The Food and Drug Administration’s Role in the Safe Use of Medical Devices: Why Otolaryngologists’ Input Is Imperative
Anjum Khan, MD, MPH Medical Officer, Division of Ophthalmic and Ear, Nose, and Throat Devices Office of Device Evaluation, CDRH, FDA Adjunct Clinical Associate Professor of Surgery, Uniformed Services University, Bethesda, MD Marilyn Neder Flack, MA Executive Director, AAMI Foundation at AAMI, Silver Spring, MD Rahul Shah, MD, Associate Professor of Otolaryngology and Pediatrics, Children’s National Medical Center and George Washington University, Washington, DC; Member, ENT Device Advisory Panel, FDA From the AAO-HNS Medical Devices and Drugs Committee Committee Chair and Series Editor: Anand K. Devaiah, MD Associate Professor, Departments of Otolaryngology, Neurological Surgery, and Ophthalmology Boston University School of Medicine and Boston Medical Center Introduction As scientific and technological advances enhance the pace of medical device1 innovation, there is increasing reliance on medical devices for patient care. Otolaryngologists, who may work in settings such as outpatient, emergency, surgical, and/or nursing home care, use a wide variety of devices for diagnosis, mitigation, and treatment of medical conditions for their patients. The inaugural article in this series for the Bulletin introduced the basic concepts of how the Food and Drug Administration (FDA) functions in regulating devices and drugs. Having a more in-depth understanding of the FDA, and how it works to ensure the safety and effectiveness of medical devices used by otolaryngologists in the above care settings is important. It enables otolaryngologists to know how they may play an active role in protecting the safety of their own patients, and in contributing to the nation’s public health related to medical devices. As discussed in two-part article, one critical role otolaryngologists can play in assisting FDA in its mission to protect and promote the public health is that of an “active reporter”of problems they encounter with actual clinical use of medical devices. The FDA’s Center for Devices and Radiological Health (CDRH) is responsible for reviewing pre-market applications for medical devices to ensure that the devices meet the regulatory requirement of a reasonable assurance of safety and effectiveness. CDRH utilizes both pre-market programs to review device information prior to permitting manufacturers to legally market medical devices, and post-market programs to perform surveillance of device performance once it is in widespread clinical use. It also has research, compliance, and educational components that round out the Center’s efforts to protect and promote the public health with respect to medical devices. The focus of this two-part article is on the pre-market and post-market work conducted by CDRH, and how otolaryngologists can contribute to ensuring and optimizing medical device safety for their patients. (Part 2) Post-market Surveillance No device is risk free, regardless of the level of pre-market review prior to marketing the device in the broad clinical community. Rare, yet potentially serious safety problems, a significant rise in anticipated risks, design problems, quality issues, and manufacturing problems may occur once any device is in widespread use. These post-market issues may occur regardless of regulatory class and whether or not the device underwent pre-market clinical testing. This may be explained, at least in part, because conditions of use during the clinical trial phase for Class III devices (and for the Class II devices for which clinical data were also necessary) may differ from routine clinical use following FDA clearance or approval. For example, in a clinical study, the device is often used by highly trained and experienced physicians, in a limited number of study sites, and in a relatively small population that is well defined. However, once these devices are legally marketed in the U.S., the device is available for use by physicians with a wider range of training and experience. Hence, it may be used in a wider patient population, and the post-market clinical performance of the device may differ from that observed in clinical trial(s) with the device. Timely reporting by device users of problems associated with medical devices in clinical use in the post-market setting is therefore critical for both manufacturers and CDRH to protect the public health (i.e., monitor device performance to identify and promptly address actual and potential safety issues). Once the devices are on the market, CDRH learns of problems from several sources. This is often through adverse event reports received from physicians, nurses, and consumers who experience problems. However, the reports from physicians and other users of various devices often lack sufficient detail or pertinent clinical information. This makes interpretation of the event and its significance more difficult. Otolaryngologists can play a key role in protecting the health and safety of their own patients, as well as the patients they will never see, by collaborating with CDRH through reporting device problems. This should be to both the medical device manufacturers and the CDRH. For example, it is important to report device problems that resulted in harm to the user and/or the patient, or could have caused harm if intervention did not occur. Providing as much detail as possible regarding the procedure in which the device was used, any device identifiers, and the nature of the device problem from the clinician’s perspective is vitally important. Such information permits CDRH to better evaluate the issue and take appropriate action if necessary. Otolaryngologists are highly encouraged to use the FDA’s MedWatch voluntary program to report any device problems they encounter that have or could affect their patients’safety. Reports may be submitted in several ways. To access the on-line and paper forms (FDA Form 3500), please visit https://www.accessdata.fda.gov/scripts/medwatch/medwatch-online.htm6. You may choose to include your name or submit the information anonymously. However, it is helpful when contact information is provided. FDA analysts may need to contact you to discuss the report. Your identity is never released to the public, even if you include your name in the report. Alternatively, you may access the recently launched mobile application, Medwatcher, to report using your phone or tablet. This is a new and convenient way to report problems with devices and other FDA regulated medical products. This method is easy and permits you to upload pictures of the device problem you are reporting. You may access this new application at http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/FormsandInstructions/ucm348271.htm7. When CDRH receives a report, the post-market analyst may review the issue in a variety of ways, depending on the reported problem: Researching previously reported events to identify patterns associated with the product; Contacting the device manufacturer for its evaluation of the problem; Talking with clinical users of the product to gain their perspective; and Reviewing the literature concerning the product and specific reported issue The analyst may consider many factors that could have caused or contributed to the event. These could include failures resulting from design, quality, manufacturing problems, human factor issues, and adverse device interactions (e.g., electromagnetic interference from one device to another). Based on the findings, the analyst may determine that the issue should be monitored over time, or may decide that action is needed. Actions can be in conjunction with other offices within CDRH, and can include interactions with the manufacturer. They work with manufacturers in different ways: addressing labeling concerns, performing facility inspections, sending warning letters, issuing device recalls, creating requirements for post-market studies, sending “Safety Alerts”to healthcare professionals and consumers, authoring peer and non-peer reviewed articles, updating relevant websites, producing informative webcasts, conducting public workshops, and forming partnerships with device user organizations.8 Examples of some regulatory actions for otolaryngologic devices can be viewed on CDRH’s searchable database of all device recalls by entering the relevant information, such as device or manufacturer’s name. 9 An example of targeted communications to consumers and healthcare professionals, to inform them how to use devices safely, is the recent communication to consumers about the use of neti pots for rinsing nasal passages. 10 This communication resulted from several post-market reports of improper use of neti pots that may have caused or contributed to two deaths from a rare brain infection in 2011. The Louisiana State Health Department linked the infections to tap water contaminated with an amoeba called Naegleria fowleri that may have been introduced into the nose via neti pots. In summary, otolaryngology is a complex, multifaceted surgical specialty that touches every part of the patient care experience including outpatient, emergency care, surgery, and nursing homes. Furthermore, our specialty has a history, present, and future of innovation that is necessary to provide cutting-edge care to patients. As such, we are especially vulnerable to issues with medical devices and products. This primer, written in conjunction between otolaryngologists and the FDA will hopefully draw attention to the significant role both groups have in medical device safety and surveillance. Physicians are encouraged to report events not only to the manufacturer, but also to CDRH. Many types of device problems occur intermittently. For this reason, large macro-level databases that are needed to rapidly identify trends in issues with a particular device. The onus lies with us to immediately and consistently report issues with devices we encounter. This allows the FDA to aggregate individual issues into meaningful, actionable data. References Medwatch Program https://www.accessdata.fda.gov/scripts/medwatch/medwatch-online.htm(Last accessed on 11-25-13). Med watcher Mobile Application http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/FormsandInstructions/ucm348271.htm (Last accessed on 11-25-13). Post-market Analyst Actions Flack, Marilyn; Gross, Thomas P.; and Samuels-Reid, Joy, et. al., “FDA Working to Ensure the Safety of Medical Devices used in the Pediatric Population,”pg. 1358, from, Pediatric Clinics of North America, December 2012, Editors Jacobs, Brian and Coppes, Max. Recalls http://www.fda.gov/MedicalDevices/Safety/ListofRecalls/ucm295488.htm. (Last accessed on 11-25-13). Consumer Updates http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm316375.htm (Last accessed on 11-25-13). This is another in a series of articles being produced by the Medical Devices and Drugs Committee, written by committee members, consultants, and invited guests for the AAO-HNS membership. Do you have a question or topic we can address, which may fall under the committee’s charge? Do you have a comment about an article? Please let us know! Send an email to our coordinator, Harrison Peery at hpeery@entnet.org and the chair, Anand Devaiah, MD, at anand.devaiah@bmc.org, with the subject line “MDDC question/article”so we can properly identify and answer your query. We strive to quickly answer our “fan mail.”Thanks in advance for your note, and helping to make sure we catch your email floating within the “Spamiverse.”Please note that we will ask your permission to publish your note, in anonymous or edited form, if it becomes the inspiration for a Bulletin article.
Anjum Khan, MD, MPH
Medical Officer, Division of Ophthalmic and Ear, Nose, and Throat Devices
Office of Device Evaluation, CDRH, FDA
Adjunct Clinical Associate Professor of Surgery, Uniformed Services University, Bethesda, MD
Marilyn Neder Flack, MA
Executive Director, AAMI Foundation at AAMI, Silver Spring, MD
Rahul Shah, MD, Associate Professor of Otolaryngology and Pediatrics, Children’s National Medical Center and George Washington University, Washington, DC; Member, ENT Device Advisory Panel, FDA
From the AAO-HNS Medical Devices and Drugs Committee
Committee Chair and Series Editor: Anand K. Devaiah, MD
Associate Professor, Departments of Otolaryngology, Neurological Surgery, and Ophthalmology
Boston University School of Medicine and Boston Medical Center
Introduction
As scientific and technological advances enhance the pace of medical device1 innovation, there is increasing reliance on medical devices for patient care. Otolaryngologists, who may work in settings such as outpatient, emergency, surgical, and/or nursing home care, use a wide variety of devices for diagnosis, mitigation, and treatment of medical conditions for their patients.
The inaugural article in this series for the Bulletin introduced the basic concepts of how the Food and Drug Administration (FDA) functions in regulating devices and drugs. Having a more in-depth understanding of the FDA, and how it works to ensure the safety and effectiveness of medical devices used by otolaryngologists in the above care settings is important. It enables otolaryngologists to know how they may play an active role in protecting the safety of their own patients, and in contributing to the nation’s public health related to medical devices. As discussed in two-part article, one critical role otolaryngologists can play in assisting FDA in its mission to protect and promote the public health is that of an “active reporter”of problems they encounter with actual clinical use of medical devices.
The FDA’s Center for Devices and Radiological Health (CDRH) is responsible for reviewing pre-market applications for medical devices to ensure that the devices meet the regulatory requirement of a reasonable assurance of safety and effectiveness. CDRH utilizes both pre-market programs to review device information prior to permitting manufacturers to legally market medical devices, and post-market programs to perform surveillance of device performance once it is in widespread clinical use. It also has research, compliance, and educational components that round out the Center’s efforts to protect and promote the public health with respect to medical devices. The focus of this two-part article is on the pre-market and post-market work conducted by CDRH, and how otolaryngologists can contribute to ensuring and optimizing medical device safety for their patients.
(Part 2)
Post-market Surveillance
No device is risk free, regardless of the level of pre-market review prior to marketing the device in the broad clinical community. Rare, yet potentially serious safety problems, a significant rise in anticipated risks, design problems, quality issues, and manufacturing problems may occur once any device is in widespread use. These post-market issues may occur regardless of regulatory class and whether or not the device underwent pre-market clinical testing. This may be explained, at least in part, because conditions of use during the clinical trial phase for Class III devices (and for the Class II devices for which clinical data were also necessary) may differ from routine clinical use following FDA clearance or approval. For example, in a clinical study, the device is often used by highly trained and experienced physicians, in a limited number of study sites, and in a relatively small population that is well defined. However, once these devices are legally marketed in the U.S., the device is available for use by physicians with a wider range of training and experience. Hence, it may be used in a wider patient population, and the post-market clinical performance of the device may differ from that observed in clinical trial(s) with the device. Timely reporting by device users of problems associated with medical devices in clinical use in the post-market setting is therefore critical for both manufacturers and CDRH to protect the public health (i.e., monitor device performance to identify and promptly address actual and potential safety issues).
Once the devices are on the market, CDRH learns of problems from several sources. This is often through adverse event reports received from physicians, nurses, and consumers who experience problems. However, the reports from physicians and other users of various devices often lack sufficient detail or pertinent clinical information. This makes interpretation of the event and its significance more difficult.
Otolaryngologists can play a key role in protecting the health and safety of their own patients, as well as the patients they will never see, by collaborating with CDRH through reporting device problems. This should be to both the medical device manufacturers and the CDRH. For example, it is important to report device problems that resulted in harm to the user and/or the patient, or could have caused harm if intervention did not occur. Providing as much detail as possible regarding the procedure in which the device was used, any device identifiers, and the nature of the device problem from the clinician’s perspective is vitally important. Such information permits CDRH to better evaluate the issue and take appropriate action if necessary.
Otolaryngologists are highly encouraged to use the FDA’s MedWatch voluntary program to report any device problems they encounter that have or could affect their patients’safety. Reports may be submitted in several ways. To access the on-line and paper forms (FDA Form 3500), please visit https://www.accessdata.fda.gov/scripts/medwatch/medwatch-online.htm6.
You may choose to include your name or submit the information anonymously. However, it is helpful when contact information is provided. FDA analysts may need to contact you to discuss the report. Your identity is never released to the public, even if you include your name in the report.
Alternatively, you may access the recently launched mobile application, Medwatcher, to report using your phone or tablet. This is a new and convenient way to report problems with devices and other FDA regulated medical products. This method is easy and permits you to upload pictures of the device problem you are reporting. You may access this new application at http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/FormsandInstructions/ucm348271.htm7.
When CDRH receives a report, the post-market analyst may review the issue in a variety of ways, depending on the reported problem:
- Researching previously reported events to identify patterns associated with the product;
- Contacting the device manufacturer for its evaluation of the problem;
- Talking with clinical users of the product to gain their perspective; and
- Reviewing the literature concerning the product and specific reported issue
The analyst may consider many factors that could have caused or contributed to the event. These could include failures resulting from design, quality, manufacturing problems, human factor issues, and adverse device interactions (e.g., electromagnetic interference from one device to another).
Based on the findings, the analyst may determine that the issue should be monitored over time, or may decide that action is needed. Actions can be in conjunction with other offices within CDRH, and can include interactions with the manufacturer. They work with manufacturers in different ways: addressing labeling concerns, performing facility inspections, sending warning letters, issuing device recalls, creating requirements for post-market studies, sending “Safety Alerts”to healthcare professionals and consumers, authoring peer and non-peer reviewed articles, updating relevant websites, producing informative webcasts, conducting public workshops, and forming partnerships with device user organizations.8
Examples of some regulatory actions for otolaryngologic devices can be viewed on CDRH’s searchable database of all device recalls by entering the relevant information, such as device or manufacturer’s name. 9 An example of targeted communications to consumers and healthcare professionals, to inform them how to use devices safely, is the recent communication to consumers about the use of neti pots for rinsing nasal passages. 10 This communication resulted from several post-market reports of improper use of neti pots that may have caused or contributed to two deaths from a rare brain infection in 2011. The Louisiana State Health Department linked the infections to tap water contaminated with an amoeba called Naegleria fowleri that may have been introduced into the nose via neti pots.
In summary, otolaryngology is a complex, multifaceted surgical specialty that touches every part of the patient care experience including outpatient, emergency care, surgery, and nursing homes. Furthermore, our specialty has a history, present, and future of innovation that is necessary to provide cutting-edge care to patients. As such, we are especially vulnerable to issues with medical devices and products. This primer, written in conjunction between otolaryngologists and the FDA will hopefully draw attention to the significant role both groups have in medical device safety and surveillance. Physicians are encouraged to report events not only to the manufacturer, but also to CDRH. Many types of device problems occur intermittently. For this reason, large macro-level databases that are needed to rapidly identify trends in issues with a particular device. The onus lies with us to immediately and consistently report issues with devices we encounter. This allows the FDA to aggregate individual issues into meaningful, actionable data.
References
- Medwatch Program https://www.accessdata.fda.gov/scripts/medwatch/medwatch-online.htm(Last accessed on 11-25-13).
- Med watcher Mobile Application http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/FormsandInstructions/ucm348271.htm (Last accessed on 11-25-13).
- Post-market Analyst Actions Flack, Marilyn; Gross, Thomas P.; and Samuels-Reid, Joy, et. al., “FDA Working to Ensure the Safety of Medical Devices used in the Pediatric Population,”pg. 1358, from, Pediatric Clinics of North America, December 2012, Editors Jacobs, Brian and Coppes, Max.
- Recalls http://www.fda.gov/MedicalDevices/Safety/ListofRecalls/ucm295488.htm. (Last accessed on 11-25-13).
- Consumer Updates http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm316375.htm (Last accessed on 11-25-13).