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Let's Talk Risk! with Dr. Naveen Agarwal

Every Friday, Dr. Naveen Agarwal leads a Let's Talk Risk! conversation with industry colleagues to discuss practical challenges and share best practices in risk management.

Publication · By Casual and informal conversations about practical aspects of medical device risk management. · English · Official site

Indexed pieces, last 90 days
26
Latest publication
Sep 29, 2026
Audience
By platform
Earliest in this view
Jul 10, 2026

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api.substack.comnaveenagarwalphd.substack.com

Latest pieces

  1. Issue · Sep 29, 2026

    QMSR QuickTake #44: A Device Can Be “Finished” Before It Is Final (opens the original)

    Excerpt · Neutral tone

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    In responding to Comment #33 in the preamble of the QMSR1, FDA addresses an important boundary question: when is something a component, and when has it become a finished device?That distinction matters because QMSR generally applies directly to manufacturers of finished devices, while manufacturers that only produce components or parts are generally not directly subject to QMSR.<a class="image-link image2 is-viewable-img" href="https://substackcdn.com/image/fetch/$s_!Hl8y!,f_auto,q_auto:good,fl_

  2. Issue · Sep 28, 2026

    TAI #44: The Supplier Risk Traceability Gap (opens the original)

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    <img alt="" class="sizing-normal" height="630" src="https://substackcdn.com/image/fetch/$s_!1MNj!,w_1456,c_limit,f_auto,q_auto:good,fl_progressive:steep/https%3A%2F%2Fsubstack-post-media.s3.amazonaws.com%2Fpublic%2Fimages%2Fb91a314c-cf96-4fb1-98e8-edc2ffdf28ee_1200x630.png"

  3. Issue · Sep 25, 2026

    Deep Dive: When the Risk Baseline and the QMS Both Break Down (opens the original)

    Excerpt · Critical tone

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    The baseline is completely broken and the iteration process is blind.FDA’s August 21, 2026 warning letter to Pensar Medical LLC illustrates a failure that goes well beyond incomplete documentation.The underlying risk-management foundation was weak. Risk-control verification remained incomplete for critical areas, and FDA reportedly found no design, process, or use-related FMEAs for the WoundPro product line.At the same time, key QMS processes were also failing.Key highlights covered in the audio

  4. Issue · Sep 22, 2026

    QMSR QuickTake #43: QMS Risk Is Broader Than ISO 14971 (opens the original)

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    In responding to Comment #32 in the preamble of the QMSR1, FDA pointed manufacturers back to ISO 13485 Clause 0.2 within the standard. The term risk relates to device safety, device performance, and meeting applicable regulatory requirements.<a class="image-link image2 is-viewable-img" href="https://substackcdn.com/image/fetch/$s_!t9bO!,f_auto,q_auto:good,fl_progressive:steep/https%3A%2F%2Fsubstack-post-media.s3.amazonaws.com%2Fpublic%2Fimages%2Fe682122e-d973-416f-ac64-2bbcd41d0097_1080x1350.pn

  5. Issue · Sep 21, 2026

    TAI #43: How Traceable Are Safety-Related Characteristics in Your Risk File? (opens the original)

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    <img alt="" class="sizing-normal" height="630" src="https://substackcdn.com/image/fetch/$s_!S3Pr!,w_1456,c_limit,f_auto,q_auto:good,fl_progressive:steep/https%3A%2F%2Fsubstack-post-media.s3.amazonaws.com%2Fpublic%2Fimages%2F17a705dc-1c54-474a-b737-9289ea8034db_1200x630.png"

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