258 - Combination Product Quality: Human Factors, CDMO Scorecards, ISO 14971 vs. ICH Q9, with Ben Locwin

258 - Combination Product Quality: Human Factors, CDMO Scorecards, ISO 14971 vs. ICH Q9, with Ben Locwin

Combination product quality with Ben Locwin: why drug and device quality systems differ, how human factors studies are designed, what to do when a CDMO's clean audit doesn't match its performance, and how ISO 14971 risk management compares with ICH Q9.

This conversation was recorded for Ben Locwin's Life Science Shifts podcast from Reliant Life Sciences, with Subhi Saadeh as the guest. It covers where pharma and medical device thinking diverge, and what that means when one product has to satisfy both.

IN THIS EPISODE

- Why drugs and devices prove safety and effectiveness in different ways

- Drug development (clinical, nonclinical, CMC) vs. device design controls

- Why the same syringe can need new human factors work for a different user

- How human factors studies are built: patient and caregiver arms, trained and untrained users

- CGMPs for combination products: QMSR, ISO 13485, ICH, and PIC/S

- Global harmonization: IMDRF for devices, ICH for drugs, and the gap for combination products

- CDMO oversight when the supplier scorecard and the audit result don't match what you see

- ISO 14971 and ISO/TR 24971 vs. ICH Q9: initial and updated probability

- FMEA as a living document


TIMESTAMPS

0:00 Pharma vs. medical device quality: two philosophies

2:10 Drug development vs. device design controls

4:29 Why device trials rarely use placebo controls

9:52 Platform technology and delivery devices

12:10 Same device, different user: bracketing and generic platforms

14:14 Human factors studies: recruitment, study arms, formative studies

15:40 CGMPs for combination products: QMSR, ISO 13485, ICH, PIC/S

16:58 Harmonization: IMDRF and ICH

19:12 Conway's Law and organizational inertia

22:06 Staying objective as a consultant

25:10 CDMO oversight: when the scorecard doesn't match reality

30:18 Scoring bias in subjective weighting

31:14 ISO 14971 vs. ICH Q9 risk management

32:32 FMEA as a living document


RELATED VIDEOS


Pharma vs. Medical Device Quality Systems: 5 Differences

https://youtu.be/xG0htEu0ph4


Working with a Device CDMO: Common Sponsor Mistakes

https://youtu.be/d2SDwndXuCk


ICH Q9 Explained

https://youtu.be/Is67hbh71RY


Design Controls Explained for Pharma and Combination Product Teams

https://youtu.be/f7esiLpUhfM


Need help with CDMO oversight, supplier audits, or risk management on a combination product?

https://letscombinate.com/services/


ABOUT BEN LOCWIN


Ben Locwin is Vice President at Reliant Life Sciences and host of the Life Science Shifts podcast. His work spans drug therapies, vaccines, and medical devices, and he is a frequent industry speaker and commentator on pharma and medical device quality.


Reliant Life Sciences:

https://www.reliantlifesciences.com/


ABOUT SUBHI SAADEH

Subhi Saadeh is the Founder and Principal of Let's Combinate, a consultant, auditor, and trainer specializing in drug-device combination products, medical devices, and pharmaceutical quality systems. He has held quality and engineering roles at Pfizer, Gilead, and Baxter, with experience spanning quality, R&D, and commercialization and a focus on design controls, supplier quality, inspection readiness, and translating regulatory expectations into practical execution.


Subhi is an ISO 13485 Lead Auditor and an ASQ Certified Quality Auditor and Certified Quality Engineer. He has chaired the Combination Product Working Group for Rx-360, served as International Committee Chair for the Combination Products Coalition (CPC) and as a member of ASTM Committee E55, and served on AAMI's Combination Products Committee.


CONNECT WITH SUBHI


Consulting, audits, and training:

https://letscombinate.com/services/


Discuss a project:

https://calendly.com/letscombinate/quick-chat


LinkedIn:

https://www.linkedin.com/in/subhi-saadeh-1169aa21/


Email:

subhi@letscombinate.com


FOLLOW LET'S COMBINATE


YouTube:

https://www.youtube.com/@LetsCombinate


Spotify:

https://open.spotify.com/show/71wYadhCrfLsdYTVachpD2


#CombinationProducts #HumanFactors #RiskManagement

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