Tintypographer
Registered
I started working on finding another role.
Hi,Hello:
I'm at a new role. I think they filed for some extensions. What I learned is that there is a scale for involvement of production teams in quality systems and when management doesn't account for that it just doesn't work. I also know those teams have incredible time constraints so I need to do my homework with very specific questions and writing before they come in for input but if I have no input on technical details then we can't really justify things to either the FDA or the notified body.
This was on the very low end of the scale where the R&D and production engineers simply had no time as mandated by executive leadership for input to quality and regulatory. Executive leaders didn't want to jeopardize timelines or "bother the production teams". I've noticed this occurs at companies where the founders and product leaders are not experienced in regulatory. They tend to see that they did their clinical studies, they ran toxicology, they paid for GMP manufacturing and they have sales going on and their investors demand profit, not a bunch of justifications and meetings. I have learned to ask questions about a startup company's understanding of the regulatory requirements, path and effort and to say what I will be able to do and what will need input, thought and writing. I'll promise not to act as a blanket auditor simply dropping open questions and guide the production andnR&D teams through it but I can't solve the problems in a vacuum
There are also the problems my own profession and predecessors have made that take cleanup.
At a company I was with that had an approved producf with CE registration, the company didn't produce for three years because of funding and production supply chain issues and there were no sales in that time. Instead of filing to place a hold on the product, the regulatory person elected to simply open CAPAs about why no work was being done in production to reduce risks or why no post market surveillance was conducted. There was no thinking about the options done by that regulatory person in talking with the FDA or notified body. hE/she simply agreed with the auditor(s) and wrote ancapa saying they would fix the production review process. But clearly no manufacturing was going on or had any likelihood of continuing in the near future so in that case the regulatory person (my predecessor) did a poor job of advising and helping the management.
It's all a balance. Quality and regulatory should not be the sole purpose of a medical device company. We have to produce products that help patients. Those products should be designed and managed with a quality system under a regulatory framework. I can't say to a R&D scientist, "we should have a SOP for opening a drawer" in the face of real deadlines but I should be able to say, "we have to definine risks to a process change and implement a control."
My new company appears to be about a 6 on the scale from 1-10. They have some messes but management is committed to solving them.