Regulatory
Philips’ 2021–2023 CPAP and CBAP recall drew criticism for slow action, leaving patients unknowingly exposed to harmful foam.
and usage could also be identified quickly using AI, for instance. “Wearables, types of hospitals at home, internal medical devices with an app…this could transform medicine,” he says.
Here, the MHRA is experimenting with this technology. They’re leading an AI airlock experiment which allows device manufacturers to explore how they can collect evidence to support the safety of products. While this is primarily concerned with readying products for approval, and focuses on AI devices, the approach could potentially help inform recall decisions, too – for instance, in helping manufacturers understand what they’re required to deliver to ensure device safety. “It shows we’re trying to get better in this area,” says Gilbert. Gilbert is confident these technologies could modernise data-sharing processes – currently, the process centres around preparing paperwork and filing it. But with digital systems, manufacturers and regulators could move towards a process where performance and safety feedback can more easily be given on devices and systems, much the way pop-ups work online. This would be a much simpler way of logging reports. It could also help to standardise reporting systems and make them more transparent. With clear processes for collecting, storing, and sharing information with the right people, firms would have little excuse for inaction. Transparency matters here, adds Gilbert. “If this is out in the open, companies have to take it seriously… [they] have to make sure their laundry isn’t dirty on the line.” The subtext being: if the right data is made accessible to all relevant parties, it wouldn’t be possible to obscure information about faulty devices – or to drag one’s feet in implementing a recall. While AI could potentially be used to automate processes and sort through large datasets in device recalls – for instance, an AI chatbot could collect
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feedback on devices while another model might automatically flag performance deviations – we’d need to figure out how we’d regulate these systems, too. Especially when integrated into a medical device. “We can’t regulate an AI decision support system the same way as a hip implant,” notes Gilbert. It’s perhaps something on the horizon in years to come.
The tools to act
As recall processes evolve, Gilbert warns they mustn’t double down on an already documentation- heavy framework. For instance, manufacturers must report incidents with their devices to regulators, document risk assessments, submit their strategy for performing the recall, deliver notification letters and more. “Manufacturers are rightly saying these documents [they have to provide] don’t do much for patient safety,” he explains, noting that even for the most comprehensive audits of devices, which could spot the need for recall or not, it’s all “the manufacturer’s filtered opinion”. Clearer reporting standards could help make this process less opaque for both manufacturers and regulators. And having streamlined reporting channels that make it easy to log data could cut down the admin burden and get things moving quicker. It gives all parties what they need to take action, faster – and if that data is more widely available, firms could potentially be held accountable should they fail to act. Plus, it gives patients and practitioners peace of mind that their concerns have been filed and received by the right people.
In its 2011 report, the GAO recommended the FDA should regularly assess how a recall is progressing and develop criteria for gauging its effectiveness. A solid flow of information from the devices, to the manufacturer and onto the regulator would certainly be a big help in tackling this problem. ●
Medical Device Developments /
www.medicaldevice-developments.com
Ann Marie Walkington/
Shutterstock.com
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