Page 64 - Safety Risk Management for Medical Devices
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Biocompatibility and Risk Management  43


                      Much information can be derived from published literature, existing in-house
                   data, or suppliers of materials. Where such information is unavailable, chemical or
                   physical characterization, or biological testing may be required to gather the required
                   data.
                      Data requirements are less stringent for lower risk applications, e.g., temporary
                   intact skin contact, than for higher risk applications, e.g., brain implants.
                      Once the risk has been estimated, it is evaluated against the risk acceptance
                   criteria, which are defined in the risk management plan. For reduction of risks,
                   certain measures can be taken to bring the risks down as far as possible. For example,
                   replacement of a material that has toxicological risks, with a material that doesn’t have
                   toxicological risks is a design that is inherently safe. Other potential Risk Control
                   measure:

                      •  Reducing exposure time
                      •  Reducing exposure surface area
                      •  Use of coatings/materials that reduce adverse biological response
                      •  Changes to manufacturing processes to reduce/eliminate toxic additives, or
                         manufacturing aids
                      •  Better cleaning/rinsing processes to remove toxic residues

                      Keep in mind that some Risk Control measures may introduce new Hazards, or
                   increased risks elsewhere in the design. In such cases, some retesting may become
                   necessary.
                      Biological evaluation of medical device materials relies on risk assessment to
                   provide justification for not conducting certain testing. This is valuable from a project
                   cost and schedule perspective, and more importantly from the ethical perspective in
                   that some animal testing may be avoided.
                      An important factor to consider is that even if a given material is shown to be
                   sufficiently safe by itself, it cannot be deduced that the same material when used in
                   combination with other materials will still be safe. Therefore the total device in its
                   final form, produced using the final processes is typically subject to biological testing.
                      As described in Chapter 24, Production and Postproduction Monitoring, data
                   from production and postproduction must be monitored for any occurrences of
                   adverse effects, including due to biocompatibility. Such learnings must be used to
                   update the risk management file as necessary.
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