Labels

Showing posts with label European IVDR. Show all posts
Showing posts with label European IVDR. Show all posts

Monday, 2 August 2021

Software

European Union: 

Software is defined as a set of instructions that processes input data and creates output data.

Software definitions per MDCG 2019-11 given,



 How to qualify the software as a medical device/in vitro diagnostic medical device software

Shall meet the definition of software according to the MDCG 2019-11 and the definition of a MD/IVD  according to Article 2(1) of MDR/IVDR

 MDR classification rules: Rules 9, 10, 11, 12, 13, 15 and 22 Annex VIII

IVDR Classification rules:To classify in vitro diagnostic medical device software all rules shall be considered.

EU Regulations References:

Is your software a Medical Device? Info graphic

MDCG 2019-11 Qualification and classification of software - Regulation (EU) 2017/745 and Regulation (EU) 2017/746

US FDA Software as Medical Device (SaMD)

“software intended to be used for more than one or more medical purposes that perform these purposes without being part of a hardware medical device.”

 How to qualify the software as a medical device/in vitro diagnostic medical device software

Meet the definition of software according Federal Food Drug & Cosmetic (FD&C) Act section 201(h) device definition.Some of the software functions are excluded from device definition.

 IMDRF Guidance documents.

Softwareas a Medical Device (SaMD): Key Definitions (IMDRF/SaMD WG/N10FINAL:2013)

Softwareas a Medical Device (SaMD): Possible Framework for Risk Categorization andCorresponding Considerations (IMDRF/SaMD WG/N12FINAL:2014)

Softwareas a Medical Device (SaMD): Application of Quality Management System (IMDRF/SaMD WG/N23 FINAL:2015)

Software as a Medical Device (SaMD): Clinical Evaluation(IMDRF/SaMD WG/N41FINAL:2017)



 

Saturday, 17 July 2021

Standards for Medical Devices

 Standards is a document, that is prepared by subject matter experts and approved by a recognized body.

This provides guidance on the design, use or performance of materials, products, processes, services, systems or persons.

International Standardisation Bodies 

European Standardisation Bodies

  • CEN: European Committee for Standardisation (www.cen.eu)
  • CENELEC: European Committee for Electrotechnical Standardisation (www.cenelec.eu)
  • ETSI: European Telecommunications Standards Institute (www.etsi.org)

International standards are developed by International Standardisation Bodies.

ISO 14971:2019 Medicaldevices — Application of risk management to medical devices. 

European standards are developed by European Standardisation Bodies.

EN 60601-1-6:2010/A2:2021 Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability

European Harmonised standards

European standard adopted on the basis of a request made by the Commission for the application of Union harmonisation legislation.

Harmonised standards are published in Official Journal of the European Union.

Devices that are in compliance with harmonized standards shall be presumed to be in conformity with the requirements of European Regulation. (Article 8)

US FDA Recognized Consensus Standards

FDA identify or recognize a standard established by a national or international standard developing bodies.Manufacturers of medical devices may submit a declaration of conformity to demonstrate they have met relevant requirements in the Federal Food, Drug, and Cosmetic Act (FD&C Act).

Guidance on Appropriate Use of Voluntary Consensus Standards in Premarket Submissions for Medical Devices: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/appropriate-use-voluntary-consensus-standards-premarket-submissions-medical-devices

US FDA Recognized Consensus Standards Database:

https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfstandards/search.cfm

 

References

REGULATION (EU) No 1025/2012

REGULATION (EU) 2017/745

REGULATION (EU) 2017/746

Standards and Conformity Assessment Program: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/appropriate-use-voluntary-consensus-standards-premarket-submissions-medical-devices


Saturday, 1 May 2021

IVDR Labels

 IVDR Annex I GSPR Section 20 of IVDR have requirements regarding the information supplied by the manufacturer.

The following section provides requirements which are applicable for Labels,

1.     20.1. General requirements regarding the information supplied by the manufacturer

2.     20.2. Information on the label

3.     20.3 Sterile packaging

IVDR brings lot of changes. As compared to IVDD, IVDR Label requirements are more detailed, some NEW requirements are incorporated.

The below table shows some of the major IVDR Label New requirements.

Label General Requirements

20.1 Information supplied by manufacturer shall be provided through manufacturer website.

20.1. The medium, format, content, legibility, and location of the label and instructions for use shall be appropriate to the particular device, its intended purpose and the technical knowledge, experience, education or training of the intended user(s).

(IVDD B.8.1 P1, Highlighted text added in IVDR)

20.1.(b) The information required on the label shall be provided on the device itself. If this is not practicable or appropriate, some or all of the information may appear on the packaging for each unit. If individual full labelling of each unit is not practicable, the information shall be set out on the packaging of multiple devices.

(IVDD B.8.1 P3, Highlighted text added in IVDR)

20.1.(c) Labels shall be provided in a human-readable format and may be supplemented by machine-readable information, such as radio-frequency identification (‘RFID’) or bar codes.

20.1.(h) Where appropriate, the information supplied by the manufacturer shall take the form of internationally recognised symbols. Any symbol or identification colour used shall conform to the harmonised standards or CS. In areas for which no harmonised standards or CS exist, the symbols and colours shall be described in the documentation supplied with the device.

(IVDD B.8.2, Highlighted text added in IVDR)

20.1.(j) The provisions of Regulation (EC) No 1907/2006 on the safety data sheet shall apply, unless all relevant information, as appropriate, is already made available in the instructions for use.

Label Content Requirements

20.2(g) The UDI carrier as referred to in Article 24 and Part C of Annex VI;

20.2(i) Where there is no indication of the date until when it may be used safely, the date of manufacture. This date of manufacture may be included as part of the lot number or serial number, provided the date is clearly identifiable;

20.2(j) Where relevant, an indication of the net quantity of contents, expressed in terms of weight or volume, numerical count, or any combination of thereof, or other terms which accurately reflect the contents of the package

20.2(n) If the instructions for use are not provided in paper form in accordance with point (f) of Section 20.1, a reference to their accessibility (or availability), and where applicable the website address where they can be consulted;

20.2(p) If the device is intended for single use, an indication of that fact. A manufacturer’s indication of single use shall be consistent across the Union;

20.2(q) If the device is intended for self-testing or near-patient testing, an indication of that fact

(IVDD B.8.4(k), Highlighted text added in IVDR)

23.2(r) Where rapid assays are not intended for self-testing or near-patient testing, the explicit exclusion hereof;

20.2(s) Where device kits include individual reagents and articles that are made available as separate devices, each of those devices shall comply with the labelling requirements contained in this Section and with the requirements of this Regulation;

20.2(u). The label for devices for self-testing shall bear the following particulars:

20.2(u)(i).The type of specimen(s) required to perform the test (e.g. blood, urine or saliva)

20.2(u)(ii).The need for additional materials for the test to function properly

20.2(u)(iii). Contact details for further advice and assistance

20.2(u). The name of devices for self-testing shall not reflect an intended purpose other than that specified by the manufacturer

20.3. Information on the packaging which maintains the sterile condition of a device (‘sterile packaging’)

20.3 The following particulars shall appear on the sterile packaging:

(a) an indication permitting the sterile packaging to be recognized as such,

(b) A declaration that the device is in a sterile condition

(c) The method of sterilisation,

(d) The name and address of the manufacturer,

(e) a description of the device,

(h) the month and year of manufacture,           

(h) an instruction to check the instructions for use for what to do if the sterile packaging is damaged or unintentionally opened before use.

 Click below link to know more about MDR Label requirements :https://meddev-info.blogspot.com/2021/05/mdr-label.html

References:

REGULATION (EU) 2017/746 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 5 April 2017 on in vitro diagnostic medical devices and repealing Directive 98/79/EC and Commission Decision 2010/227/EU 

 

MDR Labels

MDR Annex I GSPR Section 23 of MDR have requirements regarding the information supplied by the manufacturer.

The following section provides requirements which are applicable for Labels,

1.     23.1. General requirements regarding the information supplied by the manufacturer

2.     23.2. Information on the labels

3.     23.3 Sterile packaging

MDR brings lot of changes. As compared to MDD, MDR Label requirements are more detailed, some NEW requirements are incorporated.

·       Per Article 18 MDR all implantable devices (Except WET) shall have patient information document and implant card label.

The below table shows some of the major MDR Label New requirements.

Label General Requirements

23.1 Information supplied by manufacturer shall be provided through manufacturer website.

23.1.(a) The medium, format, content, legibility, and location of the label and instructions for use shall be appropriate to the particular device, its intended purpose and the technical knowledge, experience, education or training of the intended user(s).

23.1.(b) The information required on the label shall be provided on the device itself. If this is not practicable or appropriate, some or all of the information may appear on the packaging for each unit, and/or on the packaging of multiple devices.

(MDD 13.1, Highlighted text added in MDR)

23.1.(c) Labels shall be provided in a human-readable format and may be supplemented by machine-readable information, such as radio-frequency identification (‘RFID’) or bar codes.

23.1.(h) Where appropriate, the information supplied by the manufacturer shall take the form of internationally recognised symbols. Any symbol or identification colour used shall conform to the harmonised standards or CS. In areas for which no harmonised standards or CS exist, the symbols and colours shall be described in the documentation supplied with the device.

(MDD 13.2, Highlighted text added in MDR)

Label Content Requirements

23.2(a) The name or trade name of the device.

23.2(c) The name, registered trade name or registered trade mark of the manufacturer and the address of its registered place of business.

(MDD 13.3(a), Highlighted text added in MDR)

23.2(e) Where applicable, an indication that the device contains or incorporates tissues or cells, or their derivatives, of human origin, or

23.2(e) Where applicable, an indication that the device contains or incorporates tissues or cells of animal origin, or their derivatives, as referred to in Regulation (EU) No 722/2012.

23.2(f) Where applicable, information labelled in accordance with section 10.4.5 (presence of CMRs and Endocrine disrupting substances.

(MDD only have phthalate)

23.2(g) the lot number or the serial number of the device preceded by the words LOT NUMBER or SERIAL NUMBER or an equivalent symbol, as appropriate;

(MDD 13.3(d), Highlighted text added in MDR)

23.2(h) the UDI carrier referred to in Article 27(4) and Part C of Annex VI;

23.2(j) where there is no indication of the date until when it may be used safely, the date of manufacture. This date of manufacture may be included as part of the lot number or serial number, provided the date is clearly identifiable;

23.2(m) Warnings or precautions to be taken that need to be brought to the immediate attention of the user of the device, and to any other person. This information may be kept to a minimum in which case more detailed information shall appear in the instructions for use, taking into account the intended users.

(MDD 13.3(k), Highlighted text added in MDR)

23.2(o) If the device is a single use device that has been reprocessed, an indication of that fact, the number of reprocessing cycles already performed, and any limitation as regards the number of reprocessing cycles.

23.2(q1) An indication that the device is a medical device.

23.2 (r) in the case of devices that are composed of substances or of combinations of substances that are intended to be introduced into the human body via a body orifice or applied to the skin and that are absorbed by or locally dispersed in the human body, the overall qualitative composition of the device and quantitative information on the main constituent or constituents responsible for achieving the principal intended action;

23.2 (s) for active implantable devices the serial number and for other implantable devices the serial number or the batch number.

23.3. Information on the packaging which maintains the sterile condition of a device (‘sterile packaging’)

(a) an indication permitting the sterile packaging to be recognized as such,

(e) a description of the device,

(h) the month and year of manufacture,           

(j) an instruction to check the instructions for use for what to do if the sterile packaging is damaged or unintentionally opened before use.

Article 18 Implant card and information to be supplied to the patient with an implanted device

(aa) Information to be supplied to the patient with an implanted device in accordance to Article 18

1. The manufacturer of an implantable device shall provide together with the device the following:

(a) information allowing the identification of the device, including the device name, serial number, lot number, the UDI, the device model, as well as the name, address and the website of the manufacturer;

(b) any warnings, precautions or measures to be taken by the patient or a healthcare professional with regard to reciprocal interference with reasonably foreseeable external influences, medical examinations or environmental conditions;

(c) any information about the expected lifetime of the device and any necessary follow-up;

(d) any other information to ensure safe use of the device by the patient, including the information in point (u) of Section 23.4 of Annex I

Click below link to know more about IVDR Label requirements :https://meddev-info.blogspot.com/2021/05/ivdr-labels.html

Source:

REGULATION (EU) 2017/745 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 5 April 2017 on medical devices, amending Directive 2001/83/EC, Regulation (EC) No 178/2002 and Regulation (EC) No 1223/2009 and repealing Council Directives 90/385/EEC and 93/42/EEC

 

Sunday, 25 April 2021

IVDR Instruction for Use (IFU)

 IVDR Annex I GSPR Section 2o of IVDR have requirements regarding the information supplied by the manufacturer.

The following section provides requirements which are applicable for instruction for use,

1.     20.1. General requirements regarding the information supplied by the manufacturer

2.     20.4. Information in the instructions for use

IVDR brings lot of changes. As compared to IVDD, IVDR IFU requirements are more detailed, some NEW requirements are incorporated.

The below table shows some of major MDR IFU New requirements.

IFU General Requirements

20.1 IFUs shall be provided through manufacturer website.

20.1.(a) The medium, format, content, legibility, and location of the label and instructions for use shall be appropriate to the particular device, its intended purpose and the technical knowledge, experience, education or training of the intended user(s). In particular, instructions for use shall be written in terms readily understood by the intended user and, where appropriate, supplemented with drawings and diagrams.

20.1.(e) Where multiple devices, with the exception of devices intended for self-testing or near-patient testing, are supplied to a single user and/or location, a single copy of the instructions for use may be provided if so agreed by the purchaser who in any case may request further copies to be provided free of charge.

20.1.(f) When the device is intended for professional use only,instructions for use may be provided to the user in non-paper format (e.g. electronic), except when the device is intended for near-patient testing.

20.1(g) Residual risks which are required to be communicated to the user and/or other person shall be included as limitations, contra-indications, precautions or warnings in the information supplied by the manufacturer.

20.1(i) Apply hazard pictograms and labelling requirements of Regulation (EC) No 1272/2008.These information shall be given in IFU when there is insufficient space to put all the information on the device itself or on its label.

23.1.(j) The provisions of Regulation (EC) No 1907/2006 on the safety data sheet shall apply, unless all relevant information, as appropriate, is already made available in the instructions for use.

IFU Content Requirements

20.4.1(c)(i) What is detected and/or measured

20.4.1(c)(ii) function (e.g. screening, monitoring, diagnosis or aid to diagnosis, prognosis,  prediction, companion diagnostic)

20.4.1(c)(iii) The specific information that is intended to be provided in the context of:

—a physiological or pathological state;

—congenital physical or mental impairments;

—the predisposition to a medical condition or a disease;

—the determination of the safety and compatibility with potential recipients;

—the prediction of treatment response or reactions;

—the definition or monitoring of therapeutic measures;

20.4.1(c)(iv) automated or not

20.4.1(c)(v) qualitative, semi-quantitative or quantitative

20.4.1(c)(vii) testing population

20.4.1(c)(viii) For companion diagnostics, the International Nonproprietary Name (INN) of the associated medicinal product for which it is a companion test

20.4.1(e) The intended user, as appropriate (e.g. self-testing,near patient and laboratory professional use,healthcare professionals)

20.4.1(g) Description of the calibrators and controls and any limitation upon their use (e.g. suitable for a dedicated instrument only)

20.4.1(h) Description of the reagents and any limitation upon their use

20.4.1(i) List of materials provided and a list of special materials required but not provided

20.4.1(j) combinations of devices and equipment

·  validated and safe combination, including key performance characteristics, and/or
·   known restrictions to combinations of devices and equipment

20.4.1(m) Sterile devices

·       an indication of its sterile state

·       sterilisation method

·       instructions in the event of the sterile packaging being damaged before use

20.4.1(n)(i) Warnings, precautions and/or measures to be taken in the event of malfunction of the device or its degradation as suggested by changes in its appearance that may affect performance,

20.4.1(n)(ii) Warnings, precautions and/or measures to be taken as regards the exposure to reasonably foreseeable external influences or environmental conditions,such as magnetic fields, external electrical and electromagnetic effects, electrostatic discharge, radiation associated with diagnostic or therapeutic procedures, pressure, humidity, or temperature.(IVDD 8.7(r) ,Highligted text added in IVDR)

20.4.1(n)(iii) Warnings, precautions and/or measures to be taken as regards the risks of interference posed by the reasonably foreseeable presence of the device during specific diagnostic investigations, evaluations, therapeutic treatment or other procedures such as electromagnetic interference emitted by the device affecting other equipment

20.4.1(n)(iv) Precautions related to materials incorporated into the device that contain or consist of CMR substances, or endocrine disrupting substances or that could result in sensitisation or an allergic reaction by the patient or user

20.4.1(n)(v) Single use devices

If the device is intended for single use, an indication of that fact. A manufacturer’s indication of single use shall be consistent across the Union

20.4.1(n)(vi) Reusable devices

·       If the device is reusable, information on the appropriate processes to allow reuse, including cleaning, disinfection, decontamination, packaging and, where appropriate, the validated method of resterilisation

·       Information shall be provided to identify when the device should no longer be reused, such as signs of material degradation or the maximum number of allowable reuses

(IVDD 8.7(q) ,Highligted text added in IVDR)

20.4.1(o) warnings and/or precautions related to potentially infectious material that is included in the device

20.4.1(p) Requirements for special facilities, such as a clean room environment.

special training, such as on radiation safety, or particular qualifications of the intended user

20.4.1(r) Details of any preparatory treatment or handling of the device before it is ready for use, such as sterilisation,final assembly, calibration, etc., for the device to be used as intended by the manufacturer;(IVDD 8.7(o) ,Highligted text added in IVDR)

20.4.1(s) The information needed to verify whether the device is properly installed and is ready to perform safely and as intended by the manufacturer, together with, where relevant:/

—details of the nature, and frequency, of preventive and regular maintenance, including cleaning and disinfection;

identification of any consumable components and how to replace them;

—information on any necessary calibration to ensure that the device operates properly and safely during its intended lifetime;

methods for mitigating the risks encountered by persons involved in installing, calibrating or servicing devices.

(IVDD 8.7(n) ,Highligted text added in IVDR)

20.4.1(u) The metrological traceability of values assigned to calibrators and control materials, including identification of applied reference materials and/or reference measurement procedures of higher order and information regarding maximum (self-allowed) batch to batch variation provided with relevant figures and units of measure;(IVDD 8.7(k)Point 2 ,Highligted text added in IVDR)

20.4.1(v) Assay procedure including calculations and interpretation of results and where relevant if any confirmatory testing shall be considered;where applicable, the instructions for use shall be accompanied by information regarding batch to batch variation provided with relevant figures and units of measure;(IVDD 8.7(g) ,Highligted text added in IVDR)

20.4.1(w) Analytical performance characteristics, such as analytical sensitivity, analytical specificity, trueness (bias), precision (repeatability and reproducibility),accuracy (resulting from trueness and precision),limits of detection and measurement range,(information needed for the control of known relevant interferences, cross-reactions and limitations of the method), measuring range, linearity and information about the use of available reference measurement procedures and materials by the user;(IVDD 8.7(h)Point 2 ,Highligted text added in IVDR)

20.4.1(x) Clinical performance characteristics as defined in Section 9.1 of this Annex(IVDD 8.7(d),Highligted text added in IVDR)

20.4.1(z) Where relevant, clinical performance characteristics, such as threshold value, diagnostic sensitivity and diagnostic specificity, positive and negative predictive value

20.4.1(ab) Information on interfering substances or limitations (e.g. visual evidence of hyperlipidaemia or haemolysis,age of specimen) that may affect the performance of the device

20.4.1(ac) Warnings or precautions to be taken in order to facilitate the safe disposal of the device, its accessories,and the consumables used with it, if any. This information shall cover, where appropriate:(IVDD 8.7(s),Highligted text added in IVDR)

20.4.1(ac)(i) Infection or microbial hazards, such as consumables contaminated with potentially infectious substances of human origin

20.4.1(ac)(ii) Environmental hazards such as batteries or materials that emit potentially hazardous levels of radiation)

20.4.1(ac)(iii) Physical hazards such as explosion

20.4.1(ad) The name, registered trade name or registered trade mark of the manufacturer and the address of its registered place of business at which he can be contacted and its location be established, together with a telephone number and/or fax number and/or website address to obtain technical assistance(Detailed in IVDR)

20.4.1(ae) Date of issue of the instructions for use or, if they have been revised, date of issue and identifier of the latest revision of the instructions for use, with a clear indication of the introduced modifications(IVDD 8.7(u),Highligted text added in IVDR)

20.4.1(af) A notice to the user that any serious incident that has occurred in relation to the device shall be reported to the manufacturer and the competent authority of the Member State in which the user and/or the patient is established

20.4.1(ag) Where device kits include individual reagents and articles that may be made available as separate devices, each of these devices shall comply with the instructions for use requirements contained in this Section and with the requirements of this Regulation

20.4.1(ah) For devices that incorporate electronic programmable systems, including software, or software that are devices in themselves, minimum requirements concerning hardware, IT networks characteristics and IT security measures, including protection against unauthorised access, necessary to run the software as intended.

20.4.1(ah) Self-testing

20.4.2(a) Details of the test procedure shall be given, including any reagent preparation, specimen collection and/or preparation and information on how to run the test and interpret the results

20.4.2(c) The device’s intended purpose shall provide sufficient information to enable the user to understand the  medical context and to allow the intended user to make a correct interpretation of the results;

20.4.2(e) Information shall be provided with advice to the user on action to be taken (in case of positive, negative or indeterminate result), on the test limitations and on the possibility of false positive or false negative result.

Information shall also be provided as to any factors that can affect the test result such as age, gender,menstruation, infection, exercise, fasting, diet or medication(IVDD 8.7(t) Point 1,Highligted text added in IVDR)

20.4.2(f) The information provided shall include a statement clearly directing that the user should not take any decision of medical relevance without first consulting the appropriate healthcare professional, information on disease effects and prevalence, and, where available, information specific to the Member State(s) where the device is placed on the market on where a user can obtain further advice such as national helplines, websites(IVDD 8.7(t) Point 3,Highligted text added in IVDR)

 

Click below link to know more about MDR IFU requirements :https://meddev-info.blogspot.com/2021/01/mdr-instruction-fo-use-ifu-requirements.html

References:

REGULATION (EU) 2017/746 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 5 April 2017 on in vitro diagnostic medical devices and repealing Directive 98/79/EC and Commission Decision 2010/227/EU 

ROBYN MEURANT .EXPLORING THE RELATIONSHIP BETWEEN THE IVDR AND THE IVDD General Safety and Performance Requirements Versus Essential Requirements) [White paper]. NSF nternational.  https://d2evkimvhatqav.cloudfront.net/documents/md_wp_ivdr.pdf?mtime=20200716160253&focal=nones