingell Subcommittee to learn how to strengthen the quality system regulations for medical devices, a visit by Dr. Burlington hosted by Senator Wellstone that gave birth to the recognition of standards as part of the device evaluation process and a change in FDA’s control of export of medical devices under development.  And of course, who can forget the visits by one of the most controversial commissioners, Dr. David Kessler.   MEDICAL ALLEY volunteers have developed draft guidance documents for the FDA and participated on many different advisory committees to the agency for policy and practice.  Many, many more services and activities for medical device manufacturers and patients and hospitals are to the credit of MEDICAL ALLEY.  We hope this change represents a renewal of the organization’s commission. Paladin Medical, Inc. received the award for Outstanding Contribution to the Healthcare Industry in1992.

The Basics Of UDI’s: Important Information For Medical Device Companies To Know

PALADIN MEDICAL UDI CONSULTING

PALADIN MEDICAL UDI CONSULTING

As with every industry, the only constants in the healthcare industry are change and change. Rising costs, new regulations and more continually offer a new take on the industry. One of these new changes brought upon by the FDA is unique device identification or UDI.

 

The Basics & The Differences Of Unique Device Identification

The FDA has created UDIs in an attempt to adequately identify medical devices through the lifetime of the device, whether in distribution or use. The unique device identification system will be phased in over the course of many years. Once completed, the program will offer many benefits to the health care system.

Once fully implemented, UDIs will help to improve patient safety, facilitate innovation in the medical device marketplace, provide postmarket surveillance and much more.

As well, UDIs will allow for more accurate reporting, analyzing and reviewing of a number of events. Medical errors will by reduced through ease of access to precise information. The improved analyzing abilities UDIs provide will allow for a clear and concise way to track data.

 

What is GUDID and why will customers benefit from it?

Once a device is uniquely identified, there will be a label on most machines. Each label will be readable by humans and machines alike. Individuals who label each device will also submit information about certain aspects of each device to the FDA’s Global Unique Device Identification Database or GUDID.

This allows customers access to the information they would not have had otherwise, as GUDID is available to the public. Anyone can search and download information from GUDID at any time through AccessGUDID.

 

How do I get a UDI and where can I go to get more information?

All UDIs must be issued through a system that is operated by an FDA-accredited issuing agency. There is a process any applicant would go through when seeking a UDI. There are certain exceptions and alternatives to this fairly new rule, as the UDI system will take around 7 years to fully implement.

To get more information about UDIs and how they may change things, you can visit the UDI homepage on the FDA’s website.

 

What is the effective date for my device and how can I find that out?

As the UDI system is going to take 7 years to fully implement, the compliance dates for the system is fairly complicated. Each year certain classes of devices will require labeling, due to different sections of the legislation.

As the legislation was passed in September 2013, each year on September 24 different devices will be required to be properly labeled. Each device will be classified on a certain scale, usually consisting of the type of device it is. The main devices the FDA is looking at are implantable, life-saving and life-sustaining devices.

To find out more information about the types of devices, you can search the CDRH Product Classification Database here. If that doesn’t help you find the information you’re looking for, you can also find a list of how the FDA classifies these types of devices here.

Say Goodbye To Bias: Women In Engineering Are Here To Stay

Paladin Medical is about giving back

paladin medical Women In Engineering

Paladin Medical prides itself on being an organization with a talented and diverse group of individuals striving to make a difference. This starts at the top – as president of Paladin Medical, Elaine Duncan is focused on making a difference. She strives to do so by utilizing diversity.

Appointed to the sub-committee on diversity at the University of Kentucky College of Engineering Dean’s Advisory Committee, Duncan is attempting to help the college deal with a number of problems involving diversity, mainly enrollment and retention issues for females and minorities.

 

A Bigger Problem

University of Kentucky is certainly not the only school that has had issues with females in engineering, nor is it the only field of study or industry that suffers from a lack of women. Industries such as technology, engineering, science, computing and many more, often showcase a strikingly low number of women.

To put this into perspective, only 12% of the engineering workforce is made up of women. While up from 9% in 1990, this number is staggeringly low. Yet, workforce participation by women in computing and mathematical occupations has fallen dramatically. Since 1990, the percentage of women in these fields has fallen 9% – dropping to an abysmal 26% in 2013.  

 

Bias Is Bad For Business

While many factors could be attributed to these astonishing statistics, stereotypes and biases are holding everyone back. One study found engineering firms only employ the higher performing candidates 69% of the time. Yet, 29% of the time, a lower performing man is selected. Only 2% of the time is a lower performing woman is selected.

This is a problem. The United States will need almost 2 million more engineers and computer scientists in less than 10 years. Women need to be filling these spots more often. Adding women can increase productivity, innovation and creativity. Yet, nothing is being done to address this issue.

 

The Problem Is Solvable

While the issue of women in engineering is barely being addressed, women in other typically male dominated fields are pushing barriers and finding success. One industry taking on stereotypes head on is the technology industry.

 

Here’s how:

Silicon Valley Stereotypes

While Sheryl Sandberg and Marissa Mayer may be stars of the technology world these days, Silicon Valley is still a boys club. Yet, people are starting to come around to changing the way things work in Silicon Valley. One young woman, Najia Bulous – believes she can, “re-engineer the culture of Silicon Valley to be more inclusive of women and people from underrepresented groups.” She faces an uphill battle as she starts work for a tech giant in Silicon Valley this year, but she is pushing barriers.


The Powers At eBay Have Taken Notice

Not only are recent college graduates hoping to change the way things work in technology, even large companies like eBay and famous politicians like Hilary Clinton have begun to notice. eBay recently held their annual Women’s Initiative Network Summit, which featured Hilary Clinton as the keynote speaker. eBay is one of the few technology companies taking a proactive approach to hiring women in tech, and their diversity statistics show this.

Hilary believes they are going in the right direction, but there is more work to be done. She stated, “this isn’t just the right thing to do, it’s the smart thing to do for eBay’s bottom line. Inclusivity in the 21stcentury is a recipe for success. It brings fresh ideas and higher revenues.”

 

It’s Time To Step Up

While the issue of women in tech is beginning to be addressed, the issue of women in engineering has not made much progress in decades. Tech and engineering firms will need to change their biases and stereotypes to retain the talented women engineers who do apply.  In turn, these women can serve as role models for young students who might consider a career in engineering. 

Paladin Medical is trying to help make a difference by mentoring young women engineers, sponsoring a scholarship and raising awareness about the issue.

Transfer a 510(k)?

Medical device manufacturers frequently acquire by merger and acquisition a 510(k) from a previous company.  The FDA draft guidance issued December 22, 2014 provides information on how to notify FDA of such transfers. http://www.fda.gov/ucm/groups/fdagov-public/@fdagov-meddev-gen/documents/document/ucm427385.pdf  This is the FDA’s current thinking on this perplexing issue.

 

The recipient of the 510(k) assumes the responsibility to verify when a 510(k) changes hands that there has been no significant change of the device since the original 510(k) or when the device was most recently cleared by the FDA.  The validity of the 510(k) becomes the responsibility of the purchaser once the sale or acquisition has been made.  Due diligence to determine what changes could have been made which might require an updated 510(k) submission is not the subject of this guidance. 

 

In 2012 the FDA modified regulation 21 CFR part 807 to reflect statutory amendments to the FD & C Act  brought about by the FDAAA of 2007.  These changes launched the Unified Registration and Listing System (known as FURLS) which allowed FDA registration and listing to be tied to the 510(k) number, for those which require a premarket notification.  This innovation now allows the FDA to track the “K#” with the registration and listing, and thereby follow the sequence of historical transfers of a particular 510(k). 

 

FDA has not yet implemented this cross-functional database feature but in the future the 510(k) database is supposed to link to FURLS, thus permitting the most up to date registration information to be linked to the 510(k) number.  Until this is completed, manual analysis is all that can be accomplished by the general public. 

 

If your company has acquired by acquisition or merger, a premarket notification [510(k)], the notification of FDA that the 510(k) is now owned by your company is as simple as updating the Registration and Listing database.  This information must be updated annually, but may be updated at any time.  There is no additional fee required to update the annual registration for such 510(k) holder update information.  If your company has not previously registered or listed, then there is of course the annual registration and listing fee.  Your company would need to have supporting information concerning the 510(k) transfer in the appropriate 510(k) internal file.  Be aware, if a company had already registered and listed the same 510(k) in the same calendar year, the database might temporarily allow the same 510(k) number to be shown with two companies.  FDA will contact the two companies and seek to resolve the conflict.  Therefore it is important if a 510(k) is transferred by sale, the seller should remove the 510(k) number from their listing to avoid confusion.  Only one company may “hold” a 510(k) at any given time.  

 

For additional information about registration and listing you can go to http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/HowtoMarketYourDevice/RegistrationandListing/ucm318796.htmOr, contact for help us by way of our website: www.paladinmedical.com.

 

Paladin Medical will help you establish systems that ensure compliance as well as improve efficiency and productivity.

A Brief History of the Paladin

The modern meaning of the word “Paladin” is a heroic champion and strong supporter or defender of a cause. It is derived from the Latin “palatines,” meaning “of the palace,” and came to mean a warrior or knight. The twelve knights of Charlemagne were called Paladins; their mission to solve disputes between the king's subjects.

In the late 1950s, a television character on the popular Western "Have Gun Will Travel" was named Paladin. He solved problems with intellect, not gunfire. The knight symbol on his business card conveyed his message of stoic service.