Thomas Jull
Medical device operations management - R&D | Manufacturing | Market Service & Support
May 2016
< 1 min reading time
Katie Weimer’s presentation on, “3D Printed Medical Devices: What’s Next?”, at the 10x Medical Device Conference was amazing. Some great examples of how the technology is being used to form ‘patient-specific’ replacement bone sections, and scope for the future with regards to surgeons at the hospital printing these parts in-house via installed machines potentially in or near to the operating theater. Implants aren’t my area so I presume that such ‘patient-specific’ devices made from traditional materials (metallic prosthetics) are considered “custom medical devices” as they are not ‘marketed’ and so are exempt from the usual product FDA regulations (no 510(k) needed). If this is true I also presume that such devices are ‘high risk’ (could be considered class III) but are exempt from ‘general controls, special controls and premarket approval’. Like I said, this isn’t my area but the above is really a precursor to my question: If hospitals did 3D print such devices in-house would they be considered the ‘manufacturer’? Also, as in the product FDA regulations exemption above for such custom devices, would hospitals also be exempt from FDA 21 CFR 820 (no FDA-based QSR or DMR) if they were 3D printing custom bone sections in-house? How would they be regulated? Any thoughts are welcome. source: https://www.linkedin.com/groups/78665/78665-6134012195786285058 Marked as spam
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What a delight to meet you in person, Thomas. Let's get that Carl Lincoln character to join us next year.
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Thomas Jull
Thanks Joe. It was great to meet you and other conference attendees too. Thanks for an awesome event!!! Very recommended for all, including that "Carl Lincoln character".
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Thomas Jull Glad to finally meet face to face!
I remember my first 3D prototype many years ago. It was just a form factor and invaluable. Oh, how times have changed in 3D printing. You asked: "If hospitals did 3D print such devices in-house would they be considered the ‘manufacturer’? " Yes, this practice would definitely put a hospital clearly under the definition of a medical device manufacturer. FDA 21 CFR part 820 will apply. And I suspect this might be very surprising to many hospitals employing this practice. Marked as spam
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http://www.engadget.com/2016/02/25/doctors-implant-3d-printed-vertebrae-in-worlds-first-surgery/. It doesn't sound like it is printed in the hospital. Maybe prior to the procedure. It would have to be sterilized properly anyway, and from this article it looks as if a third party makes it prior to the procedure.
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Thomas Jull
Thanks Jon Speer, likewise. In that case, just imagine the levels of complexity involved with implementing such systems into hospitals. Would this potentially require addendum to the standards?
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Thomas Jull Yes, I can imagine we are going to be busy helping hospitals implement a QMS that meets 21 CFR part 820.
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FDA has issued a draft guidance document for additive manufacturing for 3D printed medical devices -https://lnkd.in/eGdC5qv
This is good news for 3D printing although point of care 3D printed medical devices that are used with or near the patient in a hospital setting may require additional technical considerations and further guidance Marked as spam
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Michael Lehmicke
The FDA recently released some draft guidance on this topic http://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/UCM499809.pdf
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Thomas Jull
Thank you Gitima Talukdar, SCPM, CSM and Michael Lehmicke. That is some useful information.
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Daniel Houlton
The whole process needs to be a complete platform solution. This must be verified and validated from start to finish (production). Each key stage must utilise simulation and optimisation methods. Ensuring it is fit for purpose. The problem that needs to be solved by creating new medical devices must drive this whole process. Some embedded design DNA
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Jon Speer how did you come to the conclusion on the hospital as manufacturer? I'm not sure it's that cut & dried. If the device was 100% "home-grown" at the hospital, then yes. But if another organization presented the solution to the hospital, I'm not sure it's that simple. If that 2nd organization provided all the technical know-how to the hospital, then it (2nd org) may be the mfg while the hospital is merely implementing that solution.
I'd like to understand this more closely as I'm convinced this will be a key aspect of the future for this industry. Marked as spam
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Corey Wilson-Wirth Yes, you are correct it is not cut and dried. There are nuances for sure. And yes, I believe you are correct that hospitals doing 3D printing will be something to keep our eye on for sure.
If the hospital is designing the medical device, wouldn't this mean they have responsibilities for design controls? If the hospital is actually doing the 3D printing of the device to be used, wouldn't this make them the actual manufacturer? Marked as spam
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Robert Christensen
As the one who first brought this technology forward over 20 years ago to produce patient specific medical implants to replace the TMJ, mandible and many other structures. it delights me to see the progress.
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