More Related Content Similar to How to survive the Perfect Storm – International Harmonization and Lessons from Brexit and the MDR (20) How to survive the Perfect Storm – International Harmonization and Lessons from Brexit and the MDR4. © 2019 Brandwood Biomedical www.brandwoodbiomedical.com
In 2011, Americans
Preferred Europe
“Northwestern University Survey Finds FDA
Predictability a Top Concern…”
Of US Companies:
• 4% approached FDA first
• 80% initially approached EU regulatory bodies.
• 65% of devices were CE-marked before receiving FDA
clearance.
http://www.prnewswire.com/news‐releases/northwestern‐
survey‐finds‐fda‐predictability‐a‐top‐concern‐among‐medtech‐
firms‐europe‐preferred‐for‐product‐approval‐122514653.html
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13months to go…
7
The waiting lists of some
notified bodies are running
up to 12-14 months, whilst
others are becoming more
selective in the type of clients
and scope of products.
Gert Bos
Q-Serve
“Our industry is prepared to submit product files
to comply with the new Medical Device
Regulation (MDR). However, we cannot do so. The
new regulatory system is not ready to function”
8. © 2019 Brandwood Biomedical www.brandwoodbiomedical.com
There is also the question of
Brexit. Without agreement that
the UK stays connected to the EU
in a manner like Switzerland, it
will no longer have notified
bodies after March June 2019,
Erik Vollebregt
Axon Lawyers
Devices Sold in
Europe
Devices Imported
into Europe
50%
70%
Devices CE
Marked by UK
Notified Bodies13months to go…
EU27 UK Source: BSi
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CE (or GHTF) as a Global Passport
Singapore
• Expedited
pathways for
GHTF‐founder
approved devies
Taiwan
• Expedited Class II
review if both CE
and FDA
approved
Saudi Arabia
• Verification of
GHTF member
approval plus
application audit
Malaysia
• Review of CE
approval plus
technical audit
Australia
• Accepts CE and
now other
jurisdictions
10
15. © 2019 Brandwood Biomedical www.brandwoodbiomedical.com
FDA changes
• No‐predicate
submissions for
lower risk devices
• De Novo program
510k program
• Based around
manufacturer
competence
SaMD trial
• Emerging Global
consensus on
device Quality
Systems and
Audit
QSR to ISO 13485
(and MDSAP)
17. © 2019 Brandwood Biomedical www.brandwoodbiomedical.com
FDA’s Proposed Future SaMD PreCert program
17
“Potentially precertified
companies could market
their lower-risk devices
without FDA premarket
review or only a streamlined
premarket review based on
the company's
precertification level
and IMDRF risk
categorization.”
This is starting to look like Conformity Assessment!
18. © 2019 Brandwood Biomedical www.brandwoodbiomedical.com
Surviving the Storm - Regulatory
Core Technical File
• Consensus Standards based
• Adapt to each jurisdiction
• Clinical Evidence is Paramount
Proactive Postmarket
• Gather data
• Monitor trends
• Act!
Regulatory Intelligence
• Standards and State of the Art
• Changing requirements
• Act!
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