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Joe Hage
🔥 Find me at MedicalDevicesGroup.net 🔥
September 2015
New CE Marking Rules
4 min reading time

Think it’s easier to launch in Europe with a CE Mark and get FDA clearance later?

Then you’ll want to attend http://medgroup.biz/New-CE-Marking-Rules, a free webinar we’re hosting for group members on October 6.

The latest adopted draft says you’ll need clinical trials for implantable and Class III devices (there are exceptions; tune in for those).

The proposed modifications are a big deal. Getting your Notified Body to accept your device as “equivalent” may not be enough.

TUV SUD’s Dr. Bassil Akra will discuss how you’ll need to adjust for EU medical device approval and post-approval processes.

Sign up at http://medgroup.biz/New-CE-Marking-Rules and we’ll make the replay, slides, and transcript available for all who register.

If you do business in Europe, you won’t want to miss this event.

++++++++++

13485 Glitch

If you registered for next week’s 13485 webinar but didn’t get a confirmation, please try again at http://medgroup.biz/ISO-13485-webinar because I found a software glitch that affected a few dozen subscribers.

And if you haven’t registered, do it quickly because we already filled 759 seats.

We’re hosting this event with greenlight.guru because the new ISO 13485 standard expects you to apply risk management methods and techniques to every single one of your QMS process, including outsourced processes as well.

That link again: http://medgroup.biz/ISO-13485-webinar

++++++++++

Discussions

How can you get listed on an incubator supplier directory?

EC-REP change of address – what are the challenges?
http://bit.ly/EC-rep

We can’t afford an FDA that discourages new, low risk medical technology

What’s new in customer complaints?

Med Device Companies: Never Say “We Sell Boxes”

Legal requirements for marketing a Class I device in Germany

LED Medical Devices in the EU

++++++++++

Make it a great week.

Joe Hage
Medical Devices Group Leader


Joe Hage
🔥 Find me at MedicalDevicesGroup.net 🔥
Manufacturers need to have a PMS plan that is specific to a product or family of products. The PMS procedure needs to be updated to identify the frequency and product-specific nature of PMS for each product family or a separate document needs to be created for each product family. For devices that are high-risk, implantable or devices that have innovative characteristics the manufacturer will need to perform some PMCF studies. Even products with clinical studies might require PMCF, because changes to the device, accessories and range of sizes may not be covered by the clinical studies. MEDDEV 2.12/2 (http://ec.europa.eu/DocsRoom/documents/10334/attachments/1/translations/en/renditions/native) provides guidance on the requirements for PMCF studies, but most companies manufacturing moderate risk devices do not have experience obtaining patient consent to access medical records in order to collect PMCF data–such as postoperative follow-up data.

Medical device manufacturers are challenged by several other requirements when they are applying for CE Marking. Which requirements did you find to be the most challenging?

Joe Hage
🔥 Find me at MedicalDevicesGroup.net 🔥
PMS & PMCF
Post-market clinical follow-up (PMCF) is only required for the highest risk devices by the FDA. For CE Marking, however, all product families are required to have evidence of PMCF studies or a justification for why PMCF is not required. The biggest mistake I see is that manufacturers refer to their PMS procedure as the PMS plan for their product family, and they say that they do not need to perform PMCF because the device is similar to several other devices on the market.

Joe Hage
🔥 Find me at MedicalDevicesGroup.net 🔥
CE Marking: 3 Biggest Challenges for US Companies

If you have a moderate risk device you probably will submit a 510(k) before applying for CE Marking, because some of the requirements for a technical file are more challenging than European requirements.

Risk Management File
The FDA only requires documentation of risk management in a 510(k) submission if the product contains software and the risk is at least a “moderate concern.” Even though you are required to perform risk analysis, a knee implant would not require submission of the risk analysis with the 510(k). If a product is already 510(k) cleared, you may be surprised to receive audit nonconformities related to your risk management documentation for CE Marking. The most common deficiencies with a risk management file are:

1. compliant with ISO 14971:2007 instead of EN ISO 14971:2012
2. reduction of risks as low as reasonably practicable (ALARP) instead of reducing risks as far as possible (AFAP)
3. reducing risks by notifying users and patients of residual risks in the IFU
4. only addressing unacceptable risks with risk controls instead of all risks–including negligible risks

Burrell (Bo) Clawson
I research patents & design products to get a patented competitive position: Over 30 patents.
Joe, when I click the link I get “Page not found.” No clue what is up.

Joe Hage
🔥 Find me at MedicalDevicesGroup.net 🔥
It works for me: https://www.linkedin.com/grp/post/2070960-6057579430275006467

Burrell (Bo) Clawson
I research patents & design products to get a patented competitive position: Over 30 patents.
Marie Suetsugu, the link to the post by Robert Packard appears to be bad.

Vivian Bui
Associate Project Engineer at Medco Product Inc,
Thanks.

Joe Hage
🔥 Find me at MedicalDevicesGroup.net 🔥
To protect you from spam, only you can add yourself, but here’s the direct link: https://www.linkedin.com/grp/home?gid=2070960. It should be as easy as hitting “Join.”

Vivian Bui
Associate Project Engineer at Medco Product Inc,
I have the same problem. Would you please add me in that group. Thanks

Carlos Romero
Making ECPs practice easier at asahi vision inc
System says that above page is not found ↑

Marie Suetsugu
QA/RA
This post by Robert Packard in the ‘Medical Devices: QA / RA’ subgroup might be of interest to some…

CE Marking: 3 Biggest Challenges for US Companies
https://www.linkedin.com/grp/post/2070960-6057579430275006467

Andrew Nelson
Senior Manager Innovation Services at Flex
Joe, many thanks. I will review it ASAP.

Cheers,
Andrew

Joe Hage
🔥 Find me at MedicalDevicesGroup.net 🔥
Yes, we recorded the session. The video and slides are immediately available at https://medicaldevicesgroup.net/webinar/ce-submissions/ with transcript to follow shortly.

Andrew Nelson
Senior Manager Innovation Services at Flex
Joe, I missed the presentation on CE Marking rules. Is there any way I can get information on requirements for CE Mark of class 1 devices that have predicate clearance by the FDA in the US?

Anas Shokor
Field Service Engineer LMS Nordics at Leica Microsystems
I clicked on the registration tab but nothing happened, so I am not sure if my registration went through.

Marcus Gould
Regulatory Affairs Consultant
Looking forward to the webinar, thank you Joe.

Clinical data and its evaluation, for all classes of medical devices, is especially being scrutinized here in the EU, and the notified bodies are really tightening up on the clinical requirements. No doubly Dr. Akra will introduce the following, but these three MEDDEV guidance documents on clinical evaluation and clinical investigations are being followed to the letter by the notified bodies and competent authorities:

http://ec.europa.eu/growth/sectors/medical-devices_old/documents/guidelines/files/meddev/2_7_1rev_3_en.pdf

http://ec.europa.eu/growth/sectors/medical-devices_old/documents/guidelines/files/meddev/guidelines2008_en.pdf

http://ec.europa.eu/growth/sectors/medical-devices_old/documents/guidelines/files/meddev/2_7_4_en.pdf

It is essential manufacturers of all medical device classes who intend to affix the CE mark to their device(s) understand these MEDDEVs in detail, and apply them according to the device class.

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Asked on September 22, 2015 2:05 am
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