820.75 Process validation.

(a) Where the results of a process cannot be fully verified by subsequent inspection and test, the process shall be validated with a high degree of assurance and approved according to established procedures. The validation activities and results, including the date and signature of the individual(s) approving the validation and where appropriate the major equipment validated, shall be documented.

(b) Each manufacturer shall establish and maintain procedures for monitoring and control of process parameters for validated processes to ensure that the specified requirements continue to be met.

(1) Each manufacturer shall ensure that validated processes are performed by qualified individual(s).

(2) For validated processes, the monitoring and control methods and data, the date performed, and, where appropriate, the individual(s) performing the process or the major equipment used shall be documented.

(c) When changes or process deviations occur, the manufacturer shall review and evaluate the process and perform revalidation where appropriate. These activities shall be documented.

Interpretation:

Whereas verification is a detailed examination of aspects of a design at various stages in the development, design validation is a cumulative summation of all efforts to assure that the design will conform with user needs and intended use(s), given expected variations in components, materials, manufacturing processes, and the use environment.

VALIDATION PLANNING. Planning for validation should begin early in the design process. The performance characteristics that are to be assessed should be identified, and validation methods and acceptance criteria should be established. For complex designs, a schedule of validation activities and organizational or individual responsibilities will facilitate maintaining control over the process. The validation plan should be reviewed for appropriateness, completeness, and to ensure that user needs and intended uses are addressed.

VALIDATION REVIEW. Validation may expose deficiencies in the original assumptions concerning user needs and intended uses. A formal review process should be used to resolve any such deficiencies. As with verification, the perception of a deficiency might be judged insignificant or erroneous, or a corrective action may be required.

VALIDATION METHODS. Many medical devices do not require clinical trials.  However, all devices require clinical evaluation and should be tested in the actual or simulated use environment as a part of validation. This testing should involve devices which are manufactured using the same methods and procedures expected to be used for ongoing production. While testing is always a part of validation, additional validation methods are often used in conjunction with testing, including analysis and inspection methods, compilation of relevant scientific literature, provision of historical evidence that similar designs and/or materials are clinically safe, and full clinical investigations or clinical trials.

Some manufacturers have historically used their best assembly workers or skilled lab technicians to fabricate test articles, but this practice can obscure problems in the manufacturing process. It may be beneficial to ask the best workers to evaluate and critique the manufacturing process by trying it out, but pilot production should simulate as closely as possible the actual manufacturing conditions.

Validation should also address product packaging and labeling. These components of the design may have significant human factors implications, and may affect product performance in unexpected ways. For example, packaging materials have been known to cause electrostatic discharge (ESD) failures in electronic devices. If the unit under test is delivered to the test site in the test engineer’s briefcase, the packaging problem may not become evident until after release to market.

Validation should include simulation of the expected environmental conditions, such as temperature, humidity, shock and vibration, corrosive atmospheres, etc. For some classes of device, the environmental stresses encountered during shipment and installation far exceed those encountered during actual use, and should be addressed during validation.

Particular care should be taken to distinguish among customers, users, and patients to ensure that validation addresses the needs of all relevant parties. For a consumer device, the customer, user, and patient may all be the same person. At the other extreme, the person who buys the device may be different from the person who routinely uses it on patients in a clinical setting. Hospital administrators, biomedical engineers, health insurance underwriters, physicians, nurses, medical technicians, and patients have distinct and sometimes competing needs with respect to a device design.

VALIDATION DOCUMENTATION. Validation is a compilation of the results of all validation activities. For a complex design, the detailed results may be contained in a variety of separate documents and summarized in a validation report. Supporting information should be explicitly referenced in the validation report and either included as an appendix or available in the design history file.

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Reference: www.FDA.gov

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