Remedies for Supply Chain Headaches: Innovating Critical Process - - PowerPoint PPT Presentation
Remedies for Supply Chain Headaches: Innovating Critical Process - - PowerPoint PPT Presentation
Remedies for Supply Chain Headaches: Innovating Critical Process Manufacturing Oversight March 23, 2016 Agenda Poor Critical Process S upply Chain Management Presents Problems for Medical Device Companies Role of S upply Chain
Agenda
- Poor Critical Process S
upply Chain Management Presents Problems for Medical Device Companies
- Role of S
upply Chain Management in FDA’ s Case for Quality
- How the Aerospace Industry can S
erve as a Model for the Medical Device Industry
- Effective S
trategies for Oversight and Management of Medical Device S upply Chain Based on Aerospace Industry S uccess
- Leveraging S
uccessful Aerospace S trategies for the Medical Device Industry
2
Poor Critical Process Supply Chain Management Presents Problems for Medical Device Companies
3
Critical Manufacturing Process S upply Chain Oversight Issues
Impact Reason
360 units recalled by FDA Affected product did not undergo heat treatment hardening step leading to lack in material strength that may contribute to the deformation of the tip.
4
Tibial Articular Surface Inserter (Class II)
Source: www.accessdata.fda.gov
Critical Manufacturing Process S upply Chain Oversight Issues
Impact Reason
46 units recalled by FDA An increased likelihood of failure of the CPU circuit
- board. This could result in a
blank display or loss of mechanical ventilation.
5
Ventilator (Class II)
Source: www.accessdata.fda.gov
Critical Manufacturing Process S upply Chain Oversight Issues
Impact Reason
193 cases recalled (6 per case) by FDA Disposable single use MFEs processed through Gamma Radiation to a S terility Assurance Level (S AL) of 10-6 per IS O 11137. Product sterility is not assured
6
Sterile Adult Multi-Function Electrodes (Class I)
Source: www.accessdata.fda.gov
What are the Current Critical Process Problem Areas for Medical Device Industry Leaders?
7
OEMs/CMs
Complete elimination of critical process defects which affect our customers is problematic Practical way to have visibility and control of processes at tier 2 and 3 suppliers is difficult to achieve Communicating expectations at all levels of supply chain is difficult
Suppliers
Understanding/
- btaining
customer requirements Timeliness of
- rders – enough
time to obtain requirements and proper processing Communication/ Resolution of issues at lower tier suppliers
Results of Poor S upply Chain Management
- Problems with Patient S
afety
- Poor Product Quality
- Product Recalls resulting in:
- Damaged company reputation and brand
- Added costs
- Loss of growth opportunities
- Loss of productivity
- Increased Production Cost
- Additional inspection and oversight
- S
crap and waste
8
9
General Quality Management S ystem (QMS ) vs. Critical Manufacturing Process Approach to S upply Chain Management
General Quality Focus General Quality Focus
“1 mile deep on the critical process, 1 inch wide on the quality system” “1 inch deep on the critical process, 1 mile wide on the quality system”
Critical Process Focus
Focus on critical manufacturing processes
S
- me Examples of Critical Manufacturing Processes for
Medical Device Companies
- Assembly
- Bat t eries
- Cable & Wire Harness
- Cast ing / Forging
- Chemical Processing
- Cleaning
- Coat ings
- Count erfeit Parts
- Elect ronic Displays
- Fluidics
- Heat Treat ing
- Machining
- Mat erial Test ing Laborat ories
- Measurement / Inspect ion
- NDT
- Opt ics
- Packaging
- PCB
- Plast ics - Ext rusion
- Plast ics - Inj ect ion Molding
- Plast ics – Blow Molding
- Power S
- urces
- Print ed Circuit Board Assemblies
- Raw Mat erials
- Reagents
- S
- ft ware
- S
t erilization
- Welding
What are Key Elements of Good Critical Manufacturing Process S upply Chain Management?
QMS Certification and 3rd Party Accreditation Understanding impact on final product quality Industry standards and best practices Contract Review Validation planning and execution SMEs with critical process knowledge Continuous Improvement
11
Role of Supply Chain Management in FDA’s Case for Quality
12
FDA CDRH 2016-2017 S trategic Priorities
Establish a national Evaluation System for Medical Devices
- Goal: Increase access to real-world evidence to support regulatory
decision making
- Goal: Increase the use of real-world evidence to support regulatory
decision making Partner with Patients
- Goal: Promote a culture of meaningful patient engagement by
facilitating CDRH interaction with patients
- Goal: Increase use and transparency of patient input as evidence in
- ur decision making
Promote a Culture of Quality and Organizational Excellence
- Goal: S
trengthen FDA’ s culture of quality within the Center for Devices and Radiological Health
- Goal: S
trengthen product and manufacturing quality within the medical device ecosystem
13
FDA CDRH 2016-2017 S trategic Priorities
- As part of the Case for Quality, collaborate with members of the medical
device ecosystem to identify, develop, and pilot metrics, successful practices, standards, and evaluation tools that will be specific to the medical device industry and focus on assuring product and manufacturing quality.
- Identify external partnerships and mechanisms to support a sustainable,
voluntary third party program that will utilize quality metrics, practices, standards, and evaluation tools to assess and promote medical device product and manufacturing quality within industry beyond compliance with regulatory requirements.
- Identify FDA policies and practices that will encourage adoption of
metrics, practices, standards and evaluation tools that promote medical device product and manufacturing quality, and recognize efforts to exceed baseline expectations of compliance with regulatory requirements.
14
Goal: S trengthen product and manufacturing quality within the medical device ecosystem
Aligning with Critical to Quality (CtQ)
15 Industry-Managed Accreditation FOCUS: Ensure compliance to critical manufacturing process requirements
Supplier Quality
Critical to Quality FOCUS: Derived from DFMEA/ PFMEA FDA Case for Quality FOCUS: Improve quality with a CtQ focus Support Support Support
What is the Medical Device Industry Doing to Align with FDA’ s Case for Quality Initiative
16
Case for Quality Medical Device Industry-led Initiative
Enhanced focus on quality while maintaining compliance
Supplier preparation and rigorous audit conducted by a technical expert will ensure product quality and compliance Promotion of a root cause approach to quality challenges
In-depth root cause corrective action responses and sustainable implementation required for closure of all non-conformances CAPA training provided to support suppliers Enhanced transparency
Instant web-based access to real time supplier audit data and CAPA Early warning system enables OEM/CM to take prompt preventative action Stakeholder engagement
OEM, CM, and supplier collaboration improves communication and identifies best practices to address quality issues Regulatory focus on preventative quality practices
Integrating audit criteria into day to day operations supports a proactive culture
- f preventative quality and standardized operating practices
Critical to Quality methodology
Ensuring compliance to critical manufacturing process requirements
AdvaMed Case for Quality Best Practices
17
How the Aerospace Industry can Serve as a Model for the Medical Device Industry
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Medical Device & Aerospace Industry S imilarities
- Importance of quality and safety
- Life-critical products/ parts/ components
- Critical manufacturing processes
- Critical Process S
upply Chain
- Complex multi-tiered Global S
upply Chain
- S
trict regulatory oversight
- High cost of product failure
19
Importance of Auditing the Process
20 Boeing 737 400,000 parts Boeing 787 2.3 million parts Boeing 777 3 million parts Boeing 747 6 million parts
Boeing procures 783 million parts in one year Adopting a process based approach to auditing enables oversight of supply chains on an enormous scale:
Source: Boeing - http://787updates.newairplane.com/787- Suppliers/World-Class-Supplier-Quality
Nadcap: Process to Manage the Aerospace Critical Manufacturing Process Supply Chain
Nadcap is an industry managed accreditation program for the Global Aerospace Industry. Nadcap verifies that an audited company has the process capability, necessary equipment, controls, qualified personnel, sub-tier controls
- etc. to follow process requirements as defined by industry standards
and/ or OEM requirements and validates actual compliance.
Compliance – Control – Cost S avings – Risk Reduction
21
25 Years of Aerospace S uccess
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Over 7,500 global accreditations 86%
- f S
uppliers credit Nadcap with improving quality in the aerospace industry.
> 85% of the top global aerospace companies participate in Nadcap 5,500 audits per year 17 critical processes
Nadcap OEM S ubscribing Members
23
Delivering Results
24
Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9
Nadcap OEM Subscriber CtQ Results
Suppliers Internal OEM
Global S upply Chain Focus
25
Nadcap Supplier Audits (2015)
- 5,466 PRI Audits in 2015
- Over 5,500 audits projected in 2016
2883 1639 944
Americas Europe Asia
Effective Strategies for Oversight and Management of Medical Device Supply Chain Based on Aerospace Industry Success
26
Effective S trategies for Oversight and Management of Medical Device S upply Chain Based on Aerospace Industry S uccess
- Identify each critical manufacturing process technology where a
process failure could result in defects affecting patient safety
- Prioritize the key critical manufacturing process technologies
- Address each critical manufacturing process separately in order to
develop process requirements based on industry standards and best practices
- Follow the Nadcap methodology to validate the critical
manufacturing process supply chain capability at all tiers
Process to Manage Medical Device S upply Chain Modeled after Aerospace Industry for each Critical Manufacturing Process
28 Audit Criteria Developed Process Evaluation/ Improvement Corrective Actions Completed Audit Reviewed Auditors Selected
Medical Device Industry leaders manage all key steps
Accreditation Decision Audit Conducted
Process to Manage Medical Device S upply Chain Modeled after Aerospace Industry
29 Audit Criteria Developed Process Evaluation/ Improvement Corrective Actions Completed Audit Reviewed Auditors Selected
Medical Device Industry leaders manage all key steps
Accreditation Decision Audit Conducted
30
Audit Criteria Development
OEMs/CMs Suppliers PRI Staff
Establish Audit Criteria Audit Criteria: Document containing audit questions to determine compliance to established industry standards and OEM requirements.
Process to Manage Medical Device S upply Chain Modeled after Aerospace Industry
31 Audit Criteria Developed Process Evaluation/ Improvement Corrective Actions Completed Audit Reviewed Auditors Selected
Medical Device Industry leaders manage all key steps
Accreditation Decision Audit Conducted
Auditors are S ubj ect Matter Experts
- Audits are conducted by S
ubj ect Matter Experts (S MEs) for each critical process area
- S
ME Auditors are selected and approved by industry technical experts participating in the critical process Task Groups
- Auditors have considerable experience
in each critical process they audit and receive initial and continued training from PRI and industry critical process Task Groups
32
Process to Manage Medical Device S upply Chain Modeled after Aerospace Industry
33 Audit Criteria Developed Process Evaluation/ Improvement Corrective Actions Completed Audit Reviewed Auditors Selected
Medical Device Industry leaders manage all key steps
Accreditation Decision Audit Conducted
34
General Quality Management S ystem (QMS ) vs. Critical Manufacturing Process Approach to S upply Chain Management
General Quality Focus
Critical Process Focus
Critical Process Audits verify the Supplier has process capability, necessary equipment, controls, qualified personnel, sub-tier controls, and the ability to follow the process requirements as defined by the OEM requirements and/or industry specifications, and validates actual compliance.
“1 mile deep on the critical process, 1 inch wide on the quality system” “1 inch deep on the critical process, 1 mile wide on the quality system”
Critical Process Audits consist of:
Verification of General Quality S ystems (QMS ) effectiveness for the critical process area being audited Critical process- focused j ob audits Critical Process specifications (audit criteria) and OEM requirements
Example of MedAccred Audit Criteria
Process to Manage Medical Device S upply Chain Modeled after Aerospace Industry
36 Audit Criteria Developed Process Evaluation/ Improvement Corrective Actions Completed Audit Reviewed Auditors Selected
Medical Device Industry leaders manage all key steps
Accreditation Decision Audit Conducted
Audit Results
eAudit Net
- All audits are electronically recorded in a in-house web based
system called eAuditNet
Audit or
- The Auditor will submit into eAuditNet completed checklist,
required attachments and write-up and grading of non- conformances
eAudit Net
- Upon Audit report submission, all automatic notifications are sent
to designated OEM, S uppliers, PRI S taff and Auditors and time control metrics are automatically initiated and sent to OEMs
37
Process to Manage Medical Device S upply Chain Modeled after Aerospace Industry
38 Audit Criteria Developed Process Evaluation/ Improvement Corrective Actions Completed Audit Reviewed Auditors Selected
Medical Device Industry leaders manage all key steps
Accreditation Decision Audit Conducted
CAPA Process
39
Supplier
- Supplier submits root cause analysis and objective evidence
- f corrective actions for each non-conformance
PRI
- PRI Staff Engineer (SME) reviews the audit report, works with the
Supplier to close and approve corrective actions
Task Group
- Reviews each non-conformance, approves or rejects the Supplier’s response
- All issues must be resolved prior to closure of the audit by Task Group
- Votes to accredit the Supplier if all corrective actions are acceptable
- If the audit fails, Supplier must start the audit process again (initial audit)
PRI
- Issues certificate of accreditation (period of validity dependent on merit status)
- Schedules next audit (reaccreditation audit)
Process to Manage Medical Device S upply Chain Modeled after Aerospace Industry
40 Audit Criteria Developed
Process Evaluation / Improvement
Corrective Actions Completed Audit Reviewed Auditors Selected
Medical Device Industry leaders manage all key steps
Accreditation Decision Audit Conducted
Industry Managed S upply Chain Points of Oversight
41
Process Active Industry Management at all Steps
Audit Criteria Developed
Industry participants create and approve all audit checklists that are used in the program. Auditors Selected
Industry participants set the qualification criteria that is used to select auditors, participate in the interview process and provide on-going annual training Audit Conducted
OEM Subscribers can participate in an Observation Audit. This process allows the OEM Subscriber to attend an audit with the purpose of evaluating auditor performance and adequacy of audit criteria. Feedback is shared with Task Group and Management Council. Audit Reviewed
OEM Subscribers have access to all audits results including any historical audit data. Access is provided the moment the Auditor submits the results of audit into eAuditNet. Corrective Actions Completed
OEM Subscribers evaluate corrective actions that are put in place by Supplier to ensure they are adequate and effective. This oversight is documented by requiring a vote to Approve or Disapprove results of each audit Accreditation Decision
Supplier Accreditation is not granted until approval is provided by OEM Subscribers.
Process Evaluation/ Improvement
Management Council is required to perform an annual audit of entire program to identify areas for improvement.
Leveraging Successful Aerospace Strategies for the Medical Device Industry
42
Learning from the Aerospace industry, the Medical Device industry founded MedAccred
An industry-managed critical process supply chain quality program
Administ ered by t he Perf ormance Review Inst it ut e (PRI), a not -f or-prof it t rade associat ion,
- n behalf of leaders in t he Medical Device Indust ry.
43
Reduces Risk Improves Patient Safety Assures Quality Products
Through MedAccred, the industry is…
44
… streamlining requirements through technical Task Groups,
Multiple Customer Requirements
Medical device industry-agreed approach to Process Validation included in audit criteria.
45
Through MedAccred, the industry is…
… reaching further down the supply chain,
My Direct Suppliers My Supply Chain
Tiers 1 & 2 Tiers 1 & 2 Tier 3 Tier 4 Tier 5
46
Through MedAccred, the industry is…
… conducting fewer but more rigorous critical process audits with experienced technical experts,
Individual Customer Audits
MedAccred Critical Manufacturing Process Task Groups
47
Active
- Cable & Wire Harness
- Heat Treating
- Plastics - Injection
Molding
- Printed Circuit Board
Assemblies
- Sterilization
- Welding
Future (potential development)
- Assembly
- Batteries
- Casting / Forging
- Chemical Processing
- Cleaning
- Coatings
- Counterfeit Parts
- Electronic Displays
- Plastics - Extrusion
- Fluidics
- Machining
- Material Testing
Laboratories
- Measurement / Inspection
- NDT
- Optics
- Packaging
- PCB
- Power Sources
- Raw Materials
- Reagents
- Software
Why are Industry Leaders Utilizing Industry-led Initiatives to Address Critical Process S upply Chain Issues?
48
OEMs/CMs
Will bring consensus industry standards, best practices and OEM processing requirements to all levels of the supply chain Participation will differentiate suppliers who are committed to improvement Visibility of critical manufacturing process capability will reach all levels of supply chain
Suppliers
Improved flowdown of requirements to all tiers in the supply
- chain. Reduced
OEM audit frequency. Audits by S MEs and a rigorous CAP A process will lead to improved process quality Process discipline will lead to reduce scrap, rework, and improved quality
49
Through MedAccred, the industry is…
… encouraging industry-wide involvement.
MedAccred Management Council
Task Groups
Cable & Wire Harness Heat Treating PCBA Plastics Sterilization Welding Supported by quality and technical training
YOU
To get your company involved in MedAccred or for more information please visit: www.medaccred.org
Concluding Thoughts
50 THE CONNECTION TO OUR PATIENTS
Connie Conboy Director, Business Development & Strategy cconboy@p-r-i.org +1 724 772 7153 Joe Pinto Executive Vice President & Chief Operating Officer jpinto@p-r-i.org +1 724 772 7175 Hannah Godfrey
- Sr. Specialist,
Business Development hgodfrey@p-r-i.org +44 207 034 1247 Liu Le Manager, PRI Asia Pacific lle@p-r-i.org +86 10 6461 9807 Americas / International Europe Asia Justin McCabe
- Sr. Specialist,
Business Development jmccabe@p-r-i.org +1 724 772 8693