This session will examine some of the hot topic in this areas including a presentation from TGA covering some of the challenges they are seeing locally as well as an industry perspective on global hot topics and trends in device vigilance
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Presentation: Device vigilance - local challenges & global trends
1. Device Vigilance
Local Challenges & Global Trends
Pam Carter
Director, Device Vigilance and Monitoring Section
Medical Devices Branch, TGA
ARCS Conference 2018
21 August 2018
2. Topics
Local challenges
• Medical Device reforms
– MMDR
– Inquiries and the results
• Relationship between sponsor and
manufacturer
• Education and training
• Reporting of AEs
• Relationship with health facilities and
professionals
Global hot topics and trends
• Women’s health
• Post market surveillance
– PSUR/Annual reporting
– Life cycle responsibilities
– Post market surveillance studies
• Reporting AEs
– Electronic
– Web forms
– Databases
– Harmonisation
– Communication between regulators
4. Expert Panel Review (MMDR)
• Two reports released during 2015
– Medicines and Devices
– Complementary medicines and Advertising
• Review included discussion papers, submissions and interviews, followed
by stakeholder workshops and other meetings
• Department considered feedback and advised Minister, who took
preferred position to Cabinet
• Government intent released in May 2016 budget - full response released
on 15 September 2016
– Government accepted 56 of the 58 Recommendations
5. MMDR medical device projects
• Key projects
• Designation of conformity assessment bodies in Australia
• Expedited review process for certain ‘novel’ devices
• Use of approvals from comparable overseas regulators
• Harmonisation with the European Union
• Strengthening of post market monitoring
6. European Harmonisation
MMDR recommendation:
• Align with new European regulatory framework where possible
• Clear rationale for Australian specific requirements
EU MDR and IVD Regulations came into force on 26 May 2017
Key changes include:
• Definitions
• Classification
• Conformity assessment procedures
• Essential Principles and General Safety &
Performance Requirements
• EU regulations also capture in-house IVDs
• Implant cards and patient leaflets
7. Medical Devices reforms
Patient Implant Cards and Device Information Leaflets
• From 1 December 2018, patient implant cards will begin to be supplied with new
implantable medical devices (starting with urogyanecological mesh)
• All permanently implantable devices are affected:
– Phased approach to be fully implemented by 1 December 2021
• Addresses an information gap
• Exempted products:
– simple implants (dental fillings, dental braces, tooth crowns, endosseous dental
implants, screws, etc.)
8. Medical Devices reforms
Patient Implant Cards and Device Information Leaflets
Must include the following information about the device:
Cards
– Name
– Model
– Batch code, lot number or serial number
– Unique device identifier (if any)
– Manufacturers name, address and website
Leaflets
– information identifying the device, or the kind of
device
– the intended purpose
– information explaining how to use the device safely
– other information that the manufacturer considers
would be useful for patients
9. Post market monitoring
• Better integration and timely analysis of
available datasets
• Electronic reporting of adverse events
• Enhanced information-sharing with overseas
regulators
• Deferred: Implementation of registries for all
high risk implantable device
10. Reforms vs Recommendations from Inquiries
• Reforms
– Quicker access to medical device technology through:
Multiple pathways to inclusion
Use of overseas approvals
• Inquiries
– Hips, breast implants, urogynaecological mesh, private health insurance, cosmetic industry, health
technology
More oversight of medical devices pre and post market
More information for patients and health professionals
Medical Device Registries
11. Relationships
• Relationship between sponsor and manufacturer
– Signed agreements
– Flow of information
– Understanding the Australian regulatory system
• Relationship with health facilities and professionals
– inSite
– Who is reporting an adverse event and to whom
– Limitations of the Therapeutic Goods Act
– Expectations on sponsors and manufacturers
Replacement of devices
Reporting
12. Education and Training
• Sponsors:
– Staying included
– Sponsor training day
– SME
– consultation
• Health Professionals
– inSite
– Web statements
– MDSU
– Consultation
13. Reporting of AEs
Still need to work on:
• No ARTG number
• Insufficient information
• Statistics
• Timely response to investigation
Getting better
• Submitting final reports
• Statistics
• Using web portal
15. Women’s health
• Mesh
• Breast implants
• Contraceptive devices
• Morcellators
• Dermal fillers
16. Post market surveillance
• PSUR/Annual reporting
– Align with European guidance
• Life cycle responsibilities
– Post market surveillance studies
– MDSAP
– Post market reviews
Clinical
Evidence
Report
Risk
assessment
Risk
mitigations
Post-market
vigilance
17. Reporting Adverse Events
• Electronic reporting
• Web forms
• Databases
• Harmonisation
– Adverse event terminology codes
Annex A: Problem terms and codes
Annex B: Type of Investigation terms and codes
Annex C: Investigation Findings terms and codes
Annex D: Investigation Conclusion terms and codes
To come: Annex E - Clinical Signs, Symptoms and Conditions,
and Annex F – Health Impacts
• Communication between regulators
Editor's Notes
The Australian Government retains responsibility for approving the inclusion of therapeutic goods in the ARTG
Rather than automatically accepting international approvals
However need to make much greater use of overseas evaluations
Need to introduce greater flexibility in approval pathways
TGA could more appropriately align level of regulation with the actual risk posed by the products in certain areas
Hi Rachel, here is a summary of some of the differences in the EU IVD Regs that we have noted to date.
The EU IVD Regs came into force on 26 May 2017 replacing IVDD 89/79/EC
There is a transitional period of 5 years until 26 May 2022.
Preliminary comments (but require further analysis)
Definitions
EU definition of an IVD is largely equivalent to our current definition (some notable additions which help to clarify what is an IVD)
EU Regs include a definition of a companion diagnostic
EU definition of ‘device for self-testing’ aligns broadly with the Australian definition of an ‘IVD medical device for self-testing’ but is extended to include ‘devices used for testing services offered to lay persons by means of information society services (important new feature which may be helpful in clarifying the regulation of direct to consumer testing provided over the internet)
Classification
Classification A, B, C & D (with D being the highest risk classification) – equivalent to our Class 1-4 hierarchy
Viral load tests Class D (currently Class 3 in our Regs (eg, HIV viral load tests)
Companion diagnostics are Class C (currently not a specific classification rule in our Regs for companion diagnostics but are regulated as Class 3 IVDs)
Self-tests are Class C unless specifically identified in the EU Regs as being Class B (eg, for detection of pregnancy, fertility testing, determining cholesterol level) – needs consideration of impact.
Conformity assessment procedures
those for Class D and Class C are largely equivalent to our requirements
some differences in CA procedures for
Class B (EU Regs don’t allow use of production quality assurance procedures and if adopted may affect some Australian manufacturers of Class 2 IVDs)
Class A sterile (EU Regs require either full QMS (excluding design examination) or production quality assurance procedures – may impact sterile IVD collection devices)
Essential Principles – new EU General Safety & Performance Requirements are largely equivalent with our EPs
EU Regs also capture in-house IVDs
Some of the recent changes implemented by the TGA to further improve the safety of implantable devices have come from reviews and inquiries on other devices but will be implemented across the board to improve safety.
Patient implant information cards with implantable devices will be phased in, and this will include breast implant devices.
Further reviews and changes will be considered as part of the overall reform process such as device identification cards and ongoing vigilance and monitoring processes.