Covid-19 has arguably become the biggest
challenge to hit humankind after the Second World War. It has thrown every
activity out of gear and forced people around the world to go indoors and
maintain social distancing. The immediate challenge is to flatten the curve
with more testing followed by quarantining the Covid-19 patients. The challenge
requires quick manufacturing and delivery of testing kits, Personal Protection
Equipment (PPE), respirators, and ventilators, among others. To defeat the
immediate enemy, the novel Coronavirus, the healthcare sector needs a large
infusion of the above-mentioned kits and increase the scale of testing. Since
the world did not have enough reserves for such equipment, there is a sudden
requirement to scale their manufacturing to meet the demand.
This is where there is a danger of companies
flouting standard medical device testing
practices to meet the demand in double-quick time. As there is a need to
deliver a rapid response to the contagion by testing in greater numbers, doing
so without proper tested equipment can be counterproductive. So, professionals
manufacturing such devices or kits need to pause and follow the established
testing protocols in the development and delivery pipeline. During such times,
quality matters more than anything else. Let us understand the dangers of not
conducting performance testing on medical devices. A faulty testing kit,
PPE, or ventilator can wreak havoc if it does not raise an alarm when there is
a positive case or vice-versa. The entire response of the medical fraternity in
combating the pandemic would depend on the knowledge that such pieces of equipment
are functioning and meeting the expected parameters.
Leveraging authorizations and
exemptions
The need of the hour is to build strategies
that leverage exemptions, authorizations, protocols, innovations, and
communication tools to deliver the goods. The medical device manufactures should
be quick to confront the pandemic and respond to the evolving situation. The
entire strategy should be risk-based and take into consideration the need for
obtaining authorizations and exemptions. For example, in the USA, there is a
provision where the federal or central governments can authorize manufacturers
to scale up the production of devices to address the pandemic. Known as the
Emergency Use Authorization or EUA, the provision can empower manufacturers to shore
up production and deliver medical devices quickly to the market. During such
times even the FDA can expedite its premarket review and be a facilitator in
the larger scheme of things. Since the current market demand is mainly for PPE,
ventilators, respirators, and diagnostic test kits, it is better to leverage a
EUA to scale up your manufacturing process.
However, the EUA does not give any
manufacturer a carte blanche to avoid medical device testing. Instead, devices
ought to meet a certain standard requiring less evidence. Notwithstanding the
relaxation in providing evidence, the FDA would conduct a risk-benefit analysis
to ascertain if the device is worth authorizing to reach the market. Further, during
a pandemic like situation such as the one driven by Covid-19, the government
can ask non-medical manufacturers to get into the act and increase the
production of essential medical kits. The standards nonetheless should not be
lost track of by such manufacturers in terms of quality, performance, and
safety. For example, non-medical manufacturers like automotive and industrial
ones may get into manufacturing of medical equipment by complying with certain
regulatory protocols as mentioned below.
·
IEC 60601 for medical electrical
equipment
·
IEC 62304 for the SDLC of medical
devices
·
ISO 10993 to evaluate the
biological parameters of medical devices
·
ISO 80601 for medical equipment
such as respirators and ventilators
What about international
exemptions?
The scourge of Covid-19 has led to a lot of
flux in the international markets as far as medical devices are concerned. Rules
related to medical device testing seemed to have been relaxed to meet the
rising demand. So, should you be a seller or manufacturer of medical devices, the
time is to leverage the exemptions and scale up production or delivery of such devices.
Some of the important exemptions for the medical devices testing specialists to
ponder are as follows:
·
Singapore to do away with the
need for registrations for certain devices, namely, PPE, surgical masks,
thermometers, and particulate respirators.
·
Australia has exempted devices
from registration that are needed for the diagnosis, monitoring, prevention,
and treatment of Covid-19.
·
China to facilitate the registration
for PPE should they meet the standards prevalent in the USA, the EU, or Japan.
Prepare against pandemic related
disruptions
Since the pandemic has led the world to
practice social distancing and quarantining, it might come as a challenge for the
medical device manufacturers. For example, there would be a significant impact
on conducting clinical trials because patients will not be able to travel or
there might be a smaller number of trials than otherwise needed for effective
analysis. Also, test protocols may change with medical device testing experts visiting
homes of patients or using telemedicine. Further, the IRB review and approval
may get delayed due to such restrictions.
Social distancing can play havoc with the testing
teams working remotely. With less or no access to collaboration tools, typical
processes followed earlier might become unresponsive. Let us understand a few
instances as explained below:
·
If the team is more into
documenting things on paper, the travel restrictions can hamper the process of
obtaining physical signatures.
·
In the absence of a centralized
communication network, messages and documents will get delayed to reach the
right recipients. Also, for any slippage, the rework can push things further
and cause delays.
·
Legacy systems can come in the
way of a quick, secure, and reliable healthcare software testing.
In other words, manufacturers and testers will not be able to collaborate
effectively in upholding appropriate security levels.
Conclusion
In the challenging times of Covid-19, the
manufacturers of medical devices should adapt to innovative ways in leveraging the
exemptions and authorizations. The need of the hour is to arrest the spread of
the pandemic by manufacturing Covid-19 related medical devices in humongous
numbers. However, in doing so, the quality and safety aspect should not be
undermined as it is only with quality kits the scourge can be confronted and
hopefully mitigated.
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