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A structured document like a Design History File (DHF) is critical to medical device manufacturers. It is used to demonstrate safety and effectiveness and is essential to product development and regulatory submission process.
Today, leaders and decision-makers in the medical device sector are looking for greater collaboration between their engineering teams and quality/regulatory affairs leaders. Therefore, forward-looking medical device companies are looking to implement a cloud-based Product Design Management Solution that truly makes life easier for various stakeholders involved.
Specifically, they are looking to get products out to the market quicker and with greater quality performance. To do this right, they need a cloud-based Product Design Management solution that keeps quality and engineering teams in sync. One key part of the overall product design process is design controls. In this page, we focus on one specific aspect of design controls, which is Design History File (DHF) management.
According to FDA 21 CFR 820.30(j), a Design History File (DHF) is a compilation of records that carries the design history of a finished medical device. This includes all the necessary records to demonstrate that the device design was developed as per the approved design plan and requirements. DHF is also an important component of medical device design review. The design review results, including identification of the design, date of review, and the details of the individuals conducting the design review, are documented in the DHF.
DHF Management is a critical part of the design control lifecycle. Using a next-generation, cloud-based product design management solution, with a world-class Design Controls Solution including DHF management is extremely important.
The FDA 21 CFR 820.30 mandates all Class 2 and 3 medical devices to establish and maintain procedures to control the design of medical devices. To that end, each manufacturer must establish and maintain a Design History File (DHF) for each type of medical device. DHF demonstrates design traceability throughout the entire product development process of the medical device. All medical device manufacturers must maintain DHF as regulated by ISO 13485:2016. All medical device manufacturers must ensure that it is up to date and readily available for regulatory inspection.
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At ComplianceQuest, we spoke to various leaders in the medical device sector across quality, engineering and product teams. One of the biggest challenges with DHF management and overall management of the Design Controls process was the lack of easy collaboration and documentation nightmares. The need of the hour is to implement a solution where engineering and quality, compliance & regulatory teams are in sync. Some of the key challenges faced with respect to design documentation include:
Overwhelming documentation affects efficiency, which can lead to delays, mistakes, and non-compliance. Similarly, teams using paper-based documentation systems or spreadsheets face issues with version control, approvals, and revisions. Design History File (DHF) of a medical device is a unified repository for all design documentation that is easily printable and remains accessible to all members.
Collaboration across departments, including engineering, quality, and regulatory, is cumbersome if critical tasks such as revisions or validations are done through spreadsheets. Manufacturers using a cloud-based design control system can store their DHF online for easy access.
A change in one component of the device can lead to a series of changes, tests, reviews, validations, and verifications. All these changes and updates can be tracked, documented, and approved in a single Design History File (DHF), according to regulatory standards.
When the number of stakeholders involved in a design process is high, there are various risks involved, from human errors to complex workflows. Using spreadsheets to identify and mitigate all risks increases the inherent risks in product development. DHF of a medical device acts as a single reference material to avoid mistakes in the manufacturing process.
Overwhelming documentation affects efficiency, which can lead to delays, mistakes, and non-compliances. Similarly, teams using paper-based documentation systems or spreadsheets face issues with version control, approvals, and revisions. DHF of a medical device is a unified repository for all design documentation that is easily printable and remains accessible to all members.
A change in one component of the device can lead to a series of changes, tests, reviews, validations, and verifications. All these changes and updates can be tracked, documented, and approved in a single Design History File, according to regulatory standards.
ComplianceQuest’s Design Controls solution gives medical device manufacturers complete visibility over the product design process. With the cloud-based solution, teams can easily collaborate and design high-quality products while remaining compliant with FDA and ISO regulations.
Design engineers can gain complete real-time visibility over the product design development process and simplify documentation for your teams so they can focus on innovation. The cloud-based solution allows the DHF of a medical device to be accessed from anywhere, anytime.
Quality leaders can use the solution to ensure that all quality processes and procedures are easily implemented throughout development efforts, along with comprehensive and up-to-date documentation. Quality teams can also get approvals and complete documentation instantly.
The Regulatory Assurance Team can readily prepare for DHF audits as there is no risk of non-compliance. Management can also easily keep track of all regulatory standards and audits.
The IT team does not have to spend time connecting various ERP and QMS Systems as CQ’s Design Controls Solution effortlessly integrates. This helps reduce IT costs and improve product quality with a comprehensive and systematic approach to product development.
As per the FDA 21 CFR Part 820.30, subsection (j), DHF must contain
According to ISO 13485:2016, the medical device manufacturer must include the following details in the DHF:
Simply put, a Design History File (DHF) contains all the steps and processes performed during the design phase of a medical device. DHF acts as a guideline for manufacturing a medical device.
We’ve been working with ComplianceQuest for about one and a half years (and going). The software itself is very well designed and will help any organization to satisfy QMS requirements. It fits hand in hand with SFDC platform and leverages all that cloud can offer. The software is very intuitive and users can be trained fairly easily. The CQ team is very knowledgeable — provided customization services tailoring to our needs.Would recommend 100%.
Andi Xie,Quality Engineer
FDA 21 CFR 820.30 is applicable to Class I, II, and III device manufacturers. As per the regulation, manufacturers must establish and maintain procedures to control the design of the devices so as to ensure that specified design requirements are met. There are various phases of design control, each having its own set of requirements and regulations that must be met to remain FDA compliant.
Design and development planning describes the design and development process based on interaction with various groups. The plan also defines the responsibility for implementation.
Design input focuses on the device requirements and ensures that the manufacturing process addresses the intended use of the device, including the needs of the patient.
Design output emphasizes the proper functioning of the device and if it conforms to the design input requirements.
Design review is conducted at every design development stage to ensure the design results are as per plan.
Design verification and validation establish and maintain procedures for verifying the device design. It is performed under defined operating conditions on initial production units or batches.
Design transfer is done to avoid any miscommunication in translation in device design. This step checks if all the design specifications are mentioned in the production specifications.
Design changes include procedures that are used to identify, document, validate, verify, review, and approve changes in design before actual implementation.
A design history file (DHF) is a record that holds all the information for compliance and to ensure the design was developed based on the approved design plan.
A Comprehensive Design History Files Checklist
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Essential Design and Development Review and Approval Criteria
Understanding Design Controls “Input & Outputs” Requirements
Design History File (DHF): According to FDA 21 CFR Part 820.30, DHF is the record that holds all the details necessary to demonstrate that the design was developed in accordance with the approved design plan. DHF contains all the details from the design and development process, inputs, outputs, verification and validation, reviews, transfers, and changes.
Device Master Record (DMR): FDA 21 CFR Part 820.40 focuses on the Device Master Record. A DMR must be created for each type of device, including device specifications, production process specifications, quality assurance procedures, packaging and labeling specifications, and installation and maintenance methods.
Device History Record (DHR): Device History Record (DHR) includes the dates of manufacture, quantity manufactured, quality released for distribution, acceptance records, primary identification label, and UDI or IPC.
The Design History File (DHF) is one of the first documents an FDA inspector will ask for during an FDA audit. To that end, it is the duty of the internal team to keep the file always up to date. A DHF audit is an internal audit performed to ensure that all elements of the design process are complete and present within the file. A DHF audit can be performed using CQ’s Product Design Management Solution. Using the solution, an auditor can focus on verifying two areas of a Design History File (DHF)
Product Assessment to ensure all product-related risks, with risk assessment and classification, are documented.
Product Risk Control to understand if the various risk control measures, verifications, and residual risk analysis are correctly captured.
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