Published June 8, 2026 | Version v2

Proactive Risk Management as the Integrating Backbone of Combination Product Development

  • 1. PTM Consulting Srl
  • 2. Velferd Srl

Description

Combination Products (CPs) are becoming increasingly important within the pharmaceutical industry due to their potential to improve patient compliance, reduce use-related errors and enhance therapeutic effectiveness. However, integrating a medicinal product and a medical device into a single therapeutic system introduces significant technical, organizational and regulatory complexity.

This white paper presents a practical methodological framework for managing Combination Product development through iterative and proactive risk management. The proposed approach integrates pharmaceutical development, device engineering, usability engineering and regulatory expectations within a single risk-based decision-making framework.

Using the example of a pen injector system combined with a drug solution cartridge, the paper illustrates how task analysis, usability engineering, design controls and risk management can interact dynamically throughout the development lifecycle. Particular attention is given to the role of risk management in guiding design inputs, verification and validation activities, human factors studies and residual risk evaluation.

The paper ultimately positions risk management not merely as a compliance activity, but as the integrating backbone enabling consistent, efficient and robust Combination Product development.

Files

MLWP_002_Proactive_risk_management.pdf

Files (418.1 kB)

Name Size Download all
md5:3daa373f7b8dd4c1286f22e9713ea0f8
418.1 kB Preview Download

Additional details

Dates

Accepted
2026-05

References

  • International Organization for Standardization. ISO 14971:2019. Medical devices — Application of risk management to medical devices. Geneva: ISO; 2019.
  • International Organization for Standardization. IEC 62366-1:2015+A1:2020. Medical devices — Part 1: Application of usability engineering to medical devices. Geneva: ISO/IEC; 2020.
  • International Organization for Standardization. ISO 11608-1:2022. Needle-based injection systems for medical use — Requirements and test methods — Part 1: Needle-based injection systems. Geneva: ISO; 2022.
  • European Parliament and Council of the European Union. Regulation (EU) 2017/745 on medical devices. Official Journal of the European Union; 2017.
  • U.S. Food and Drug Administration. 21 CFR Part 3.2(e). Definition of combination product. Code of Federal Regulations.
  • International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use. ICH Q8(R2), Pharmaceutical Development. Geneva: ICH.
  • U.S. Food and Drug Administration. Applying Human Factors and Usability Engineering to Medical Devices. Guidance for Industry and Food and Drug Administration Staff. FDA; 2016.
  • U.S. Food and Drug Administration. Design Control Guidance for Medical Device Manufacturers. FDA; 1997.