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Pen Design Plan
This article demonstrates a plan to design the pen described in another article on Design Controls, and may not make sense if you haven’t read “Design a pen.”
In that article I began with a quote from Leonardo DeCaprio from the movie Wolf of Wall Street where he challenged his team to “sell me this pen,” implying a good salesman could sell anything. I believe a good team could design anything so I demonstrated how to use Design Control requirements to create innovative, safe products especially in healthcare. There’s a balance between too many restrictions and not enough freedoms that comes from practice; that article gave advice, this one demonstrates a project-plan and may not make sense without having read the first.
I use this plan as a starting point for more complex products in hands-on workshops and it may not be as useful to a reader without that context.
This article is an initial draft a design plan to demonstrate concepts explained in the article Design me a pen. From this point on it will be referred to as a plan but it’s a discussion point rather than a complete project plan. A useful plan would have enough detail and references so that anyone not familiar with your processes could complete the plan without asking questions or needing more information; they would know why they are working, what they need to do, and how to do it including with whom to communicate.
This plan documents design inputs, the minimum required design reviews, and preliminary examples of tests that will be required for verification and validation. It shall be continuously updated using design change procedures in accordance with company quality control policies.
This plan is only for design controls, from design inputs to design transfer. It does not cover other aspects of development such as process controls, post-market surveillance, risk, or master validation planning.
FDA 21 CFR 820.30ISO 13485
My article on Design a pen
PenUserNeeds.doc (fictional document)PenRegulatoryRequirements.doc (fictional document)ISO-standard-Example-1 (fictional ISO standard)ASTM-standard-Example-1 (fictional ASTM standard)
See our corporate Design Control policy for definitions of the following terms used throughout this plan:
Design & Development Planning 21CFR820.30 (b)Design Input 21CFR820.30 (c)Design Output 21CFR820.30 (d)Design Review 21CFR820.30 (e)Design Verification 21CFR820.30 (f)Design Validation 21CFR820.30 (g)Design Transfer 21CFR820.30 (h)Design Changes 21CFR820.30 (i)Design History File 21CFR820.30 (j)
Deliverables & Design History File
The following documents must be completed prior to design transfer. Any changes to this plan shall be documented with the rational for changes and relevant test data as the Design History File. All changes or updates to this plan will be considered project reviews, but sub-teams may have additional reviews when creating design outputs or tests.
Design Planning, Design Reviews, & Design History File
ThisPlan-Completed.doc (the final report, ensuring all deliverables)
Design Verification, Validation, & Transfer
Pen system-level drawing.dwg
Pen mechanical drawings.dwg1, .dwg2, .dwg3
Ink chemical specifications.spc
Design inputs are comprised of user needs, risk management, regulatory requirements, and business needs. Design inputs must be verified or validated prior to design transfer using documented protocols with pre-determined acceptance criteria, must be completed before transfer to manufacturing, and must be updated every three months throughout this project including the six months after design transfer and use in the field. Risk Management must be updated on the same schedule and include members of manufacturing and post-market surveillance in the updates.
Company risk management policies shall take priority over other design inputs or requirements.
For simplicity, this plan is consolidates all input documents into this page in an abbreviated format.
User Needs (design document available to all departments):
#UN1 visible on a range of patients’ skin colors#UN2 sterile pen#UN3 sterile and non-toxic ink#UN4 easy to hold and use
Risk Management (shared document used by design, manufacturing, purchasing, distribution, and field service departments):
#RM1 must not risk an unsterile product reaching a patient#RM2 must risk patient safety by slipping in a user’s hand during surgery
Regulatory Requirements (design document available to all departments):
#RN1 Must use ink or marking material that’s approved by regulatory agencies in the United States and European Union
Business Requirements (design document available to all departments):
#BN1 Must be color-coded to match corporate brand: “blanched almond,” hex code “ffebcd.”
#BN2 Must fit into existing packaging of other products (maximum of 6.0 inches long, 0.5″X0.5″ wide and deep
#BN3 Must cost less than $1 for final products made in orders of >1,000 per month
Design requirements are for the benefit of design teams and must be linked to Design Inputs. Suggestions for how to verify or validate are non-binding, not exhaustive, and must be described in detail in other documents. For simplicity, this plan is consolidates all requirements documents into this page in an abbreviated format.
#SR1 ink must not leak when pen shaken by a typical user*#SR2 ink and pen able to be sterilized using gamma radiation#SR3 able to be used 10 times without failing**
#MR1 must not slip out of hands in a typical hospital surgery room environment*
#MR2 greater than 4.0 inches and less than 6.0 inches long
#MR3 Must be less than 0.5″ wide or deep, and greater than 0.25″ wide or deep
#MR4 weigh between 2 and 4 ounces**
#MR5 the color of the outside must be “blanched almond,” hex color code “ffebcd”
Ink requirements, version 2:
#IR1 color = silver, hex code “??????”#IR2 color able to be seen on typical patients’ skin, including diverse races, in typical operating room lighting
#PR1 must hold 6 pens
#PR2 must withstand drops of five feet onto a hard floor at least ten times without loosing functionality
#LR1 must adhere to EU MDR requirements
Verification & Validation
#SR1 and #SR3 shall be verified using the test protocol VerTestProtocol-1.doc and documented in VerTestProtocol-1-Results.doc#SR2 shall be verified using methods described in ISO-standard-Example-1.
#MR1 shall be validated using the test protocol ValTestProtocol-1.doc and documented in ValTestProtocol-1-Results.doc
#MR2 , #MR3, #MR4, & #MR5 shall be verified using Design Output documents on size, shape, and material selection; and by manufacturing inspection protocols Man-Protocol-ex1.doc.
#IR1 shall be verified using Design Output documents on size, shape, and material selection; and by manufacturing inspection protocols Man-Protocol-ex1.doc.
#IR2 shall be validated using the test protocol ValTestProtocol-1.doc and documented in ValTestProtocol-1-Results.doc
#PR1 shall be verified using Design Output documents on size, shape, and material selection
#PR2 shall be verified using Package-Protocol-ex1.doc.
#LR1 shall be verified using Design Output documents on size, shape, and material selection; and by manufacturing inspection protocols Man-Protocol-ex1.doc.
Transfer to Manufacturing
Design outputs must be shown to satisfy all inputs through verification or validation, which shall be demonstrated through Trace Matrix.doc and coordinated with manufacturing goals according to the MasterValidationPlan.doc.
The trace matrix shall list all inputs in the Design Input and show by objective evidence that each need was satisfied by Outputs. The links that must be shown between outputs and inputs include Design Requirements, specifications, verification and validation results.
This plan and the Risk Management document shall be updated after design transfer and throughout the first six months of product sales.
That’s All, Folks!