Summary “ISO 14971 and ICH Q9 are not competing frameworks. They are asking different questions about risk.” In this episode of the Let’s Talk Risk! conversation, host Naveen Agarwal speaks with Susan Neadle, Principal Consultant and President of Combination Products Consulting Services, to explore what changes when medical device and pharmaceutical risk-management approaches come together in a combination product. ISO 14971 places strong emphasis on hazards, hazardous situations, harms, users, and safety. ICH Q9 approaches risk through a different lens, with a strong focus on product quality, process variability, critical quality attributes, and control strategies. Susan explains why neither perspective is sufficient by itself for a combination product—and why the real challenge is understanding the interactions among the drug, device, manufacturing process, user, environment, and lifecycle. They also discuss the work underway on ISO 24971-3, intended to provide practical guidance on integrating these approaches; how new hazards and hazardous situations can emerge from constituent-part interactions; what combination products mean for supplier controls; and the leadership judgment required when technical, business, and patient considerations converge. Listen to the full 25-minute podcast or jump to a section of interest listed below. Chapters 01:19 – What Are Combination Products?02:41 – Difference in Risk Management.05:06 – Why Meeting Specifications Is Not Enough08:40 – ISO 24971-3 and the Need for Practical Integration Guidance10:49 – Bridging Drug and Device Risk Management Mindsets13:17 – ISO 14971 and ICH Q9: Different Questions About Risk14:55 – Combined Use Systems, Interface Risks, and New Hazardous Situations18:01 – Interaction Risks Between Drugs, Devices, and Biologics19:33 – Leadership, Judgment, and Making Risk-Based Decisions22:03 – Supplier Controls and Sponsor Responsibility24:55 – Key Takeaways: Lifecycle Risk Management and Keeping the End User Safe If you enjoyed this podcast, consider subscribing to the Let’s Talk Risk! newsletter. Suggested links: LTR: Integrating purchasing controls across product lifecycle. LTR: FDA’s New Risk Lens Under QMSR. LTR: LTR Risk Coach - AI-Powered Decision Support Tool. Key Takeaways * ISO 14971 and ICH Q9 are complementary, not competing. They examine risk through different lenses, and combination products require both perspectives. * The unit of analysis becomes the combined use system. Looking separately at a drug and device can miss risks created by their interactions with each other, the user, manufacturing processes, and the use environment. * Specifications alone do not establish safety. Particularly on the device side, user interaction and lifecycle experience can reveal hazards even when the product continues to meet specification. * Interactions can create risks that do not exist within either constituent part alone. Material compatibility, degradation, adsorption, extractables and leachables, sterilization, and biologic interactions are examples discussed in the episode. * Lifecycle changes matter. Supplier changes, process changes, labeling changes, and post-market information can alter the risk picture and require reassessment of the complete system. * The sponsor owns the complete risk picture. Suppliers may have strong risk-management processes for their particular component or constituent part, but the sponsor remains responsible for understanding the complete combination product. * Risk management is not a document. It is an ongoing lifecycle process informed by the product, constituent parts, manufacturing process, users, and post-market experience. Keywords Combination products, ISO 14971, ICH Q9, ISO 24971-3, combined use systems, lifecycle risk management, supplier controls, human factors, benefit-risk assessment, post-market risk About Susan Neadle Susan Neadle MS, BS, FRAPS, FAAO, is Principal Consultant and President of Combination Products Consulting Services LLC and an internationally recognized expert in combination products, medical devices, digital health, risk management, quality, regulatory affairs, and product and process design. She brings more than 35 years of industry experience, including a 26-year career at Johnson & Johnson and leadership experience at Amgen. Susan chairs the AAMI Combination Products Steering Committee and has held leadership roles across numerous industry working groups. She is also an educator and author of The Combination Products Handbook: A Practical Guide for Combination Products and Other Combined Use Systems. Her career has included extensive work in combination-product quality and regulatory strategy, design controls, Quality by Design, criticality analysis, risk management, and lifecycle product development. 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