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FUNDAMENTALS

What are Design Controls

Design controls are systematic processes and procedures that ensure medical devices are designed to meet user needs and intended uses. They establish a framework for managing design and development activities from conception through production, ensuring safety, efficacy, and regulatory compliance. These controls provide documented evidence that design outputs meet design inputs, that risks are identified and mitigated, and that the final product performs as intended. They’re not just regulatory checkboxes. They’re essential quality management practices that prevent costly design flaws and ensure patient safety.

Relevant Standards

  • ISO 13485:2016, Clause 7.3 - Design and Development
  • QMSR 21 CFR 820.30 (Incorporated by reference to ISO 13485 per 820.7)
PHASE 1

Planning: Setting the Foundation

Effective design control begins with comprehensive planning. Organizations must establish and document critical planning elements before design activities commence. This upfront investment prevents costly rework and ensures regulatory compliance throughout the development lifecycle.

01 Design and Development Stages

Define the distinct stages of the design and development process, including clear boundaries and transitions between each stage (e.g., concept, design input, design output, verification, validation, transfer).

02 Review, Verification, and Validation Activities

Specify the appropriate review, verification, and validation activities for each design and development stage. This ensures that design outputs meet inputs and the final product meets user needs and intended use.

03 Responsibilities and Authorities

Clearly assign responsibilities and authorities for each design and development activity. This includes defining who is accountable for decisions, documentation, approvals, and execution throughout the process.

04 Resource Needs and Competence

Identify all necessary resources, including personnel, infrastructure, and work environment. Define the required competencies for personnel involved in design and development, and ensure adequate training is provided.

05 Traceability Methods

Establish and document methods for ensuring traceability between design inputs, design outputs, verification activities, and validation activities. This helps manage design changes and provides documented evidence for compliance.
These planning requirements aren’t optional—they’re mandatory documentation that auditors will review. Organizations that skip thorough planning often face delays, quality issues, and regulatory observations during inspections.

Applicable Regulatory Requirements

  • ISO 13485:2016, Clause 7.3.2 (a-f) - Design and development planning
  • 21 CFR 820.30(b) - Design and development planning
PHASE 2

Design Inputs: The Requirements Foundation

Design inputs are the foundation upon which your entire device is built. These inputs must be complete, unambiguous, able to be verified or validated, and not in conflict with each other.

Risk Management Integration

Design inputs must include applicable outputs from risk management activities. This ensures that identified hazards and associated risks are directly addressed in the device design from the earliest stages, not retrofitted later.

Verification Readiness

Every requirement must be written in a manner that allows for objective verification or validation. Ask: “How will we prove this requirement has been met?” If you can’t answer that question, the requirement needs refinement.

Completeness and Clarity

Requirements must be comprehensive enough to fully describe what the device must do, yet clear enough that there’s no ambiguity in interpretation. Conflicting requirements must be resolved before design activities proceed.

Applicable Regulatory Requirements

  • ISO 13485:2016, Clause 7.3.3 - Design and development inputs
  • 21 CFR 820.30(c) - Design input

Design Inputs: Practical Examples

Avoid Subjective Requirements

Indicate a Possible Test

Indicate a possible test by adding a simple phrase to connect a specific criterion to the requirement.
  • Screen must be visible from a distance of 1m.
  • Pump shall be able to deliver fluid continuously for 30 minutes at a rate of 2ml/min.

Avoid Making Multiple Requirements

Each requirement should address a single testable criterion. When you see “and” or “or” in a requirement, consider splitting it into separate, independently verifiable requirements.
Multiple Requirements: “The battery low warning lamp shall light up when the voltage drops below 3.6 volts AND the current workspace OR input data shall be saved.”This contains multiple separate requirements that should be split into individual, independently verifiable requirements.

Design Inputs: Quality Characteristics

Good design inputs address functional requirements (what the device does), performance requirements (how well it does it), and constraint requirements (the boundaries within which it operates). Each category requires different verification approaches and acceptance criteria. A well written Requirements Specification will have the following attributes:

Applicable Regulatory Requirements

  • ISO 13485:2016, Clause 7.3.3 - Design and development inputs
  • 21 CFR 820.30(c) - Design input
PHASE 2

Design Outputs: Documented Evidence

Design outputs are the tangible results of your design and development process—the specifications, procedures, and documentation that define exactly what gets built and how.

Applicable Regulatory Requirements

  • ISO 13485:2016, Clause 4.2.3 - Medical Device File (MDF) requires organizations to establish and maintain a central repository of design output documentation for each device type or family.
  • ISO 13485:2016, Clause 7.3.4 - Design and development outputs must be documented, meet the design and development input requirements, provide appropriate information for purchasing, production, and service provision, and include acceptance criteria.
  • 21 CFR 820.30(d) - Design output procedures must ensure that design outputs are expressed in terms that allow for adequate evaluation against design input requirements, and are verified and validated.

01 Device Description & Labeling

General description, intended use/purpose, and all labeling including instructions for use

02 Product Specifications

Complete technical specifications defining the device’s physical, functional, and performance characteristics

03 Manufacturing/Production Procedures

Specifications and procedures for manufacturing, packaging, storage, handling, and distribution (software => production, distribution)

04 Measurement & Monitoring

Procedures for measuring and monitoring device performance and quality throughout its lifecycle

05 Installation Requirements

As appropriate, specific requirements and procedures for device installation

06 Servicing Procedures

As appropriate, detailed procedures for maintenance, repair, and servicing activities PHASE [ALL/ANY]

Design Review: Critical Evaluation

Design reviews are formal, documented, systematic examinations of design results to evaluate the design’s ability to meet requirements and identify problems. These reviews serve as critical checkpoints throughout the design lifecycle, bringing together multidisciplinary teams to assess progress, identify risks, and ensure design integrity.

Applicable Regulatory Requirements

  • ISO 13485:2016, Clause 7.3.5 - Design and development review
  • 21 CFR 820.30(e) - Design review

Who Participates?

Include representatives from all functions concerned with the design stage being reviewed—engineering, quality, regulatory, clinical, manufacturing, and marketing. Independent reviewers provide objective assessment.

When Do They Occur?

At appropriate phases such as feasibility completion, design input finalization, design output completion (“DESIGN FREEZE”), and before design transfer. The number and timing depend on device complexity and risk.

What Gets Reviewed?

All design outputs relevant to the stage being reviewed, verification and validation results, risk analysis outputs, usability data, and any issues or concerns raised since the previous review.

Documentation Requirements

Minutes must identify participants, design elements reviewed, issues identified, action items assigned, and evidence that design requirements have been met. PHASE 3

Verification & Validation: Proving Design Success

Applicable Regulatory Requirements

  • ISO 13485:2016, Clause 7.3.6, 21 CFR 820.30(f) - Design and development verification / design verification
  • ISO 13485:2016, Clause 7.3.7, 21 CFR 820.30(g) - Design and development validation / design validation

Understanding V&V

Verification means confirmation by examination and provision of objective evidence that the design output meets the design input requirements. It answers: “Did we build it right?” Validation means confirmation by examination and provision of objective evidence that devices conform to defined user needs and intended uses. It answers: “Did we build the right thing?”

Key Requirements

Document V&V plans including methods, acceptance criteria, and statistical techniques with rationale for sample size Verification confirms that specified requirements have been fulfilled. Validation ensures that particular requirements for a specific intended use can be consistently fulfilled using PRODUCTION EQUIVALENT units under actual or simulated use conditions.

Documentation Standards

Organizations must document comprehensive verification and validation plans before testing begins. These plans establish the testing roadmap, defining exactly what will be tested, how it will be tested, what constitutes success, and how many samples will be evaluated. User Needs, Design Input, Design Process, Design Output, Medical Device, Review, Verification, Validation

V&V Planning

Applicable Regulatory Requirements

  • ISO 13485:2016, Clause 7.3.6 - Design and development verification (plans shall include statistical techniques with rationale for sample size)
  • ISO 13485:2016, Clause 7.3.7 - Design and development validation (plans shall include statistical techniques with rationale for sample size)
Effective V&V requires careful planning and documentation before testing begins. The planning phase establishes the foundation for objective, reproducible testing that demonstrates regulatory compliance and design integrity. V&V plans can be standalone documents or integrated sections within V&V protocols. Interfaces must be considered and tested during both verification and validation activities.
A critical principle: V&V should NOT be an experiment. By the time you reach formal V&V, you should already know the outcome and capability of your system based on feasibility studies, design characterization, and dry-run testing. Formal V&V confirms what you already know with statistical rigor—it shouldn’t be discovering basic performance characteristics.

V&V Critical Principles

  • Not an Experiment
  • Know Outcomes Beforehand
  • Do Feasibility Studies
  • Perform Dry-Run Tests

Sampling Strategies

Type Testing (N=1)

Use when there is NO variation in test performance, confirming presence/absence of features, or fixed design characteristics. A single sample sufficiently demonstrates compliance because the result will be identical across all units.

Attribute Data Analysis

For pass/fail data with variation, use methods like Bayes Success Run, binomial confidence intervals, or acceptance sampling plans. These techniques handle go/no-go results where variation affects pass rates.

Variable Data Analysis

For continuous measurements, use Normal Tolerance Intervals or capability studies with normal distribution. Options include testing many units mid-range, stress testing to induce failures, or testing fewer units at worst-case conditions. PHASE [ALL/ANY]

Design Changes

Applicable Regulatory Requirements

  • ISO 13485:2016, Clause 7.3.9, 21 CFR 820.30(i) - Design and development changes
Design changes are inevitable throughout a device’s lifecycle. Effective change control ensures that modifications are properly evaluated, documented, and approved before implementation, maintaining device safety and regulatory compliance.

When Design Changes Occur

Design Change Control Process

1

Identification & Documentation

Document the proposed change, rationale, and affected design elements. Assign unique change control number for traceability.
2

Impact Assessment

Evaluate impact on design inputs, outputs, risk analysis, verification/validation, and regulatory submissions. Determine if change is significant.
3

Verification or Validation

Conduct appropriate testing or re-testing to confirm the change achieves intended results without introducing new risks or failures.
4

Review & Approval

Cross-functional review by design, quality, regulatory, and other stakeholders. Formal approval before implementation.
5

Implementation & Communication

Update all affected documentation. Train personnel and communicate changes to relevant parties.
Important: Not all changes require full validation. Use risk-based approach to determine appropriate level of verification or validation. Specifically, design changes occurring after formal verification and validation activities have begun require careful review, as these changes may impact testing that has already been completed and may necessitate re-testing or additional validation activities.
PHASE 4

Design Transfer

Applicable Regulatory Requirements

  • ISO 13485:2016, Clause 7.3.8, 21 CFR 820.30(h) - Design and development transfer
Design transfer is the process by which a medical device’s design is correctly translated into production specifications.

Production Readiness

Ensure manufacturing/production processes can consistently produce devices that meet all design specifications and quality requirements (eg. pilot production runs, process validation etc.)

Documentation & Training

Verify that all production specifications, work instructions, and quality control procedures are complete, accurate, and traceable to design outputs. Complete training of all production personnel.

Cross-Functional Alignment

Establish clear communication and shared understanding between design, manufacturing, quality, and regulatory teams. Conduct design transfer readiness assessments. DOCUMENTATION

Design & Development File

Applicable Regulatory Requirements

  • ISO 13485:2016, Clause 7.3.10, 21 CFR 820.30(j) - Design and development files
The Design History File (DHF) is a compilation of records that describes the design history of a finished medical device. It demonstrates that the design was developed in accordance with the approved design plan and regulatory requirements.

What the DHF Contains

Best Practice: Maintain the DHF as a living document throughout development, not as an afterthought before submission. Use a centralized document management system to ensure version control, traceability, and easy retrieval during audits or inspections.