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MDSAP/EU MD Changes
PharMed Management Group Inc.
Rita Shahvar
AGENDA
• MDSAP
• ISO 13485:2016
• Clinical Evidence Report – MEDDEV 2.7.1/Rev 4
• Medical Device Directive – Revisions (MDR)
• PharMed Management Group Can Help.
MDSAP – Auditing Organization with
Recognition
• The following auditing organizations
have received authorization to conduct
MDSAP audits and have recognition
from FDA to perform audits accepted in
the US, EU, JP, AUS and others
harmonized geographies.
• BSi Group America Inc.
• Intertek Testing Services NA Inc.
• TÜV SUD America Inc.
MDSAP – Audit Requirements
• MDSAP is a single audit program that
will allow a single regulatory audit to
satisfy the needs of multiple regulatory
jurisdictions.
• The single audit of a medical device
manufacturer’s quality management
system will include the assessment of
design and development (where
appropriate), Good Manufacturing
Practices (GMPs), adverse event
reporting, and other applicable
requirements of the participating
regulatory authorities.
• Auditors followed published MDSAP
audit guidance very closely. MDSAP
certificates for all ISO 13485/CMDCAS
locations when MDSAP becomes fully
operational in 2017.
MDSAP – Partners in the MDSAP Pilot
Program
• The MDSAP Pilot is intended to allow MDSAP
recognized Auditing Organizations to conduct a single
audit of a medical device manufacturer that will
satisfy the relevant requirements of the medical
device regulatory authorities participating in the pilot
program.
• International partners that are participating in
the MDSAP Pilot include:
• Therapeutic Goods Administration of
Australia
• Brazil’s Agência Nacional de Vigilância
Sanitária
• Health Canada
• Japan’s Ministry of Health, Labour and
Welfare, and the Japanese
Pharmaceuticals and Medical Devices
Agency
• The World Health Organization (WHO)
Prequalification of In Vitro Diagnostics
(IVDs) Programme and the European
Union (EU) are Official Observers
AGENDA
• MDSAP
• ISO 13485:2016
• Clinical Evidence Report – MEDDEV 2.7.1/Rev 4
• Medical Device Directive – Revisions (MDR)
• PharMed Management Group Can Help.
ISO 13485:2016 – Changes from 2003
• Some of the biggest changes between the 2003 and 2016 version
include:
• Incorporation of risk-based approaches beyond product
realization. Risk is considered in the context of the safety and
performance of the medical device and in meeting regulatory
requirements;
• Increased linkage with regulatory requirements, particularly for
regulatory documentation;
• Application to organizations throughout the lifecycle and
supply chain for medical devices;
• Harmonization of the requirements for software validation for
different software applications (QMS software, process control
software, software for monitoring and measurement) in
different clauses of the standard;
• Emphasis on appropriate infrastructure, particularly for
production of sterile medical devices, and addition of
requirements for validation of sterile barrier properties;
• Additional requirements in design and development on
consideration of usability, use of standards, verification and
validation planning, design transfer and design records;
• Emphasis on complaint handling and reporting to regulatory
authorities in accordance with regulatory requirements, and
consideration of post-market surveillance; and
• Planning and documenting corrective action and preventive
action, and implementing corrective action without undue
delay.
ISO 13485:2016 –
Changes from 2003
• Advance planning is essential to avoid panic
closer to March 2019.
• Health Canada has announced that as of 1
January 2019, they will terminate their
current CMDCAS program and only accept
MDSAP certificates. Manufacturers with
products on the market in Canada cannot
wait until 29 February 2019 to transition to
the ISO 13485:2016 certificate. Failure to
meet the 1 January 2019 date for transition
to a MDSAP certificate may mean your
products will not be licensed in Canada1
1. https://www.bsigroup.com/en-US/medical-devices/Our-services/ISO-13485-Revision/
1
AGENDA
• MDSAP
• ISO 13485:2016
• Clinical Evidence Report – MEDDEV 2.7.1/Rev 4
• Medical Device Directive – Revisions (MDR)
• PharMed Management Group Can Help.
MEDDEV 2.7.1./4 –
Clinical Evaluation
• Majority of Revision 3 is the same with
the exception of details regarding:
• Frequency of Evaluation
• Low Risk (Class I) – 2 to 5 years
• Low-Medium Risk (Class IIa) - at least every two
(2) years
• Medium Risk (Class IIb) – at least annually
• High Risk/Implantable Devices – Annually
• Qualifications of Team Members
• Declaration of Interest
• Intended to prevent bias
• Establishing State-of-the-Art
• Equivalency
• A contract to be made between internal
organization and equivalent manufacturer
allowing access to their data on an ongoing basis.
• If this is not feasible, manufacturers
should at least provide physical,
mechanical and chemical characterization
requirements through comparative
testing.
AGENDA
• MDSAP
• ISO 13485:2016
• Clinical Evidence Report – MEDDEV 2.7.1/Rev 4
• Medical Device Directive – Revisions (MDR)
• PharMed Management Group Can Help.
Medical Device Directive
Revision - MDR
• The new rules will apply 3 years after publication for
medical devices.
• ISO 13485:2016 was published in March 2016, with a
transition period of three years. The harmonization of
this standard allows the presumption of conformity to
the Regulation in the future.
• Manufacturers will have the transition period to apply
for certification under the MDR for devices currently
certified under the Medical Devices Directive (MDD).
Certificates issued to the
• MDD during the transition period will remain valid for
the entirety of their certification period (no longer
than five years), unless that exceeds four years after
the date of application. If you do not receive
certification during the transition period, and your
MDD certificate expires, you will have to remove
products from the market in the EU until they have
been certified under the MDR.
http://www.aami.org/productspublications/articledetail.aspx?ItemNumber=3189
AGENDA
• MDSAP
• ISO 13485:2016
• Clinical Evidence Report – MEDDEV 2.7.1/Rev 4
• Medical Device Directive – Revisions (MDR)
• PharMed Management Group Can Help.
PharMed Management Group Can Help.
• Gap Assessments for current quality system per the
requirements required for MDSAP.
• Align requirements for MDSAP and revised ISO
13485:2016 to identify processes that should be
updated to meet harmonized requirements.
• Update procedure for CER per MEDDEV 2.7.1/4
requirements and develop a gold standard template to
meet requirements for rev 4, and risk based
classification of products.
• Perform a preparedness audit for MDSAP, MDR and ISO
13485:2016.
• Revised CER’s to meet MEDDEV 2.7.1/4 requirements
using revised template.
• MDR gap assessment, based on anticipated changes to
be implemented after May 2017, and final version of
Medical Device Directive Revision (MDR) is issued.
• Please contact us at pharmedgrp@gmail.com or
847-947-0560.

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MDSAP/EU MD Changes Summary

  • 1. MDSAP/EU MD Changes PharMed Management Group Inc. Rita Shahvar
  • 2. AGENDA • MDSAP • ISO 13485:2016 • Clinical Evidence Report – MEDDEV 2.7.1/Rev 4 • Medical Device Directive – Revisions (MDR) • PharMed Management Group Can Help.
  • 3. MDSAP – Auditing Organization with Recognition • The following auditing organizations have received authorization to conduct MDSAP audits and have recognition from FDA to perform audits accepted in the US, EU, JP, AUS and others harmonized geographies. • BSi Group America Inc. • Intertek Testing Services NA Inc. • TĂśV SUD America Inc.
  • 4. MDSAP – Audit Requirements • MDSAP is a single audit program that will allow a single regulatory audit to satisfy the needs of multiple regulatory jurisdictions. • The single audit of a medical device manufacturer’s quality management system will include the assessment of design and development (where appropriate), Good Manufacturing Practices (GMPs), adverse event reporting, and other applicable requirements of the participating regulatory authorities. • Auditors followed published MDSAP audit guidance very closely. MDSAP certificates for all ISO 13485/CMDCAS locations when MDSAP becomes fully operational in 2017.
  • 5. MDSAP – Partners in the MDSAP Pilot Program • The MDSAP Pilot is intended to allow MDSAP recognized Auditing Organizations to conduct a single audit of a medical device manufacturer that will satisfy the relevant requirements of the medical device regulatory authorities participating in the pilot program. • International partners that are participating in the MDSAP Pilot include: • Therapeutic Goods Administration of Australia • Brazil’s AgĂŞncia Nacional de Vigilância Sanitária • Health Canada • Japan’s Ministry of Health, Labour and Welfare, and the Japanese Pharmaceuticals and Medical Devices Agency • The World Health Organization (WHO) Prequalification of In Vitro Diagnostics (IVDs) Programme and the European Union (EU) are Official Observers
  • 6. AGENDA • MDSAP • ISO 13485:2016 • Clinical Evidence Report – MEDDEV 2.7.1/Rev 4 • Medical Device Directive – Revisions (MDR) • PharMed Management Group Can Help.
  • 7. ISO 13485:2016 – Changes from 2003 • Some of the biggest changes between the 2003 and 2016 version include: • Incorporation of risk-based approaches beyond product realization. Risk is considered in the context of the safety and performance of the medical device and in meeting regulatory requirements; • Increased linkage with regulatory requirements, particularly for regulatory documentation; • Application to organizations throughout the lifecycle and supply chain for medical devices; • Harmonization of the requirements for software validation for different software applications (QMS software, process control software, software for monitoring and measurement) in different clauses of the standard; • Emphasis on appropriate infrastructure, particularly for production of sterile medical devices, and addition of requirements for validation of sterile barrier properties; • Additional requirements in design and development on consideration of usability, use of standards, verification and validation planning, design transfer and design records; • Emphasis on complaint handling and reporting to regulatory authorities in accordance with regulatory requirements, and consideration of post-market surveillance; and • Planning and documenting corrective action and preventive action, and implementing corrective action without undue delay.
  • 8. ISO 13485:2016 – Changes from 2003 • Advance planning is essential to avoid panic closer to March 2019. • Health Canada has announced that as of 1 January 2019, they will terminate their current CMDCAS program and only accept MDSAP certificates. Manufacturers with products on the market in Canada cannot wait until 29 February 2019 to transition to the ISO 13485:2016 certificate. Failure to meet the 1 January 2019 date for transition to a MDSAP certificate may mean your products will not be licensed in Canada1 1. https://www.bsigroup.com/en-US/medical-devices/Our-services/ISO-13485-Revision/ 1
  • 9. AGENDA • MDSAP • ISO 13485:2016 • Clinical Evidence Report – MEDDEV 2.7.1/Rev 4 • Medical Device Directive – Revisions (MDR) • PharMed Management Group Can Help.
  • 10. MEDDEV 2.7.1./4 – Clinical Evaluation • Majority of Revision 3 is the same with the exception of details regarding: • Frequency of Evaluation • Low Risk (Class I) – 2 to 5 years • Low-Medium Risk (Class IIa) - at least every two (2) years • Medium Risk (Class IIb) – at least annually • High Risk/Implantable Devices – Annually • Qualifications of Team Members • Declaration of Interest • Intended to prevent bias • Establishing State-of-the-Art • Equivalency • A contract to be made between internal organization and equivalent manufacturer allowing access to their data on an ongoing basis. • If this is not feasible, manufacturers should at least provide physical, mechanical and chemical characterization requirements through comparative testing.
  • 11. AGENDA • MDSAP • ISO 13485:2016 • Clinical Evidence Report – MEDDEV 2.7.1/Rev 4 • Medical Device Directive – Revisions (MDR) • PharMed Management Group Can Help.
  • 12. Medical Device Directive Revision - MDR • The new rules will apply 3 years after publication for medical devices. • ISO 13485:2016 was published in March 2016, with a transition period of three years. The harmonization of this standard allows the presumption of conformity to the Regulation in the future. • Manufacturers will have the transition period to apply for certification under the MDR for devices currently certified under the Medical Devices Directive (MDD). Certificates issued to the • MDD during the transition period will remain valid for the entirety of their certification period (no longer than five years), unless that exceeds four years after the date of application. If you do not receive certification during the transition period, and your MDD certificate expires, you will have to remove products from the market in the EU until they have been certified under the MDR. http://www.aami.org/productspublications/articledetail.aspx?ItemNumber=3189
  • 13. AGENDA • MDSAP • ISO 13485:2016 • Clinical Evidence Report – MEDDEV 2.7.1/Rev 4 • Medical Device Directive – Revisions (MDR) • PharMed Management Group Can Help.
  • 14. PharMed Management Group Can Help. • Gap Assessments for current quality system per the requirements required for MDSAP. • Align requirements for MDSAP and revised ISO 13485:2016 to identify processes that should be updated to meet harmonized requirements. • Update procedure for CER per MEDDEV 2.7.1/4 requirements and develop a gold standard template to meet requirements for rev 4, and risk based classification of products. • Perform a preparedness audit for MDSAP, MDR and ISO 13485:2016. • Revised CER’s to meet MEDDEV 2.7.1/4 requirements using revised template. • MDR gap assessment, based on anticipated changes to be implemented after May 2017, and final version of Medical Device Directive Revision (MDR) is issued. • Please contact us at pharmedgrp@gmail.com or 847-947-0560.