Design and Development Planning

The US regulations for design controls have requirements for design and development planning.  In fact, a design and development plan is an indication that a manufacturer has “exited” research phase activities and entered the development phase, and thus, design controls should be in place.  The regulation, 21 CFR 820.30(b), specifically states:

Design and development planning. Each manufacturer shall establish and maintain plans that describe or reference the design and development activities and define responsibility for implementation. The plans shall identify and describe the interfaces with different groups or activities that provide, or result in, input to the design and development process. The plans shall be reviewed, updated, and approved as design and development evolves.
ISO 13485 §7.1 also outlines planning activities for product realization.  From the standard, it states:
The organization shall plan and develop the processes needed for product realization. Planning of product realization shall be consistent with the requirements of the other processes of the quality management system.
The organization shall document one or more processes for risk management in product realization. Records of risk management activities shall be maintained (see ISO 13485 §4.2.5).
In planning product realization, the organization shall determine the following, as appropriate:
  1. quality objectives and requirements for the product;
  2. the need to establish processes and documents (see ISO 13485 §4.2.4) and to provide resources specific to the product, including infrastructure and work environment;
  3. required verification, validation, monitoring, measurement, inspection and test, handling, storage, distribution and traceability activities specific to the product together with the criteria for product acceptance;
  4. records needed to provide evidence that the realization processes and resulting product meet requirements (see ISO 13485 §4.2.5).
The output of this planning shall be documented in a form suitable for the organization’s method of operations.

What should be included in the design and development plan?

Using the US regulation, SoftwareCPR points out the three key aspects to include in a design and development plan:
  • Write it down.  Create a plan that allows agreement on all the quality processes that will be employed during the entire lifecycle of the product.  Write down what you do know in the plan, and identify the areas with unknowns that will be researched and updated as part of the lifecycle of the product.  Use the 80/20 rule – don’t get hung up on the 20% you don’t know – release the plan.  Then update the plan as more is learned.
  • Interfaces between groups – except for the smallest manufacturers, generally many different groups will work together to design, develop, verify, validate, manufacture, service, and monitoring a medical device.  The design and development plan is the place to describe how the groups responsible for all those disparate functions will interface/interact/communicate, and at what points in the lifecycle will these interactions will occur.
  • Identify the activities that will occur at each lifecycle phase and what deliverables will be produced.

A common design and development plan outline from various industries follows:

  1. Introduction
    1. Project Overview
    2. Project Deliverables
    3. Evolution of the SPMP
    4. Reference Materials
    5. Definitions and Acronyms
  2. Project Organization
    1. Process Model
    2. Organizational Structure
    3. Organizational Boundaries and Interfaces
    4. Project Responsibilities
  3. Managerial Process
    1. Management Objectives and Priorities
    2. Assumptions, Dependencies, and Constraints
    3. Risk Management
    4. Monitoring and Controlling Mechanisms
    5. Staffing Plan
  4. Technical Process
    1. Methods, Tools, and Techniques
    2. Software Documentation
    3. Project Support Functions
  5. Work Packages, Schedule, and Budget
    1. Work Packages
    2. Dependencies
    3. Resource Requirements
    4. Budget and Resource Allocation
    5. Schedule

 

About the author

Partner and General Manager, Brian Pate is ISO 1385:2016 Lead Auditor certified for Medical Device Quality Management Systems (MD), and ISO 19011:2018 Management Systems Auditing (AU) and Leading Management Systems Audit Teams (TL). Brian started his medical device career in anesthesia clinical research in 1985 and has since worked both academia and industry including many years with Johnson & Johnson, Baxter Healthcare, and GE Medical. Brian’s roles have included software engineering, systems engineering, quality assurance, and regulatory affairs. Brian has served on multiple AAMI TIR working groups, including TIR32-2008 (Application of ISO 14971 Risk Management to Software; now IEC 80002-1) and TIR45-2012 (Guidance on the use of Agile practices in the development of medical device software) and served as a reviewer for the 2nd edition of TIR45. Brian serves on the AAMI Software Committee and as an AAMI instructor for the software, design controls, and agile methods courses. Brian also is a member of the Underwriters’ Laboratories (UL) Standards Technical Panel for UL1998 (Software in Programmable Components) and or UL5500 (Remote Software Updates).

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