In The Road to Hell is paved with Good Intentions a playground expert talks starts with a discussion about requiring helmets at all times and ties it into updated standards for playground surface and what happens in real life. Sometimes these things just don't work out like expected. On children wearing helmets:
The question arises then, what is the impact of using a safety helmet? In talking with child development physiologists they suggest several issues. First they suspect, although there is little research on this, that such protective gear may disrupt the normal progression of reflex maturation. They also are concerned that the lack of consequences when falling may retard the child’s ability to form proper assessments of their skill, i.e. reduce their judgment. Finally they speculate that it reinforces a pattern of parenting that is over protective and ultimately harmful.
There are many possible reasons for the accident rates to remain unchanged that have nothing to do with the resiliency of the landing surface. One possibility is that the recent trend to cover the entire playground with rubber is so expensive that the amount of play equipment has to be reduced significantly. This results in a lack of events, which in turn reduces the opportunities for graduated challenge that allow kids to gain skills incrementally. On the one hand little kids must use equipment that is beyond their skill level and on the other hand older kids find little to challenge them and so use the equipment in inappropriate ways.
Big news in the medical device world:
U.S. medical device maker Medtronic said on Sunday it had agreed to buy Covidien for $42.9 billion in cash and stock and move its executive base to Ireland in the latest transaction aiming for lower corporate tax rates abroad.As big as they are, these two companies don't have that much overlap in the products they sell. Medtronic focuses on cardiovascular, while Covidien does not have many products in that space. So from that perspective the deal makes sense. Although one of the main benefits seems to be a tax advantage for Medtronic, when you're paying $42 billion for a company for a tax advantage, I think it is a clear sign that the US corporate income tax is too high.
Excellent piece in the Washington Post on the FDA and sunscreen:
…American beachgoers will have to make do with sunscreens that dermatologists and cancer-research groups say are less effective and have changed little over the past decade. That’s because applications for the newer sunscreen ingredients have languished for years in the bureaucracy of the Food and Drug Administration, which must approve the products before they reach consumers.…The agency has not expanded its list of approved sunscreen ingredients since 1999. Eight ingredient applications are pending, some dating to 2003. Many of the ingredients are designed to provide broader protection from certain types of UV rays and were approved years ago in Europe, Asia, South America and elsewhere.
If you want to understand how dysfunctional regulation has become ponder this sentence:
“This is a very intractable problem. I think, if possible, we are more frustrated than the manufacturers and you all are about this situation,”
Who said it? Janet Woodcock, director of the FDA’s Center for Drug Evaluation and Research! Or how about this:
Eleven months ago, in a hearing on Capitol Hill, FDA Commissioner Margaret A. Hamburg told lawmakers that sorting out the sunscreen issue was “one of the highest priorities.”If this is high priority what happens to all the “low priority” drugs and medical devices?
Medical devices are largely designed in the United States and while the US has a decent size medical device manufacturing industry, it has been significantly moved offshore the last twenty or so years. The offshoring I've been part of hasn't worked out nearly as well as the executives planning the move has hoped with the offshore sites running into labor or quality problems that took years to work through. Two articles have recently caught my attention on companies starting to inshore production.
The NY Times published an article which covers the negatives of out sourcing and companies who have shifted manufacturing to the United States:
Time was foremost among them. The Indian mill needed too much time — three to five months — to perfect its designs, send samples, schedule production, ship the fabric to the United States and get it through customs. Mr. Winthrop was hesitant to predict demand that far in advance.
There were also communication issues. Mr. Winthrop would send the Indian factory so-called tech packs that detailed exactly what kind of fabric he wanted and what variations he would allow. But even with photos and drawings, the roll-to-roll variance was big. And he couldn’t afford to fly to India regularly, or hire someone to monitor production there.
He also found that suppliers deferred to his wishes, rather than being frank about some of his choices, which weren’t, he conceded, always good ones.These negatives match my observations and aren't easily solvable. Additionally, Atomic Delights details how Apple makes the Mac Pro in the United States:
What makes Apple fascinating is not that they are using some wiz-bang alien technologies to make things - even here in Portland, Oregon, all the technologies Apple shows in this video are in-practice across numerous local factories. What makes Apple unique is that they perform their manufacturing with remarkable precision and on a scale that is simply astonishing, using techniques typically reserved for the aerospace or medical device industries.Usually a company undergoes an expensive clean up the line activity (clarifying documentation, improving equipment, etc.) before offshoring, then still runs into the problems. I think if companies spent more of the money they spend on offshoring on improving production processes then they could be just as profitable in the US.
QMED details how one medical device company is dealing with the 2.3% tax on medical devices imposed as part of Obamacare:
To cover reduced margins, merit Medical no longer provides 401(k) matching for its employees. In addition, the company stopped donating to charities it previously supported, such as Junior Jazz and The Leonardo. That said, the company has not had to lay off any of its employees yet. In total, the company employs 1,700 people. “You take that kind of money out of a company and something has to give and it's basically research and development or marketing, and those are jobs,” notes Fred Lampropoulos, CEO of Merit Medical.
Ten months ago, I started a medical device product development project with an entrepreneur / CEO. The goal he made very clear was that before the end of 2013, he wanted to have the device on the market. The device is semi-complicated. It’s an electronic gadget driven by custom firmware. Plus, there are plastic parts and pieces, disposable components, and so on. Before kicking off the project, I had a few conversations with the CEO about project timeline. He reiterated time and again one year, one year, one year. I told him that while theoretically this schedule was possible, 18 months was more realistic–mostly because of FDA wildcard. So we talked about FDA and 510(k) process. After hearing about all of this, the CEO said he thought FDA would only take 90 days to provide clearance and that we should plan accordingly.
In early July, I submitted a 510(k) for a fairly simple and straight forward disposable, single use device. The predicate was a very good match. Of course I followed FDA guidance documents, checklists, etc. for what to put into a 510(k). I also reviewed the RTA checklist as I compiled the 510(k) documents. Of course I felt the submission was complete. Why would I send it to FDA if otherwise? A couple weeks after submitting, I received a “refuse” response from FDA. The response included the RTA checklist with reviewer comments.
In early August, the RTA response was submitted. A couple weeks later, I received a phone call from a FDA reviewer–someone different than the person who first reviewed the submission. He had a few questions, I had a few of my own. He said he would get back with me and did so the next day, this time with a few more questions. I was kind of confused at this point. Some of the things he asked about was marked as fine by the first reviewer. Other points of discussion pertained to how we addressed the issues identified by the first reviewer. Keep in mind, we discussed the specific action plan with the first reviewer who agreed with our plan. Any way, the second reviewer said he needed to discuss the issues with the branch chief and would get back with me.
which lists sacred cows in corporate
life that we should reconsider:
