13485cert

How do you control design changes?

In Change Control, Class IIb, Class III, Design & Development, ISO, ISO 13485, ISO 14971, Medical Device, PMA, Quality, Quality Management Systems, Risk Management on May 4, 2012 at 4:59 am

Of JB’s recommended artists, the Josh Abbott Band was probably my favorite. I especially liked this one. I hope every man is lucky enough to know a girl like Texas. I’m lucky enough to have married a girl that grew up in Texas. They are something special.

We have been discussing the best ways to control design changes at work, and I thought it might present an opportunity to have more of an interactive discussion with my readers.

During my rounds as a 3rd party auditor, I have seen quite a few design control procedures. The most complex consisted of 19 procedures (NOT recommended, but there were no nonconformities). The most simple consisted of one 4-page procedure, which I wrote, but I would never recommend being this brief. I have created a couple of polls in my LinkedIn profile for you to respond to if you would like to share your own company’s “design control stats”:

http://linkd.in/IJtoBL

The problem I see is that most projects are not new product designs. Sometimes the projects are not even major design changes. I think most changes involve supplier changes, component specification improvements, and design for manufacturability. These changes require review and approval of changes. These changes must also be recorded and retained as a Quality Record.

My own personal preference is to always open a design project—no matter how small the change is. In order to make the process flexible, I also prefer to define how many design reviews each project will have in the design plan rather than mandating that design reviews be held in a stage-gate fashion for 100% of projects.

Most companies will have a table of requirements with columns added to indicate if the requirements are mandatory for the project or optional. For example, “risk management plan needs to be updated? Yes/No.” I like this approach, because the table of requirements makes the decision making systematic.

Sometimes a change is only to a work instruction for a step in the manufacturing process. In these cases, some companies will use a document change order process to supplement the engineering change order process.

My feeling is that more complex products (i.e. – Class IIb & Class III in EU and Class III/PMA in US) will require more stringent design controls for the change. What does your company do to control design changes?

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  1. All of our “new” products have all been slight variations on an existing product, and all have been done with just an ECO and document change (Class I Exempt). This is an area where we could improve.

    You picked a great song!

  2. ;Thank you for the feedback. For Class 1 devices and Class 2 devices with special controls, it is certainly easier to identify the risks and V&V testing that might require repeating. When products get more novel, it is much more difficult to identify what is needed. I’m glad you liked the song.

  3. Thank you to everyone following my blog! You set a record on Friday, May 4 with 60 people in one day. I guess design controls is a little more interesting than supplier auditing and risk management. I’m open to other suggestions if you have them. Please keep reading, and I’ll keep writing. The other possibility is that everyone is a huge fan of the Josh Abbott Band.

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