European Regulations of Medical Devices and In-vitro Diagnostic Medical Devices. The Notified Body Point of View

Similar documents
Table of Contents for the REGULATION (EU) 2017/745 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 5 April 2017

Reporting Changes to your Notified Body

Want to know more about the Notified Body? Everything you need to know to help you through the Notified Body process and on to accreditation.

Valve Manufacturers Association of America

BUSINESS PLAN CEN-CLC/TC 3 QUALITY MANAGEMENT AND CORRESPONDING GENERAL ASPECTS FOR MEDICAL DEVICES EXECUTIVE SUMMARY

New Requirements for Placing of Medical Devices on the Market: Conformity Assessment to the Technical Regulations

CO-ORDINATION OF NOTIFIED BODIES PPE Regulation 2016/425 RECOMMENDATION FOR USE

Frequently Asked Questions on the Construction Products Regulation (CPR) - Enterprise and Industry

Guidance from the Group of Notified Bodies for the Construction Products Regulation 305/2011/EU

CE MARKING PROCESS & NOTIFIED BODIES

The PPE Directive and the PPE Regulation

The New EU-Regulation on Construction Products

BUSINESS PLAN CEN/TC 79 RESPIRATORY PROTECTIVE DEVICES EXECUTIVE SUMMARY

Achieve Success with European Medical Device Commercialization. By Russ King

Notification of a Body in the framework of a technical harmonization directive

The transition requirements of the new Regulation (EU) 2016/425 of the European Parliament and of the Council on personal protective equipment

The New EMC Directive 2004/108/EC

Guidelines for designating and monitoring notified bodies in Norway

The New EMC Directive 2004/108/EC

EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY

EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY

The Machinery Directive 2006/42/EC

Regulation (EC) 1272/2008 on Classification, labelling and packaging. (CLP Regulation) DG Environment

New Legal Framework Carlo Casati

COMMISSION IMPLEMENTING REGULATION (EU) /... of XXX. on the European Rail Traffic Management System European deployment plan

Assessment Report Construction Product Regulation* * CPR - REGULATION (EU) No 305/2011

Declaration of Conformity Declaration of Performance Notes

1. Terms defined in the Construction Products Regulation (CPR)

EUROPEAN UNION. Brussels, 13 February 2014 (OR. en) 2011/0357 (COD) PE-CONS 54/13 ENT 190 MI 550 CONSOM 128 COMPET 470 CODEC 1481

(recast) (Text with EEA relevance) out the conformity assessment procedure. Conformity 20 February 2014.

REGULATION FOR THE CE CERTIFICATION ACCORDING TO THE MEDICAL DEVICES DIRECTIVE

Regulation (EU) No 305/2011 laying down harmonised conditions for the marketing of construction products (EU CPR)

Market Surveillance in Luxembourg

COMMISSION DELEGATED REGULATION (EU) /... of

Council Directive 93/68/EEC of 22 July 1993 amending Directives

(1135/2016) Translation from Finnish Legally binding only in Finnish and Swedish Ministry of Economic Affairs and Employment, Finland

DRAFT COMMISSION DELEGATED REGULATION (EU) / of XXX

Regulation 574_2014: Annex III CPR. and. Regulation 568_2014: Annex V CPR

Record of Amendments. Version Date Amendment Section/page affected

FAQs Radio Equipment Directive (RE-D)

The New PPE Regulation (EU) 2016/425

BUSINESS PLAN CEN/TC 239 RESCUE SYSTEMS EXECUTIVE SUMMARY

RULEBOOK ON ELECTROMAGNETIC COMPATIBILITY

Implementation of the Construction Products Regulation (CPR) in harmonized standards - Template for Annex ZA -

Chief Operating Officer Giampiero Belcredi

COMMISSION IMPLEMENTING REGULATION (EU) /... of XXX

EIA and other forms of assessment - EIA and SEA, habitat assessment, Water Framework Directive, IED and waste management

Pressure Equipment Directive PED 2014/68/EU Commission's Working Group "Pressure"

The new Gas Appliances Regulation (EU) 2016/426

CEN standardization work on refrigerating systems, especially standard EN 378

Business Quality Assurance International Ltd

DIRECTIVE 2014/34/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

BUSINESS PLAN CEN/TC 305 POTENTIALLY EXPLOSIVE ATMOSPHERES EXPLOSION PREVENTION AND PROTECTION EXECUTIVE SUMMARY

Implementing the Construction Products Regulation (EU) 305/2011

GASTEC QA. Evaluation Guideline KE 191. Amendment A1 Excess flow valves. KE A1 March 2012

This follows similar work previously conducted by Bureau Veritas for Nestlé S.A. in other global operations.

Certificate of Registration

Guidance on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) Regulations 2012

Implementation of the Construction Products Regulation (CPR) in harmonized standards - Template for Annex ZA -

JBCE input for the RoHS FAQ document

EN ISO ÖNORM. Edition: (ISO 14937:2009)

REDCA update on the RED. Days to go. 17 May 2017

SAR Technical Requirement

1. Which national directives/laws control the placing on the market of equipment for explosive atmospheres?

BUSINESS PLAN CEN/TC 160 PROTECTION AGAINST FALLS FROM A HEIGHT INCLUDING WORKING BELTS EXECUTIVE SUMMARY

Record of Amendments. Version Date Amendment Section/page affected

COMMISSION DELEGATED REGULATION (EU) /... of XXX

OFFICIAL JOURNAL OF IN VITRO DIAGNOSTIC MEDICAL DEVICES DIRECTIVE (98/79/EC)

ATEX/05/1/7. In detail:

Ref. Ares(2016) /12/2016 NATIONAL MARKET SURVEILLANCE PROGRAMME Luxembourg

CERTIFICATE. Conformity of the Factory Production Control CPR TÜVRh

European Technical Approval ETA-08/0035 This ETA replaces ETA-08/0035 with validity from till

EC Certificate - Full Quality Assurance System Directive 93/42/EEC on Medical Devices, Annex II excluding Section 4

7.3 Design and Development Design and development planning Design and development inputs Design and development outputs 7.3.

CE marking of fire-resistant doors the right way!

Living with the Construction Products Directive - The Role of the Notified Bodies

ROLA CENTRUM NAUKOWEGO POśARNICTWA W LITEWSKIM SYSTEMIE OCHRONY PRZECIWPOśAROWEJ

COMPILATION OF COMMUNITY PROCEDURES ON INSPECTIONS AND EXCHANGE OF INFORMATION

GASTEC QA. Approval Requirements 31-2

On , CCMC received a proposal from DIN for the creation of a new Technical Committee in the area of Food Authenticity (see Annex 1).

ISO 9001:2015 TRANSITIONS

PART 3-O REQUIREMENTS FOR SPRINKLER SYSTEMS MAINTENANCE AND SUPERVISION. 3-O Introduction O.1 Scope of Maintenance and Supervision...

EUROPEAN COMMITTEE FOR ELECTROTECHNICAL STANDARDIZATION (CENELEC) TECHNICAL COMMITTEE No. 62: ELECTRICALEQUIPMENT IN MEDICAL PRACTICE

BUSINESS PLAN CEN/TC 10 LIFTS, ESCALATORS AND MOVING WALKS EXECUTIVE SUMMARY

GASTEC QA. Approval Requirements 31-1

ENTSO-E response to GB compliance understanding

9 Standards, Regulations and Authorities

An overview of sterilizer equipment standards current and planned. Richard Bancroft Science & Technical Director STERIS

Changes in international standards relating to diagnostic x-ray equipment, with particular attention to radiation protection

GUIDANCE DOCUMENT ON THE ATEX DIRECTIVE TRANSITION FROM 94/9/EC TO 2014/34/EU

GASTEC QA. Evaluation Guideline KE 192. Amendment A1 Rubber materials for seals and diaphragms for gas appliances and gas equipment

SUPPLEMENTARY REGULATIONS SPECIFIC TO CERTIFICATION OF PERSONAL PROTECTIVE EQUIPMENT (PPE)

BUSINESS PLAN. CEN/TC 336 BITUMINOUS BINDERS Version 2018 EXECUTIVE SUMMARY

Technical Bulletin CE marking: from 1st July 2013

Electrical equipment designed for use within certain voltage limits (LVD GUIDE)

RADAR REFLECTOR STANDARD FOR CERTIFICATION. DET NORSKE VERITAS Veritasveien 1, N-1322 Høvik, Norway Tel.: Fax:

BUSINESS PLAN CEN/TC 49 GAS COOKING APPLIANCES EXECUTIVE SUMMARY

Guideline Construction Products Regulation (EU) 305/20122

Product Safety Reporting Requirements in the European Union

LOW VOLTAGE DIRECTIVE 2014/35/EU GUIDELINES. Electrical equipment designed for use within certain voltage limits

Transcription:

European Regulations of Medical Devices and In-vitro Diagnostic Medical Devices The Notified Body Point of View Dr.-Ing. Christian Zietsch Berlin 2018-06-20

Preliminary notes All information given, are given with reservations! At the moment the future is not 100% clear. The basic concept is fixed, but the detailed implementation is partly unknown (e.g. Common Specifications). mdc medical device certification GmbH Folie 2

Table of Content Introduction (short) Challenges for the Notified Bodies and Economic Operators Important Transition Provisions MDR Consequences from the Transition Provisions IVDR - Timelines Notified Bodies: New Tasks and Functions Examples Audits Recommendations Conclusions mdc medical device certification GmbH Folie 3

Introduction As EU-Regulations the Regulation on Medical Devices and the Regulation on In Vitro Diagnostic Medical Devices are directly applicable without transformation into national laws! The regulations have been already entered set in force, but the date of application is later and there are various transition periods. Some parts may be already used before the day of application. National medical device laws must be completely revised and adapted (no contradictions to regulations). mdc medical device certification GmbH Folie 4

Introduction Motto: Go back to START New notifications of the Notified Bodies New certifications of the manufacturers New registrations of the products There is no grandfathering! mdc medical device certification GmbH Folie 5

Challenges for the Notified Bodies & Economic Operators Complete notification is required, for both MDR and IVDR (new requirements are much higher compared to notifications under MDD / IVDD) Expected duration at least 1 year after 26.11.2017 (earliest date of application for notification under MDR/IVDR) Notified Bodies will be notified earliest end of 2018 / beginning of 2019 and then capable of acting It can not be predicted how many NB will be notified and with which scopes The authority responsible for notified bodies will review an appropriate number of NB assessments of manufacturers technical documentation (as part of its ongoing monitoring of NB) mdc medical device certification GmbH Folie 6

Challenges for the Notified Bodies & Economic Operators Systems old and new must exist in parallel at the NB and manufactures Work load of NB per manufacturer will increase considerably (app. factor 2 to 3) During the very limited transition periods a high quantity of recertifications according to the Directives as well as initial certifications according to the Regulations will be demanded Although the personnel resources of the NB have been expanded extreme capacity shortages are expected mdc medical device certification GmbH Folie 7

Important Transition Provisions (MDR - Article 120 + 123) 05.05.2017 25.05.2017 26.11.2017 26.05.2020 Publication Entry into force Start of application period for Notified Bodies Date of application Expiry of notifications under Directive 93/42/EEC End of issuing certificates according to Directive 93/42/EEC For all devices without a certificate according to Directive 93/42/EEC, for all new devices and for all old devices with modified design / intended use the MDR is mandatory mdc medical device certification GmbH Folie 8

Important Transition Provisions (MDR - Article 120 + 123) 26.05.2024 26.05.2025 Last expiry date for certificates and last date for placing products on the market under Directive 93/42/EEC End of distribution and putting into service of products placed on the market under Directive 93/42/EEC Short: three years transition period (2017 2020) mdc medical device certification GmbH Folie 9

Consequences from the Transition Provisions All products, which are covered by a certificate (!) under Directive 93/42/EEC and the design and intended use remains without changes, may be placed on the market until 26 May 2024. For class I products (non-sterile, no measuring function) this is not the case. They have to fulfil the MDR by 26 May 2020. In order to receive a certificate according to Directive 93/42/EEC valid until 26 May 2024, the initial or renewal certification needs to be fully completed and issued between 26 May 2019 and 26 May 2020. Due to the capacities at the Notified Bodies there will be deadlines regarding inquiries (duly filled questionnaires including all attachments), applications and complete documents (quality documents and technical documentation). mdc medical device certification GmbH Folie 10

IVDR - Timelines Regulation on IVD, 2017/746 coming in force: 2017-05-25 Applications for Notified Bodies possible from 2017-11-26 Assessment of applications (expected: 1...2 years) Notification to Commission??, Start of conformity assessments acc. Regulation 2017/746 Mandatory application of Regulation 2017/746: 2022-05- 26 (Exceptions see articles 110, 113) EC-Certificates acc. 98/79/EC become void: 2024-05-27 2017 2018 2019 2020 2021 2022 Short: five years transition period (2017 2022) mdc medical device certification Folie 11

Notified Bodies: New Tasks and Functions The Essential Requirements acc. MDD/IVDD are widely expanded to General Safety and Performance Requirements acc. MDR, IVDR Much higher Requirements for Technical Documentations (e.g. MDR Annex II, III) Much higher Requirements for Clinical Evaluation and Post Market Clinical Follow-up etc. (MEDDEV 2.7/1 Rev. 4, MDR Annex XIV) and New Consultation Procedures for class III and certain active class IIb devices Numerous additional reports that need to be updated on a regularly basis e.g. PMCF, PMS, PSUR (periodic safety update report), Summary of safety and clinical performance, Trend reporting Reclassifications (higher risk class) of certain Medical Devices and IVD mdc medical device certification GmbH Folie 12

New Consultation Procedures New Consultation Procedures for implantable class III devices and active class IIb devices, which administer or remove pharm. products The NB issues a Clinical Assessment Evaluation Report (CAER) on the clinical evaluation and sends it together with the clinical evaluation to the European Commission. The report and the documents are forwarded to an experts committee. The expert committee will decide within 21 days whether or not an expert report regarding the CAER is drawn up. If yes, the expert report is issued within 60 days. The Notified Body takes the expert report into consideration for the decision (In case after 60 days no feedback is available, the Notified Body can continue the conformity assessment.) mdc medical device certification GmbH Folie 13

Notified Bodies: New Tasks and Functions For class I reusable surgical instruments (Ir) the following aspects of reprocessing need to be checked by the Notified Body: cleaning disinfection sterilisation maintenance functional testing instructions for use The assessment will be performed within a certification of the quality system but will also require parts of the technical documentation. mdc medical device certification GmbH Folie 14

Notified Bodies: New Tasks and Functions Common Specifications (CS) will be developed under the MDR/IVDR and published as EU Commission Decisions The Common Specifications can include technical requirements, documentation needs regarding technical documentation, clinical evaluation, performance evaluation and post market surveillance as well as PMCF requirements Common Specifications have a higher status than harmonized standards and are practically mandatory mdc medical device certification GmbH Folie 15

Notified Bodies: New Tasks and Functions Approx. 80 90% of other IVD (acc. IVDD) will require Notified Body activity and need certification acc. to IVDR New Economic Operators Importers and distributors, which re-pack or re-label products have to fulfil defined requirements including the obligation for certification by a Notified Body EUDAMED and UDI mdc medical device certification GmbH Folie 16

Economic Operators Manufacturer Control Information Control Importer Distributor Information Control Information Information Information Authorised Representative Broad tasks and cooperation: Traceability UDI Product registration Complaints Adverse events Corrective actions mdc medical device certification GmbH Folie 17

EUDAMED Modular European Database mdc medical device certification GmbH Folie 18 Lübeck Summer Academy on Medical Technology; July 4, 2017, Dr. Almut Fröhlich, Federal Ministry of Health

Audits The first audit according to MDR / IVDR will be an very comprehensive initial audit. The basis so far used for audit time calculation may not be sufficient for the future. Surveillance audits according to MDR / IVDR may even in small companies not possible within one day. Surveillance audits have to be performed at least every 12 months. Suppliers / subcontractors will be more involved in audits. More focus will be taken on PMS, PMCF, Vigilance. mdc medical device certification GmbH Folie 19

Recommendations Due to extensive assessments of technical documentations etc. the full transition from 93/42/EEC, 90/385/EC and 98/79/EC to MDR / IVDR may not be possible on the same date for all devices of a manufacturer. Some manufacturers need to be prepared to run the old and new system in parallel. Start the transition to MDR / IVDR a.s.a.p. (optimal already started), contact your NB for coordination, time line etc.. Thing twice about changing the NB now or within the next years. Expect higher costs and longer processing time, due to the increasing amount of work (Economic Operators and NB). mdc medical device certification GmbH Folie 20

Recommendations If you need additional employees, start recruiting now. Check the information, given by Notified Bodies, consultants etc., on a regular basis keep updated. There are various seminars with respect to the MDR and IVDR you should participate, for example: - mdc seminar Tech. Documentation acc. to MDR 09.10.2018, Berlin - mdc seminar Clinical Evaluation acc. to MEDDEV 2.7/1 Rev. 4 & MDR 10.10.2018, Berlin - mdc seminar MDR basics 29.12.2018, Berlin - mdc seminar IVDR basics 16.10.2018, Berlin mdc medical device certification GmbH Folie 21

Conclusions All involved parties (manufacturers, Notified Bodies, Competent Authorities ) expect a high workload. A binding conformity assessment by the Notified Body will by possible only after notification. Due to the fact that the transition period under MDR is extremely short and that under the IVDR a lot of devices will now need certification, the time needs to used for preparation. Manufacturers can not wait for the Notified Body. The transition periods have to be also used for timely (re-)certification according to the old Directives. Priority for the Regulations should be for the devices, which so far are not covered by a certificate according to the Directives. A good (!) compliance with the current Directives is a important basis for the Regulations. mdc medical device certification GmbH Folie 22

Thank you for your attention! Questions? mdc medical device certification GmbH Folie 23

mdc medical device certification GmbH Kriegerstraße 6 70191 Stuttgart Telefon: +49 (0) 7 11 / 25 35 97-0 Telefax: +49 (0) 7 11 / 25 35 97-10 E-Mail: mdc@mdc-ce.de mdc medical device certification GmbH Niederlassung Berlin Albert-Einstein-Str. 14 12489 Berlin Telefon: +49 (0) 30 / 63 92 84 10 Telefax: +49 (0) 30 / 63 92 84 27 E-Mail: mdc@mdc-ce.de mdc medical device certification GmbH Zweigniederlassung austria Wienerbergstraße 11 / A 18 1100 Wien, Österreich Telefon: +43 (1) / 388 0483-0 Telefax: +43 (1) / 388 0483-590 E-Mail: mdc@mdc-ce.at mdc medical device certification GmbH Folie 24