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Design Validation: More than Just User Testing

EduQuest, a global team of FDA compliance experts, answers industry’s pressing questions. In this round, Denise Dion, Vice President of Regulatory & Quality Services for EduQuest, corrects a common misconception.

Question: Really, in the final analysis, isn’t design validation just user testing?

Answer: I’ve heard that a lot lately. But it’s not true.

The Quality System Regulation (21 CFR Part 820) includes requirements for design controls. The regulation requires design validation to ensure that your design (or design change) meets both defined user needs as well as your defined intended uses. These needs and uses must be defined in the documentation of your design input requirements.

The regulation also requires that design validation be done under actual or simulated use conditions (my emphasis) with production or production equivalent units. If design validation were only user testing, the regulation would not allow for simulated use conditions. 

FDA clarifies these requirements in its Design Control Guidance for Medical Device Manufacturers: “The requirements which form the design input establish a basis for performing subsequent design tasks and validating the design.”
Furthermore, under the Validation Methods section of the Design Control Guidance, FDA says, “Many medical devices do not require clinical trials. However, all devices require clinical evaluation and should be tested in the actual or simulated use environment as a part of validation. This testing should involve devices which are manufactured using the same methods and procedures expected to be used for ongoing production.
“While testing is always a part of validation, additional validation methods are often used in conjunction with testing, including analysis and inspection methods, compilation of relevant scientific literature, provision of historical evidence that similar designs and/or materials are clinically safe, and full clinical investigations or clinical trials.”
So, design validation is really what happens near the end of the design or redesign of a medical device. It’s done as a set of various activities to answer the question, “Does this design solution actually perform and function as I intend it to, and does it meet my user needs?”
Design verification activities provide theoretical assurance that the design is appropriate in regard to your defined design input requirements. However, design validation provides evidence—beyond theoretical assurance—that the device you designed is truly safe and effective within the context of those same design input requirements.

Ms. Dion has been with EduQuest since 2002, following 18 years with FDA. Her final eight years with FDA were served at headquarters as the medical device investigator liaison between the Office of Regulatory Affairs (ORA) and the Center for Devices and Radiological Health, as well as between ORA headquarters and field staff. EduQuest can be reached by This email address is being protected from spambots. You need JavaScript enabled to view it.