New european rules governing medical devices vigilance and combination products
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New European Rules governing medical devices vigilance and combination products. Lincoln Tsang May 2008. Topics. Review of rules governing medical devices sector Changes made in the new law New framework governing novel combination products. European regulatory landscape.

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New european rules governing medical devices vigilance and combination products

New European Rules governing medical devices vigilance and combination products

Lincoln Tsang

May 2008

Topics combination products

  • Review of rules governing medical devices sector

  • Changes made in the new law

  • New framework governing novel combination products

European regulatory landscape
European regulatory landscape combination products

  • Directives on devices adopted in 1990, 1993 and 1998 constitute the basic regulatory framework to harmonise practices in Member States

  • Placing on the market is linked to the need to undertake conformity assessment with essential requirements

    • Risk assessment

    • Risk management

    • Risk/benefit analysis

    • Standards

Reviews combination products

  • Medical Devices Experts Group (June 2002)

    • Functioning of the Medical Devices Directive

  • Commission Communication to Council of Ministers and European Parliament (May 2003)

    • Enhancing the implementation of the New Approach Directives

  • Commission Communication to Council of Ministers and European Parliament (July 2003)

    • Medical devices

Conclusion of sector specific reviews
Conclusion of Sector-specific Reviews combination products

  • The basic framework remains appropriate

  • Room for improvement in a number of areas, including

    • Conformity assessment

    • Proper implementation of provisions on clinical data and quality assurance

    • Post-market Surveillance

    • Vigilance

    • Co-operation between Member States

    • International dimension

What happened during the legislative process
What happened during the legislative process? combination products

  • EP negotiated 141 amendments

    • definition of single use

    • proposal from Commission on “reprocessing of devices”

    • specific labelling requiring for SUD and devices containing DEHP

  • Council negotiated 90 amendments

  • 17 out of 23 articles are changed

  • 9 out of 12 annexes of MDD modified

  • Mixture of cosmetic changes and substantial major changes

  • Alignment of AMIDD with MDD

Major changes to the regulatory framework
Major changes to the regulatory framework combination products

  • Refinement made:

    • clinical evaluation

    • classification and the corresponding conformity assessment

    • uniform application of rules and demarcation

    • reclassification issues

    • principle of design for patient safety

Why clinical trials and monitoring
Why clinical trials and monitoring? combination products

  • Failure ex vivo to mimic clinical evaluation

  • Proof of concept

  • Modifications

  • New purpose

  • User issues

  • Efficacy

  • Safety for humans

  • Pharmacoeconomic considerations

An example treatment of abdominal aortic aneurysms
An example- treatment of abdominal aortic aneurysms combination products

  • Design

  • Stress testing

  • Fatigue testing

    X Fractures in vivo

    X Endoleaks

Clinical evaluation
Clinical evaluation combination products

  • In principle clinical evaluation is necessary for every device

  • In principle for Class III device and implantable devices a clinical investigation has to be performed

  • Documentation of clinical evaluation now part of the technical documentation

  • Notified bodies are required to assess clinical evaluation as part of conformity assessments (subject to classification of the device)

  • Principles of clinical evaluation clarified

Clinical data in new law amendment made to annex x
Clinical data in new law (amendment made to Annex X) combination products

  • Information about safety and/or performance generated from use of device

  • Clinical investigations

  • Clinical investigations or other studies reported in literature or similar device (where equivalence to the device in question can be demonstrated)

  • Published and/or unpublished reports on other clinical experience of either the device or similar device

Continuous monitoring
Continuous monitoring combination products

  • Clinical evaluation must be kept up to date

  • Implementation of post-market clinical follow up (PMCF) as part of PMS unless justification for absence

  • Exchange of information as regards clinical investigations between CAs

    • information on approval or non-approvals of clinical studies

    • information on termination of clinical trials

    • information on adverse events

Essential requirements
Essential requirements combination products

  • Inclusion of design for patient safety

  • Consideration of

    • ergonomic features

    • mental, physical and health conditions of patients and users (home use devices for disabled and elderly patients)

  • Electronic labelling possible in the future (requires implementation)

  • Specific labelling requirements for SUD (risks on reuse)

Read across to machinery directive
Read across to Machinery Directive combination products

  • Machinery Directive excluded medical devices

  • Where the relevant hazard exists, devices which are also machinery…must also meet the essential health and safety requirements set out in Annex I of [Machinery Directive] to the extent that those essential health and safety requirements are more specific than MDD

    • lex specialis applies if Machinery Directive is more specific (moving parts, assembling of devices at point of care)

Special labelling requirements
Special labelling requirements combination products

  • Devices intended to administer and/or remove medicines, body fluids or other substances to or from the body or devices intended for transport or storage of such body fluids or substances contain Phthalates

  • Devices including treatment of children or pregnant or nursing women, justification for use substances which are classified as carcinogenic, mutagenic or toxic to reproduction in technical documentation and instructions for use residual risks based upon precautionary principle

  • EP wanted to place prohibition of all dangerous substances

Device vigilance
Device Vigilance combination products

  • Most significant

  • Changes made in amending Directive

    • basic framework not changed

    • collect, record, report

  • Parallel changes made to MEDDEV 2.12-1 (Device Vigilance)

    • 2.5 years consultation with CAs, Commission, industry and other interested parties

    • agreed position of best practice in interpretation

    • definitions

    • process

    • GHTF

Reporting timescales
Reporting timescales combination products

  • Serious public health threat

    • immediately but not later than 2 calendar days after awareness by the manufacturer

  • Death or unanticipated serious deterioration in state of health

    • immediately after the manufacturer established a link between the device and the event but not later than 10 elapsed calendar days following the date of awareness of the event

  • Immediately means without delay that could not be justified

Definitions combination products

  • Serious deterioration in state of health (expanded)

    • life threatening illness or deterioration in state of health

    • permanent impairment of a body function or permanent damage to a body structure

    • a condition required medical or surgical intervention to prevent

    • any indirect harm as a consequence of an incorrect diagnostic or IVD test results when used within IFU

    • foetal distress, foetal death or any congenital abnormality or birth defects

  • Serious public health threat

    • any event type resulting in imminent risk of death, serious injury, or serious illness that may require prompt remedial action

Field safety corrective action
Field safety corrective action combination products

  • Replaced definition for recall

    • action taken by manufacturer to reduce a risk of death or serious deterioration in the state of health associated with the use of a medical device already on the market

    • action notified via a field safety notice

  • In assessing need for FSCA, use methodology described in harmonised standard EN ISO 14971 last edition

FSCA combination products

  • Return of device to supplier

  • Device modification

  • Device exchange

  • Device destruction

  • Retrofit by purchaser of manufacturer’s modification or design change

  • Advice given by manufacturer regarding use of the device

Exemption rules
Exemption rules combination products

  • Previous exemption rules 1-6 replaced by “conditions where under the vigilance system a report is usually not required”.

  • Summary reporting might be allowed for incidents described in FSNs and for common and well documented incidents (cfr old exemption rules 7 & 8)

Enforcement combination products

  • National competence

    • effective

    • dissuasive

    • proportionate

  • Co-ordination and centralisation of information exchange

  • May be based upon consumer protection and/or general product safety regulation

Challenges ahead ancillary component to a device
Challenges ahead: ancillary component to a device combination products

  • Novel drug/device combination products

    • EMEA guidance on quality, safety and effectiveness of medicinal substance

  • Advanced therapy medicinal products

    • gene therapy

    • cell therapy

    • tissue engineered

    • specific risk management guidance