Let's Talk Risk! Podcast

Where MedTech professionals gain clarity and confidence to navigate complex decisions.

Let’s Talk Risk! brings together MedTech leaders and practitioners for thoughtful conversations on the challenges that shape risk, quality, innovation, and leadership. With 150+ episodes and more than 30K downloads, it helps professionals gain the clarity and confidence to lead through complex decisions. naveenagarwalphd.substack.com

  1. LTR 159: The Evolving Regulatory Landscape for AI in MedTech

    5일 전

    LTR 159: The Evolving Regulatory Landscape for AI in MedTech

    Summary “Stop thinking of AI as replacing humans. Think about humans staying in charge while AI is placed in the loop” Artificial intelligence is no longer a future concept in MedTech. It is already inside medical devices, quality systems, regulatory workflows, post-market processes, and product development decisions. In this episode of the Let’s Talk Risk Podcast, host Naveen Agarwal sits down with Priya Setty and Atty Chakraborty for a wide-ranging discussion on how AI is changing medical device regulation and quality practice. Priya frames AI through a human lens: like a child growing into adulthood, AI needs supervision, boundaries, and responsible “parenting.” Atty builds on that by explaining how the conversation has shifted from “How do we regulate AI?” to more practical questions about testing, validation, acceptance criteria, context of use, and lifecycle control. The discussion covers the EU AI Act, FDA’s total product lifecycle approach, global regulatory trends, post-market complaint triage, AI in audits and quality operations, change control, PCCP, and the career implications for QA/RA professionals. A recurring theme is clear: AI can improve the quality, consistency, and timeliness of decisions, but only if humans remain in charge. Chapters 00:00 – Introduction: AI in MedTech and why this conversation matters 03:06 – Priya’s child development lens for understanding AI governance 08:45 – EU AI Act vs MDR: horizontal regulation meets medical device rules 11:15 – FDA’s lifecycle approach to AI-enabled medical devices 23:17 – AI in post-market complaint triage and safety signal detection 31:57 – PCCP for AI-enabled devices: opportunity, adoption, and business case 36:05 – Career implications for QA/RA professionals If you enjoyed this podcast, consider subscribing to the Let’s Talk Risk! newsletter. Suggested links: * Navigating convergence and divergence between the EU MDR and EU AI Act * LTR: Case Study: Contrasting U.S. and EU Approaches to AI Regulation * LTR: LTR Risk Coach - AI-Powered Decision Support Tool. Key Takeaways * AI is not new, but the risk profile has changed.What has changed is broader access, greater autonomy, and higher consequence decisions. * AI governance is about keeping humans in charge.Organizations need clear boundaries, validation, monitoring, and human judgment at critical decision points. * The EU and FDA are approaching AI differently.The EU AI Act creates a broad governance overlay, while FDA continues to emphasize lifecycle control, context of use, and post-market performance. * AI can strengthen QA/RA work if used carefully.It can support complaint triage, audit preparation, regulatory intelligence, quality documentation, and change assessment. * Post-market monitoring becomes even more important with AI.AI systems should not be treated as “validated once and valid forever,” especially when models may drift or behave differently in real-world use. * PCCP is useful when the product roadmap is clear.It can support planned AI changes, but it is not a shortcut for uncertain models or poorly defined strategy. * QA/RA professionals need AI governance fluency.They do not need to become data scientists, but they should understand intended use, bias, drift, validation, and where human review is essential. Keywords AI in medical devices, AI governance, AI-enabled medical devices, EU AI Act, FDA AI guidance, lifecycle management, post-market monitoring, PCCP, complaint triage, AI validation, change control, QA/RA professionals About Priya Setty Geethapriya (Priya) Setty is a regulatory affairs strategist and systems builder with over eight years in global regulatory affairs and more than twenty years in healthcare. Starting her career as a pediatric occupational therapist, Priya brings a unique blend of clinical insight and policy expertise to the evolving world of medical technology. She leads regulatory intelligence and digital transformation initiatives at a global medical device company, specializing in global regulatory strategy, regulatory intelligence, and digital health/AI compliance for high-risk devices. Priya is adept at navigating complex regulations such as the EU AI Act and FDA guidance, ensuring compliance is embedded in every innovation. A certified PMP, RAC (Devices), and ISO 13485 lead auditor, Priya is known for demystifying complex regulations and building systems that keep teams ahead of industry changes. Guided by her mantra, “make a choice, and make it happen,” she is dedicated to leadership, mentorship, and simplifying healthcare through curiosity and purpose-driven action. About Attrayee Chakraborty Attrayee Chakraborty is a quality and regulatory leader specializing in digital health and AI-enabled medical devices. At Analog Devices, she drives QMS development, risk management, and AI governance to meet global regulatory standards. Recognized as Quality Magazine’s 2025 “Rookie of the Year” and a 2025 RAPS Rising Star, Attrayee has delivered talks at major industry events including RAPS, MDM West, and ISPE. She also serves on working groups with IEEE, RAPS, and SQA, shaping the future of healthcare AI compliance. Passionate about empowering early-career professionals, she bridges the gap between regulatory rigor and real-world innovation. Disclaimer Information and insights presented in this podcast are for educational purposes only. Views expressed by all speakers are their own and do not reflect those of their respective organizations. Parts of this article were created using AI-generated content, which was subsequently reviewed, edited, and fact-checked by the author to ensure accuracy and alignment with our standards. This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit naveenagarwalphd.substack.com/subscribe

    42분
  2. Case Study: FDA’s New Expectation for Use-Related Risk in Medical Device Submissions

    6월 19일

    Case Study: FDA’s New Expectation for Use-Related Risk in Medical Device Submissions

    You cannot reverse engineer your human factors regulatory strategy at the 11th hour. FDA’s new human factors guidance is not just about what goes into a marketing submission. It changes the way teams need to think about use-related risk, critical tasks, labeling, training, post-market evidence, and design change control across the product lifecycle. In this audio case study, we walk through why Category 3 human factors validation may become the default concern when critical tasks are introduced or impacted and why Decision Point D is not a shortcut, but an evidence-based exception that depends on history of use, user interface complexity, and the adequacy of existing risk controls. Key highlights covered in the audio: * Why human factors can no longer be treated as a late-stage submission activity * How use-related risk analysis drives the identification of critical tasks * Why Category 3 validation may be triggered by more than obvious design changes * How Decision Point D may reduce submission burden — but only with strong evidence * Why post-market surveillance data now has direct pre-market strategic value Keywords: FDA human factors guidance, medical device marketing submissions, use-related risk analysis, critical tasks, Category 3 human factors validation, Decision Point D, eSTAR, QMSR, medical device usability, post-market surveillance, design validation, medical device labeling. 🎧Click Play above to listen to a brief audio summary about this case and lessons QA/RA and Clinical professionals can apply in practice using the newly released FDA Guidance. Thanks for reading Let's Talk Risk!. If you liked this post, share with others. Note: The audio summary was prepared using Google NotebookLM, an AI-enabled research tool. Here are a few key resources used for this analysis: * FDA (2026, May 29), Content of Human Factors Information in Medical Device Marketing Submissions, Final Guidance, FDA. * Al-Faruque, F. (2026, May 28). FDA provides additional examples, clarity in human factors guidance. Regulatory Affairs Professionals Society (RAPS). * Lenz, A. R. (2026, June 3). FDA Issues Final Guidance for Content of Human Factors Information in Medical Device Submissions. FDA Law Blog. * Pure Global. (2026, June 2). FDA Human Factors Guidance 2026 Update for Device Submissions. Pure Global Regulatory News. * Regulatory Evolution of Human Factors in Medical Device Submissions: A Comprehensive Analysis of the Final FDA Guidance and Its Quality System Implications. (2026). * Strochlic, A. (2026, May 29). Key Updates in the Final FDA Guidance: Content of Human Factors Information in Medical Device Marketing Submissions (2026). Emergo by UL. This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit naveenagarwalphd.substack.com/subscribe

    41분
  3. LTR 158: Three Questions To Keep Risk Connected to Decisions

    6월 12일

    LTR 158: Three Questions To Keep Risk Connected to Decisions

    Summary “Tools do not remove uncertainty” In this Let’s Talk Risk! conversation, host Naveen Agarwal speaks with Vilma Nasteckiene, PhD, founder of Holistic Business Risk, about a broader and more human view of risk management. Vilma brings experience from banking, fintech, operational excellence, consulting, research, and business transformation. Her work focuses on reconnecting risk management with the real habits, decisions, tensions, and accountability practices that shape how organizations actually operate. This conversation moves beyond medical device risk management in the narrow technical sense. Instead, it explores risk as a business discipline: how companies grow, how complexity creates silos, how risk becomes disconnected from decision-making, and why mature risk management requires more than procedures, reports, and frameworks. Vilma offers three simple questions for a balanced approach to lifecycle risk management: What are we trying to achieve? What do we rely on to achieve it? How could it fail? The discussion connects directly to medtech, where product lifecycle, organizational lifecycle, regulatory expectations, patient safety, and business sustainability often collide. Listen to the full 30-minute podcast or jump to a section of interest listed below. Chapters 00:00 – Introduction01:10 – Vilma’s journey into holistic business risk02:40 – When risk management drifts away from real business decisions05:55 – What lifecycle risk management means07:20 – Why companies lose risk visibility as they scale09:00 – Applying lifecycle thinking to organizations and products12:45 – Co-creating better risk expectations with regulators and industry15:25 – Mature business practices as risk management practices20:10 – Strategic planning as a risk control22:00 – Three questions for reconnecting risk with decisions25:20 – Why tools do not remove uncertainty27:20 – Closing remarks and key takeaways If you enjoyed this podcast, consider subscribing to the Let’s Talk Risk! newsletter. Suggested links: LTR: Lifecycle Risk Integration Under QMSR. LTR: Different Functions, Different Risk Lenses. LTR: LTR Risk Coach - AI-Powered Decision Support Tool. Key Takeaways * Risk management cannot be separated from business management. If risk is delegated entirely to a risk department, it will eventually lose contact with the decisions that actually create or reduce risk. * Organizations often outgrow their risk management systems. As companies scale, complexity increases. Risk may shift from real-time decision-making into reporting, dashboards, procedures, and post-hoc justification. * Lifecycle thinking applies at more than one level. It applies to the organization, the product, the service, and the regulatory relationship. A startup, a scale-up, and a mature company should not all manage risk in exactly the same way. * More procedures do not automatically mean better risk management. Vilma challenges the idea that visible documentation equals maturity. A company can have many procedures and still fail to connect risk with daily decisions. * Strategic planning can be a powerful risk practice. Growth, profitability, compliance, innovation, and safety can create competing pressures. If those tensions are not addressed at the strategy level, they are pushed down into functions. * Simple questions can reconnect risk to reality. Vilma’s practical questions are: What are we trying to achieve? What do we rely on to achieve it? How could it fail? * Risk maturity is more than frameworks and tools. Tools can help organize uncertainty, but they cannot remove it. They also cannot fully capture hesitation, silence, weak signals, informal concerns, or leadership behavior. * Regulators and industry can reduce “fake fear” by co-creating expectations. Vilma’s fintech example shows the value of bringing regulators, founders, and practitioners into the same room to design risk expectations that reflect real operating maturity. Keywords Risk management, lifecycle risk management, risk maturity, holistic business risk, Vilma Nasteckiene, medtech risk, fintech risk, business risk, strategic planning, operational risk, risk culture, regulatory expectations, weak signals, leadership habits, decision-making, ISO 31000, risk governance, organizational maturity, risk-based thinking, Let’s Talk Risk About Vilma Nasteckiene Vilma Nasteckiene is the founder of Holistic Business Risk and describes her work as helping organizations “unfake and destigmatize risk management.” Her mission is to humanize risk perception and connect business and risk management to the daily habits of resilient, antifragile organizations. She works with managers, regulators, and auditors to connect purpose, client needs, processes, and risk management into visible collaborative practice. Vilma’s background includes banking, credit risk, operational risk, business process management, consulting, research, and system change. She contributed to fintech regulatory requirements and best-practice development in Lithuania, completed PhD research on risk management in management practices, helped initiate national adoption of ISO 31000 and related standards in Lithuania, and co-founded the Lithuanian Association of Risk Management Professionals. Her work emphasizes the practical connection between strategy, accountability, operations, leadership behavior, and risk maturity. Let’s Talk Risk! with Dr. Naveen Agarwal is a bi-weekly live audio event on LinkedIn, where we talk about risk management related topics in a casual, informal way. Join us at 11:00 am EST every other Friday on LinkedIn. Disclaimer Information and insights presented in this podcast are for educational purposes only, and not as legal advice. Views expressed by all speakers are their own and do not reflect those of their respective organizations. Parts of this article were created using AI-generated content, which was subsequently reviewed, edited, and fact-checked by the author to ensure accuracy and alignment with our standards. This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit naveenagarwalphd.substack.com/subscribe

    28분
  4. LTR 157: Why Risk Doesn't Get Heard and How to Change That

    5월 29일

    LTR 157: Why Risk Doesn't Get Heard and How to Change That

    Summary “Quality and risk people need to translate safety into business terms.” In this Let’s Talk Risk! conversation, host Naveen Agarwal speaks with Eric Sugalski about how MedTech professionals can communicate safety, risk, and innovation more effectively to senior leaders. Eric brings a broad product-development perspective across engineering, manufacturing, regulatory strategy, commercialization, and early-stage MedTech leadership. He discusses why innovation and safety should not be treated as separate conversations, why risk professionals need to get involved earlier, and how safety-led thinking can reduce rework, improve alignment, and strengthen business outcomes. The conversation also explores the siloed nature of MedTech, the need for cross-functional decision-making, and how QA/RA and risk professionals can increase their influence by connecting safety concerns to revenue, time, market success, and leadership priorities. Listen to the full 30-minute podcast or jump to a section of interest listed below. Chapters 00:00 – Introduction02:40 – Why MedTech innovation is moving faster05:00 – Thinking about safety beyond compliance08:00 – Safety-led innovation as a business advantage11:00 – Bringing safety into early product development13:35 – Communicating risk and safety to senior leaders16:30 – Why quality and risk need a strategic seat earlier18:45 – Translating safety into business terms20:25 – Building cross-functional leadership skills21:40 – MedTech Mindset and deeper industry conversations25:35 – Closing remarks and key takeaways If you enjoyed this podcast, consider subscribing to the Let’s Talk Risk! newsletter. Suggested links: LTR: Learning to Effectively Communicate Regulatory Risk. LTR: How GenAI is Transforming Quality in MedTech. Skool: MedTech Mindset Community by Eric Sugalski. Key Takeaways * Safety can be a driver of innovation, not a constraint. When safety is considered early, it can guide better requirements, reduce rework, and support stronger product decisions. * MedTech teams are still too siloed. Engineering, regulatory, quality, clinical, and commercial teams often work with different definitions of success, which can weaken decision-making. * Risk professionals need to get involved earlier. If quality and risk teams only enter after problems occur, their role stays corrective instead of strategic. * Leadership influence requires business language. Translating safety and risk into time, revenue, delay, rework, and market impact helps leaders understand why action matters. * Professional growth is proactive. Eric emphasizes that MedTech professionals must actively seek cross-disciplinary learning if they want to expand their influence. Keywords MedTech leadership, safety-led innovation, risk communication, medical device product development, quality leadership, regulatory strategy, cross-functional alignment, senior leadership, MedTech startups, business case for safety, patient safety, product development, commercialization, risk management, QA/RA leadership About Erick Sugalski Eric Sugalski is President of Tangram Medtech, where he serves as a fractional VP of Engineering for MedTech companies working to clear FDA, launch manufacturing, and build products that can succeed in the market. His work connects product development with regulatory strategy, manufacturing readiness, clinical considerations, commercial fit, and cross-functional alignment. Eric is also founder and CEO of Ampulis, which partners with pharma companies to design and manufacture combination products, and he is involved as a MedTech investor with Robin Hood Ventures. His background spans product development, prototyping, manufacturing, human factors, regulatory affairs, supply chain, commercialization, and medical device entrepreneurship. Let’s Talk Risk! with Dr. Naveen Agarwal is a bi-weekly live audio event on LinkedIn, where we talk about risk management related topics in a casual, informal way. Join us at 11:00 am EST every other Friday on LinkedIn. Disclaimer Information and insights presented in this podcast are for educational purposes only, and not as legal advice. Views expressed by all speakers are their own and do not reflect those of their respective organizations. Parts of this article were created using AI-generated content, which was subsequently reviewed, edited, and fact-checked by the author to ensure accuracy and alignment with our standards. This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit naveenagarwalphd.substack.com/subscribe

    27분
  5. LTR 156: Using AI as a Thinking Partner in Product Development Without Losing Control

    5월 22일

    LTR 156: Using AI as a Thinking Partner in Product Development Without Losing Control

    Summary “AI can be a powerful helper, but it should not be the decision-maker.” In this Let’s Talk Risk! conversation, host Naveen Agarwal speaks with David Grilli about how MedTech teams can use AI responsibly in product development without losing control of risk, quality, or accountability. David brings experience across medical device risk management, system safety, reliability engineering, and regulated product development. He shares practical examples of where AI may help—such as requirements development, software troubleshooting, and early discovery—while emphasizing the need for clear boundaries, human judgment, validation, and leadership oversight. The conversation also explores how teams should define the intended use of AI applications, how to communicate AI proposals to leadership, and why AI should be treated as a cognitive partner rather than an accountable decision-maker. Listen to the full 30-minute podcast or jump to a section of interest listed below. Chapters 00:00 – Introduction03:20 – Where AI is showing up in product development05:00 – Using AI for requirements without giving up decision authority08:45 – Treating AI as a helper, not an accountable decision-maker12:00 – AI for debugging, code review, and software troubleshooting16:00 – Data quality, training inputs, and weak answers17:30 – AI in early discovery and idea-stage development18:40 – Making the leadership case for AI adoption20:55 – Intended use, validation, and QMS expectations22:35 – Where human review belongs in AI-enabled workflows25:40 – David’s key takeaways If you enjoyed this podcast, consider subscribing to the Let’s Talk Risk! newsletter. Suggested links: LTR: Building Trustworthy AI and MedTech Readiness. LTR: What AI/ML Device Recalls Reveal About Emerging Risks. LTR: LTR Risk Coach - AI-Powered Decision Support Tool. Key Takeaways * AI should support judgment, not replace it. David emphasizes that AI can help generate options, identify gaps, and accelerate work, but humans remain accountable for decisions. * Start with high-impact, low-risk use cases. Requirements drafting, debugging, and discovery support may be practical starting points when clear review controls are in place. * Define the intended use before deploying AI. Teams should be clear about what AI is allowed to do, what it is not allowed to do, and where human review is required. * Leadership needs more than enthusiasm. A credible AI proposal should include workflow, expected benefit, risks, mitigations, validation expectations, and decision criteria. * AI adoption is a governance challenge. As AI enters product development, teams must build review points, instructions, and accountability into the development process. Keywords AI in MedTech, artificial intelligence, product development, medical device risk management, ISO 14971, system safety, software validation, design controls, requirements development, human judgment, AI governance, QMS, risk-based decision-making, leadership, product innovation About David Grilli David Grilli is a senior engineering consultant supporting teams building safety-critical, regulated, and operationally complex systems. His background spans more than 15 years across medical device risk management, aviation reliability engineering, and system safety, with experience in ISO 14971, MIL-STD-882, design reviews, hazard analysis, failure-mode analysis, technical justification, and audit readiness. David is also the founder of North Star Haptics, where he applies systems risk, reliability awareness, and human-interface thinking to early-stage tactile technology development. His prior experience includes senior risk management engineering at Abbott and reliability and system safety work at Honeywell. Let’s Talk Risk! with Dr. Naveen Agarwal is a bi-weekly live audio event on LinkedIn, where we talk about risk management related topics in a casual, informal way. Join us at 11:00 am EST every other Friday on LinkedIn. Disclaimer Information and insights presented in this podcast are for educational purposes only, and not as legal advice. Views expressed by all speakers are their own and do not reflect those of their respective organizations. Parts of this article were created using AI-generated content, which was subsequently reviewed, edited, and fact-checked by the author to ensure accuracy and alignment with our standards. This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit naveenagarwalphd.substack.com/subscribe

    27분
  6. LTR 155: Leverage VIP to Move from Compliance to Capability

    5월 15일

    LTR 155: Leverage VIP to Move from Compliance to Capability

    Summary “Compliance alone does not drive quality” In this Let’s Talk Risk! conversation, host Naveen Agarwal speaks with Mike Cook about the the Voluntary Improvement Program (VIP), and how it can help MedTech leaders go beyond inspection readiness toward true quality maturity. Mike explains how VIP grew out of FDA’s Case for Quality initiative, why the program uses a maturity-appraisal model rather than a traditional audit model, and how organizations can use it to surface operational weaknesses, strengthen quality culture, and translate quality improvement into business language. The conversation also explores why many companies struggle to make the business case for proactive QMS improvement, how VIP may help organizations prepare for the expectations of QMSR, and why quality leaders need to connect risk reduction, operational excellence, and sustainable business performance. Listen to the full 30-minute podcast or jump to a section of interest listed below. Chapters 00:00 – Introduction01:40 – From Case for Quality to VIP03:45 – What makes VIP different from an audit07:40 – How appraisals reveal QMS maturity11:00 – Translating quality into business language13:00 – Why leaders hesitate to invest in improvement16:05 – Cost, ROI, and regulatory benefits of VIP18:10 – The challenge of status quo21:15 – How VIP may support QMSR readiness24:30 – Key Takeaways If you enjoyed this podcast, consider subscribing to the Let’s Talk Risk! newsletter. Suggested links: LTR: QMSR and the Assurance Mindset: A Leadership Imperative LTR: How Quality can Help Overcome MedTech R&D Challenges. LTR: LTR Risk Coach - AI-Powered Decision Support Tool. Key Takeaways * Compliance is not the same as quality. VIP grew from the recognition that both compliant and non-compliant companies can still face similar quality and safety problems. * VIP is not a traditional audit. It uses a third-party appraisal model to assess maturity, capability, and how work is actually performed across the organization. * Quality improvement needs executive language. Mike emphasized that appraisal results can help translate quality into ROI, risk reduction, cost avoidance, and strategic decision-making input. * The biggest barrier may be status quo. Many organizations know improvement is needed but struggle to pause reactive work long enough to invest in a different operating model. * QMSR raises the stakes for maturity. As FDA focuses more on risk-based decisions and QMS effectiveness, maturity models may help companies strengthen internal capability before gaps become visible through inspection. Keywords FDA Case for Quality, VIP Program, Voluntary Improvement Program, QMSR, quality maturity, QMS improvement, operational excellence, medical device quality, FDA inspections, risk management, quality culture, continuous improvement, MDIC, CMMI, MedTech leadership, quality systems About Mike Cook Mike Cook is a a Strategic Account Executive at MDDAP, LLC, where his work focuses on the Voluntary Improvement Program and helping medical device manufacturers strengthen quality culture, operational excellence, execution consistency, and continuous improvement beyond traditional compliance and audits. Before joining MDDAP, Mike spent more than six years at Greenlight Guru, a quality management software platform designed specifically for medical device companies. His background includes quality management systems, clinical and SaaS account leadership, diagnostic imaging, healthcare systems, and organizational leadership. Let’s Talk Risk! with Dr. Naveen Agarwal is a bi-weekly live audio event on LinkedIn, where we talk about risk management related topics in a casual, informal way. Join us at 11:00 am EST every other Friday on LinkedIn. Disclaimer Information and insights presented in this podcast are for educational purposes only, and not as legal advice. Views expressed by all speakers are their own and do not reflect those of their respective organizations. Parts of this article were created using AI-generated content, which was subsequently reviewed, edited, and fact-checked by the author to ensure accuracy and alignment with our standards. This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit naveenagarwalphd.substack.com/subscribe

    26분
  7. LTR 154: From Procedures to Judgment - Leading Through QMSR Inspections

    5월 8일

    LTR 154: From Procedures to Judgment - Leading Through QMSR Inspections

    Summary “FDA isn’t just inspecting procedures anymore. They are looking at how risk-based decisions are actually made.” In this episode of the Let’s Talk Risk Podcast, host Naveen Agarwal speaks with Michelle Lott about what early FDA 483 observations under QMSR are already revealing: a clear shift from procedural compliance to evaluating how well companies actually make risk-based decisions across their quality systems. This conversation goes beyond clauses and documentation. It explores how FDA is now looking at system effectiveness, how risk must be integrated across the full product lifecycle, and why leadership teams need to rethink how decisions are made, justified, and communicated under increasing ambiguity. Michelle brings a practical, field-level perspective on what is changing, where companies are most vulnerable, and how QA/RA teams can prepare their organizations for a more dynamic, judgment-driven inspection model. Key Points * FDA is increasingly citing deficiencies in risk management and system-level effectiveness, not just individual subsystems. * QMSR shifts inspections toward how decisions are made, not just whether procedures exist. * ISO 14971 alone is not enough—risk must extend across processes, lifecycle stages, and QMS interactions. * Post-market signals—not just complaints—are becoming critical inputs to risk management. * Leadership involvement, especially through management review, will face greater scrutiny under QMSR. Chapters 00:00 – QMSR and the New FDA Inspection LensWhat early 483s reveal about how inspections are changing 05:30 – Risk Management Beyond the Procedure (Clause 7.1)Why risk must connect across the full product lifecycle 10:40 – What “Risk-Based Approach” Really Means (Clause 4.1.2(b))How FDA may evaluate decision-making, not just documentation 17:00 – Management Review, CAPA, and Leadership AccountabilityWhy effectiveness and escalation matter more than timeliness 21:30 – From Feedback to Signals (Clause 8.2.1)How post-market data and external signals feed a living risk system 31:30 – What QA/RA Leaders Should Do NowHow teams can prepare for a more judgment-driven inspection model If you enjoyed this podcast, consider subscribing to the Let’s Talk Risk! newsletter. Suggested links: * LTR: Risk, CAPA and FDA Inspections under QMSR. * LTR: QMSR Readiness, Risk-Based Assurance and FDA Expectations. * LTR: A 90-Day Plan to Review QMSR Readiness. Keywords QMSR, FDA inspections, ISO 13485, risk-based approach, risk management, CAPA, preventive action, post-market surveillance, safety signals, management review, quality systems, MedTech regulation, 483 observations, system effectiveness About Michelle Lott Michelle Lott is the founder of Lean RAQA, where she provides fractional RA/QA leadership, audit prep, quality system design, and regulatory strategy for MedTech startups and small companies. With 20+ years of experience and an RAC certification, Michelle has helped hundreds of firms navigate FDA submissions and ISO compliance, bringing clarity and efficiency to even the most complex regulatory challenges. Disclaimer Information and insights presented in this podcast are for educational purposes only. Views expressed by all speakers are their own and do not reflect those of their respective organizations. Parts of this article were created using AI-generated content, which was subsequently reviewed, edited, and fact-checked by the author to ensure accuracy and alignment with our standards. This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit naveenagarwalphd.substack.com/subscribe

    39분
  8. LTR 153: Sherita Black on Building a Practical Policy for Risk Acceptability

    5월 1일

    LTR 153: Sherita Black on Building a Practical Policy for Risk Acceptability

    Summary “Just having a policy in place is one thing. Having a QMS that aligns to it is the next.” In this Let’s Talk Risk! conversation, host Naveen Agarwal speaks with Sherita Black about one of the most challenging and often misunderstood topics in ISO 14971: creating a policy for risk acceptability. The conversation goes beyond the standard’s wording and gets into the practical questions that many teams struggle with: who top management really is, how to involve them, and how to turn policy into something that actually drives decisions. Sherita brings a strong cross-functional perspective shaped by years of experience in pharmaceutical validation, medical device design quality, complaint handling, and enterprise risk management. In her current role as Risk Management Business Process Owner at BD, she focuses on maintaining risk management procedures, aligning stakeholders, and supporting an effective risk management program across the organization. Listen to the full 30-minute podcast or jump to a section of interest listed below. Chapters 00:00 – Introduction02:48 – What ISO 14971 expects from top management03:54 – Why a risk management policy matters05:56 – Three approaches to risk control and acceptability08:44 – How to identify the right top management group14:32 – Risk management policy vs. quality policy18:10 – What evidence auditors expect to see24:31 – Why strong risk management can become competitive advantage If you enjoyed this podcast, consider subscribing to the Let’s Talk Risk! newsletter. Suggested links: LTR: ISO 14971 Fundamentals - Risk Acceptability Policy LTR: Top Management Responsibility for Risk Management. LTR: LTR Risk Coach - AI-Powered Decision Support Tool. Key Takeaways * A risk management policy sets the framework for how an organization defines, controls, and monitors risk across the device lifecycle. * Top management in the context of ISO 14971 should be close enough to understand the device and senior enough to allocate resources and make decisions. * Risk acceptability is not one-size-fits-all; the policy should reflect device context, intended use, and the nature of the risks involved. * A risk management policy may sit within the broader quality framework, but it should remain explicit and focused on safety and benefit-risk decisions. * Auditors will look beyond the written policy and expect evidence that it is actually being executed through design controls, standards compliance, monitoring, and management review. * Strong risk management is not just about compliance; it can improve device quality, customer trust, and long-term business performance. Keywords ISO 14971, risk acceptability, risk management policy, top management, medical device safety, QMSR, design controls, benefit-risk, audit readiness, risk governance About Sherita Black Sherita Black is a quality and regulatory leader with experience across the medical device and pharmaceutical industries. She currently serves as Risk Management Business Process Owner at Beckton-Dickinson, where she is responsible for risk management procedures and cross-functional alignment to support an effective enterprise risk management program. Her background includes design quality assurance, complaint handling, post-market surveillance, regulatory compliance, and global standards implementation, with prior roles at Philips, Regulatory and Quality Solutions, and Boehringer Ingelheim. She holds degrees in biomedical engineering and industrial and human factors engineering. Let’s Talk Risk! with Dr. Naveen Agarwal is a bi-weekly live audio event on LinkedIn, where we talk about risk management related topics in a casual, informal way. Join us at 11:00 am EST every other Friday on LinkedIn. Disclaimer Information and insights presented in this podcast are for educational purposes only, and not as legal advice. Views expressed by all speakers are their own and do not reflect those of their respective organizations. Parts of this article were created using AI-generated content, which was subsequently reviewed, edited, and fact-checked by the author to ensure accuracy and alignment with our standards. This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit naveenagarwalphd.substack.com/subscribe

    29분

소개

Let’s Talk Risk! brings together MedTech leaders and practitioners for thoughtful conversations on the challenges that shape risk, quality, innovation, and leadership. With 150+ episodes and more than 30K downloads, it helps professionals gain the clarity and confidence to lead through complex decisions. naveenagarwalphd.substack.com

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