Passing verification without moving the filing date

Passing verification without moving the filing date

Discretion comes first, so every case is illustrative. The method is real.

Where it started

Six weeks before design verification of a new autoinjector, characterization testing on several thousand units showed the glass syringe fracturing in about one drop in 800. The filing date for the combination product depended on the device passing verification. The parts for verification were already produced.

The strategic question

Redesign the device and move the filing. Or take a calculated risk: go into verification with the parts on the shelf, knowing a pass was likely but not certain, and fix the design afterwards.

What we found

Root cause first. The fracture traced to a housing component adjusted late in the program to ease assembly. The change left less material where the syringe rests on impact. High-speed camera and simulation confirmed it.

The verification plan added its own risk. The client’s own quality procedure fixed the sample at ten units with zero failures permitted, so a single fracture would fail the test. ISO 11608-1 also allows attribute plans with a defined number of accepted failures. With 32 units and two failures permitted, one fracture no longer decides the outcome, and a pass demonstrates higher reliability at the same 95 % confidence. The standard allowed the larger plan, but the client’s own procedure did not. The procedure had to change first.

Three directions

01

MVP

Keep the parts. Revise the internal quality procedure to allow the 32-unit sample plan

Time
6–10 weeks
Cost
€80–150k
Effect on filing
None
Risk
Medium. Passes with margin, but the design is no more robust
02CHOSEN

Golden opportunity

MVP, plus a shock-absorbing rear cap in a parallel track. One mould changes, nothing else

Time
10–14 weeks
Cost
€200–350k
Effect on filing
None
Risk
Low–medium. Ready if a late drop failure appears
03

Full ambition

Redesign the housing. New parts, new characterization, new verification

Time
12–18 months
Cost
€2.5–4M
Effect on filing
12–18 months
Risk
High. The drug waits for the device

What was chosen

Golden opportunity. Quality revised the internal procedure, and verification started on the original date with the 32-unit plan. The risk was accepted with open eyes, and the rear cap was developed alongside as insurance, tested and documented, ready to go in without opening the rest of the design.

What it gave the client

Verification passed, and the filing went in on its date. The rear cap went into the commercial design. The revised procedure now applies to the company’s other device programs too.