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Australia – Healthcare Opportunities for British Business


• 9.30 am Thursday 18th October 2012
• Speakers:
    – “Introduction to Australia & the Healthcare Market”
    Joe Dodd, Manager Trade & Investment, UKTI Melbourne

    – “The device market in Australia – some useful facts”
    Mark Glover, Manager Commercial Optimisation, Commercial Eyes

    – “How do I get my product registered?”
    Jeanette Lodge, Project Manager Regulatory Affairs, Commercial Eyes




                                                                          2
Australia – Healthcare Opportunities for British
Business
Joe Dodd
Manager, Trade & Investment, British Consulate-General Melbourne




                                                                   3
Why Australia?

• You’ll feel at home immediately:
    – Over 1,000 UK companies and more Brits than in any other country
    – Very similar business, legal and regulatory culture
• Best performing OECD country economically, with good growth prospects
• Strong Australian dollar making UK goods and services more affordable
• Closely linked to fast growing Asia-Pacific nations
• Well funded, growing healthcare market




                                                                          4
Australia – an economic snapshot

                                           Australia       UK

Population                                 22.5 million    62 million

Global GDP ranking                         13th            7th

GDP growth est. 2012                       3%              0.6%

GDP per capita ($US 2011)                  $40,800         $36,600

Ease of doing business (World Bank 2011)   15th            4th

Unemployment (Sept 2012)                   5.1%            8%

Land mass – sq kms                         7 692 000 000   295 000



                                                                        5
UK/Australia trade links

• UK exports to Australia grew by
  over 60% from 2007 - 2011 (to
  more than £10 billion)
• UK’s overall exports contracted
  first half of 2012, to Australia rose
• 7th biggest market for services
  exports and 18th largest for goods
• UK is 2nd biggest foreign direct
  investor in Australia




                                          6
Australia – Country Background

                          States: 6 states (parliaments
                          are elected) and 2 territories
                          (Chief Ministers are appointed
                          by Federal Govt)

                          Cities: Sydney 4.5 million
                          Melbourne 4 million
                          Brisbane 2 million
                          Perth 1.6 million
                          Adelaide 1.2 million




                                                           7
Australian Healthcare Overview

• Australia has well developed and well funded system, total expenditure
  around AU$100 billion per annum
• 15th largest healthcare market in the world with growing and ageing
  population.
• Rated as best healthcare market to do business in Asia Pacific looking at
  market size, opportunity & risk.
• Forecasted to grow at 3.5% for next 5 years.




                                                                              8
Public System Overview

• Public System run by combination of
  Commonwealth and State
  governments.
• Commonwealth – policy, research,
  information, major initiatives.
• States – delivery of public health
  services




                                        9
Hospital Distribution

                        Hospitals by         Public            Private
                        State
                        NSW                  226               173
                        Victoria             150               161
                        Queensland           170               106
                        Western Australia    95                55
                        South Australia      80                56
                        Tasmania             24                8
                        ACT                  3                 12
                        Northern Territory   5                 2


                                                      FreeDigitalPhotos.net




                                                                              10
Funding System

• “Medicare” – major part of funding system
• Medicare Benefits Schedule provides fee for service to health
  professionals at point of care.
• Public hospitals funded jointly by federal and state governments –
  managed by state governments.
• Medicare levy 1% additional bill for individuals / families earning
  over certain level if they don’t take out private health cover.




                                                                        11
Private System

• Federal government pays 75% of Medicare benefit schedule fee to private
  provider
• Private health insurance will cover additional 25%, plus other associated
  costs such as accommodation.
• 1,275 total hospitals in Australia of which 547 are private.
• 45% of private hospitals run by not-for-profit groups including charities and
  religious bodies.
• 55% for profit companies.
• Ramsay Healthcare – 65 hospitals, <7000 beds, 28% of private beds in
  Australia. Also 33 facilities in UK
• Healthscope – 47 hospitals plus pathology services.
                                                                                  12
Aged Care

• Around 3 million people of retirement age and older
• $30 billion spend on aged care per year
• Caring for an ageing population is an ongoing issue
• Residential – mainly non-government providers but financed by
  Commonwealth government with subsidies paid to providers.
• Residents may also pay care fees
• Home and Community – both public and non-government with programmes
  of funding combining Commonwealth and State funds.
• 50% providers are non-profit charitable organisations.



                                                                        13
How can UKTI Australia help British companies?


• Carry out in-depth research on the market to
  your specifications
• Find local distributors for your products
• Arrange meetings with key potential clients
• Help you attend trade fairs and missions
• Product launches, industry seminars and PR
  and marketing support                          Joe Dodd
• Whatever you need to succeed in the            Tel: +61 3 9652 1605
                                                 Email: joe.dodd@fco.gov.uk
  market!



                                                                              14
15




                           Opportunities for British Business

                                “The Device Market in Australia
                                           Some useful facts”
                                               Mark Glover
Commercial in confidence




                                    Commercial Optimisation
                                         18th October 2012
Commercial in confidence
                           16
Commercial in confidence
                           17
Commercial in confidence
                           18
19


                                                  Health Expenditure
Commercial in confidence




                           Source: Australian Institute of Health and Welfare, Health expenditure Australia 2009-10 @ current prices


                                                                                                                                       19
20

                               Healthcare Funding in Australia -1
                           •   Medicare
                                – Is funded from taxation and subsidises healthcare for all Australians
                                    • Prescribed drugs, Rx from Doctors & Dentists, access to public
                                       hospitals

                           •   Pharmaceuticals
                                – Subsidised via the Pharmaceutical Benefit Scheme $9.6B (£6.1B)
                                – Patient contribution
                                   • General $35.40; Concessional $5.80

                           •   Private Health Insurance
                                – Patients choose Clinician and Hospital
Commercial in confidence




                                – Implantable Device reimbursement – Prostheses List
                                – Selected extras
                                     • Optical, Dental, Well being



                                                                                                          20
21

                               Healthcare Funding in Australia - 2
                           •   Consumable medical technology
                                – E.g. Rehabilitation Appliances, National Diabetes services, Continence
                                  Aids

                           •   Implantable Devices
                                – Public Hospitals provides implantable, provide surgery, both restricted by
                                   Hospital / State budgets

                                – National Procedure Banding Schedule covers theatre fees and
                                  consumables

                                – Prostheses List – private insurers are required by law to pay benefits for a
                                  range of prostheses.
Commercial in confidence




                                – There are over 9,500 prostheses on the list in 3 categories
                                    • Part A – Prostheses
                                    • Part B – Human Tissue (includes products that are substantially derived
                                      from human tissue)
                                    • Part C – Non-implantable devices

                                                                                                                 21
22
                                           Pharmaceuticals
                           Process to gain PBS listing for registered products
Commercial in confidence




                           Source: Department of Health and Ageing, PBPA Policies, Procedures and Methods, 9th December 2011


                                                                                                                               22
23


                                              PBS Growth – 10 years
Commercial in confidence




                           Source: From Discovery to Off-Patent: The Changing World of Medicines and Implications for Policymakers 22 nd Mrch 2012
24

                                       What is a Medical Device
                           A “medical device” is any instrument, apparatus, implement,
                           appliance, implant, invitro reagent or calibrator, software,
                           material or other similar or related material.
                           a)Intended by the manufacturer to be used, alone or in combination, for human beings
                           for one or more of the specific purpose(s) of:
                                 – Diagnosis, prevention, monitoring, treatment, or alleviation of disease
                                 – Diagnosis, monitoring, treatment, alleviation or or compensation for an injury
                                 – Investigation, replacement, modification, or support, of the anatomy or of a
                                    physiological process
                                 – Support or sustaining life
                                 – Control of conception
                                 – Disinfection of medical devices
Commercial in confidence




                                 – Providing information for medical or diagnostic purposes by means of the in
                                    vitro examination of specimens derived from the human body
                           And
                           b)Which does not achieve its primary intended action in or on the human body by
                           pharmaceutical, immunological or metabolic means, but which may be assisted in its
                           intended function by such means

                                                                                                                    24
25


                                         Device vs. Pharmaceutical
Commercial in confidence




                           Source: Medical Technology in Australia: Key Facts and Figures 2011
26

                           Changing needs for medical technology with
Commercial in confidence         Australia’s ageing population




                           Source: Medical Technology in Australia: Key Facts and Figures 2011


                                                                                                 26
27

                                Value of the medical technology
                                      industry in Australia
                           • There is no official source of data

                           • Total revenue 2009-2010
                                 • ~ $7.6B (£4.9B)
                                 • ~ $8.4B (£5.4B) with in-vitro diagnostic (IVD)
                                 • ~ $9.2B (£5.9B) with IVD & Dental
Commercial in confidence




                           • Expected CAGR 9% over the next 5 years
                           Source: Extrapolation of date from contracted provider. Medical Technology in Australia: Key Facts and Figures 2011



                                                                                                                                                 27
28

                           Classification of medical technology
Commercial in confidence
                                  companies in Australia




                           Source: Data from 240 companies in the MTAA database. Medical Technology in Australia: Key Facts and Figures 2011


                                                                                                                                               28
29
                                      Categorisation of medical
Commercial in confidence           technology items on the ARTG




                           Source:.Medical Technology in Australia: Key Facts and Figures 2011


                                                                                                 29
30




                              How do I get my product
                                           registered?
                                              Jeanette Lodge
                           Project Manager – Regulatory Affairs
Commercial in confidence




                                                                  30
Agenda
•   Regulatory framework
•   Local sponsor responsibilities
•   Summary of legislation & guidance
•   Comparison EU v AUS
    • What is the same?
    • What is different?
•   Some TGA specific requirements
•   Cost and Timelines
•   TGA Reforms
•   Post-market requirements
•   New Zealand
Regulatory Framework
•   Therapeutic Goods Administration (TGA)
     •   Department of Health and Ageing
     •   Regulate medicines, biologicals and
         medical devices
     •   ARTG
     •   Administers the TG Act 1989
     • Devices loosely regulated 1991 >
     • Act revised in 2002 (to 2007): risk
       classification
     • Global Harmonisation Task Force
       (GHTF)
     • Office of Devices Authorisation
    •    Ms Andrea Kunca
     • Reforms ongoing (see later)
     • Industry association - MTAA
Local Sponsor Responsibilities
                            • Located in Australia (legally
                              responsible)
                            • Procedures & agreement with
                              Manufacturer*
                            • Ensure manufacturer:
                            •   complies with Essential Principles
                                (declaration)
      • Applies an appropriate conformity assessment procedure
      • Holds current conformity assessment evidence
•   TGA eBS (e Business Services) account
•   Regulatory Applications to TGA (see later)
•   Pay fees and annual charges (see later)
•   Post market requirements (see later)
* May also be the sponsor
Legislation &
Guidance
 • The Therapeutic
   Goods Act 1989
   ‘The Act’
• The Therapeutic Goods Regulations 1990
• The Therapeutic Goods (Medical Devices)
  Regulations 2002 (the Regulations)
• Guideline: Australian Regulatory Guidelines for
  Medical Devices (ARGMD)
• Additional guideline for boundary products
• Relevant state legislation and customs
  requirements may also apply
Comparison: EU v AUS
What is the same?
• Basis in GHTF procedures and TGA framework
  based on EU MDD/AIMDD
• TGA has signed MRA with EU and EFTA for
  several industry sectors, including medical devices
• Definition of medical device (accessory also a
  medical device in Australia)
• Device Classes (although classification may vary)
• Conformity Assessment Procedures are closely
  aligned, except for CE Marking process
  (MDD/AIMDD Annex II to VII = TGA Device Regs
  2002 Schedule 3, Parts 1 to 6 – refer TGA table)
What is different?
EU                        Australia
EU MDD/AIMDD              TG Act and Regulations
18 Classification Rules   5 Classification Rules
One Class III; Class I    ‘Straight’ v ‘Special’ Class III (e.g. medicine,
with animal ingredient    human, animal, microbial, recombinant)
Essential Requirements Essential Principles (e.g. device specific,
(e.g. software validation clinical requirements, English labelling/
more stringent)           packaging/IFU, other)
CE Certification and      CE Mark not required, EC Certificate
marking                   accepted under MRA for some devices
EU DoC                    TGA DoC
What is different?
EU                                 Australia
Labelling to include authorised    Must include local sponsor name and
representative or importer         address as well as manufacturer
details                            details
Hip, Knee, Shoulder - Class III    Transitioning from Class IIb to III
                                   (current TGA reforms)
CNS contact – Class III            Transient use - Class I to IIb; Short,
                                   long-term, implantable - III
Definition of circulatory system   Definition includes common iliac
does not include common iliac      arteries, therefore some Class III in
arteries                           Aus not EU
Separate IVD Directive             IVD are subset of medical devices

See also TGA website: ARGMD Section 8
TGA Specific
•   TGA Applications:
     •   Lodge manufacturer’s evidence (and periodic updates)
     •   Submit product inclusion application (and any ‘substantial’ changes)
     • Lower risk products: EC Certificate: Random application audit
     • Higher risk products: mandatory application audit unless EU or
       EFTA MRA certificate of conformity can be supplied
     • Special products: TGA Conformity Assessment audit
     • Design and type examination: not suitable manufacturers
       evidence
     • Grouping under Section 41BE
     • Class III: UPI plus variants
•   Formulated devices: ‘random’ audit always conducted
     • Pay or delay!
Cost &
                         Timelines
Item                      Cost (AUD)              Timeline
Manufacturer’s Evidence   nil                     1 to 4 weeks
TGA Conformity            $870 plus $19,400 to 6 to 12 months +
assessment                $51,200
Class I Inclusion         nil                     Automatic
Class Im/s to AIMD        $890 to $1,150          4 weeks to decision
Inclusion                                         or audit request
Application audit         nil, $3,360 or $6,170   30 or 60 days +
Substantial variations    $390 plus $11,800 to Varies with change
                          $30,800
Annual charges            $70 to $1,150           N/A
TGA Reforms
• Increased rigor with assessment of higher
  risk devices
• Four proposed changes (Nov 2010
  consultation):
  •   Joint reclassification – in progress
  •   Use of third party assessment bodies
  •   Transparency around grouping
  •   Publication of product details on TGA website
Post Market Requirements
• Manufacturer v Sponsor responsibilities
   • May delegate activities by written
     agreement, but responsibility lies with
     manufacturer or sponsor
• Requirements include:
   • Adverse event reporting (device monitoring &
     vigilance), device tracking (maintain audit trail,
     TGA sampling, inspection or ‘desk-top’ audit)

                         •   Recall Procedures
                         •   Application for low-volume turnover
                             (LVT)
New Zealand
• ANZTPA
• ‘Piggy-backs’ on TGA process
• Medsafe notification required within 30 days of
  supply of new device
• Notification via WAND
   • Web Assisted Notification of
     Devices
   • Can clone TGA eBS details
     to WAND (although databases
      no longer linked)
• Devices containing medicine component are
  regulated as medicines
Commercial in confidence
                           Where we can help…….
                                                  44
45




                                  Commercial Eyes
                           "We take the complexities out of commercialisation
                           so that your products can achieve their full potential"



                            www.commercialeyes.com.au
Commercial in confidence




                             Jeanette Lodge:     +61 3 9428 1899
                                   jeanette.lodge@commercialeyes.com.au
                             Mark Glover:        +61 422 009 582
                                   mark.glover@commercialeyes.com.au
Questions, Comments or Follow up?

Joe Dodd
Tel: +61 3 9652 1605
Joe.dodd@fco.gov.uk

Jeanette Lodge
Tel: +61 3 9428 1899
jeanette.lodge@commercialeyes.com.au

Mark Glover:
Tel: +61 422 009 582
mark.glover@commercialeyes.com.au




                                       46

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Australia's Healthcare Market: Opportunities for British Medical Device Companies

  • 1. 1
  • 2. Australia – Healthcare Opportunities for British Business • 9.30 am Thursday 18th October 2012 • Speakers: – “Introduction to Australia & the Healthcare Market” Joe Dodd, Manager Trade & Investment, UKTI Melbourne – “The device market in Australia – some useful facts” Mark Glover, Manager Commercial Optimisation, Commercial Eyes – “How do I get my product registered?” Jeanette Lodge, Project Manager Regulatory Affairs, Commercial Eyes 2
  • 3. Australia – Healthcare Opportunities for British Business Joe Dodd Manager, Trade & Investment, British Consulate-General Melbourne 3
  • 4. Why Australia? • You’ll feel at home immediately: – Over 1,000 UK companies and more Brits than in any other country – Very similar business, legal and regulatory culture • Best performing OECD country economically, with good growth prospects • Strong Australian dollar making UK goods and services more affordable • Closely linked to fast growing Asia-Pacific nations • Well funded, growing healthcare market 4
  • 5. Australia – an economic snapshot Australia UK Population 22.5 million 62 million Global GDP ranking 13th 7th GDP growth est. 2012 3% 0.6% GDP per capita ($US 2011) $40,800 $36,600 Ease of doing business (World Bank 2011) 15th 4th Unemployment (Sept 2012) 5.1% 8% Land mass – sq kms 7 692 000 000 295 000 5
  • 6. UK/Australia trade links • UK exports to Australia grew by over 60% from 2007 - 2011 (to more than £10 billion) • UK’s overall exports contracted first half of 2012, to Australia rose • 7th biggest market for services exports and 18th largest for goods • UK is 2nd biggest foreign direct investor in Australia 6
  • 7. Australia – Country Background States: 6 states (parliaments are elected) and 2 territories (Chief Ministers are appointed by Federal Govt) Cities: Sydney 4.5 million Melbourne 4 million Brisbane 2 million Perth 1.6 million Adelaide 1.2 million 7
  • 8. Australian Healthcare Overview • Australia has well developed and well funded system, total expenditure around AU$100 billion per annum • 15th largest healthcare market in the world with growing and ageing population. • Rated as best healthcare market to do business in Asia Pacific looking at market size, opportunity & risk. • Forecasted to grow at 3.5% for next 5 years. 8
  • 9. Public System Overview • Public System run by combination of Commonwealth and State governments. • Commonwealth – policy, research, information, major initiatives. • States – delivery of public health services 9
  • 10. Hospital Distribution Hospitals by Public Private State NSW 226 173 Victoria 150 161 Queensland 170 106 Western Australia 95 55 South Australia 80 56 Tasmania 24 8 ACT 3 12 Northern Territory 5 2 FreeDigitalPhotos.net 10
  • 11. Funding System • “Medicare” – major part of funding system • Medicare Benefits Schedule provides fee for service to health professionals at point of care. • Public hospitals funded jointly by federal and state governments – managed by state governments. • Medicare levy 1% additional bill for individuals / families earning over certain level if they don’t take out private health cover. 11
  • 12. Private System • Federal government pays 75% of Medicare benefit schedule fee to private provider • Private health insurance will cover additional 25%, plus other associated costs such as accommodation. • 1,275 total hospitals in Australia of which 547 are private. • 45% of private hospitals run by not-for-profit groups including charities and religious bodies. • 55% for profit companies. • Ramsay Healthcare – 65 hospitals, <7000 beds, 28% of private beds in Australia. Also 33 facilities in UK • Healthscope – 47 hospitals plus pathology services. 12
  • 13. Aged Care • Around 3 million people of retirement age and older • $30 billion spend on aged care per year • Caring for an ageing population is an ongoing issue • Residential – mainly non-government providers but financed by Commonwealth government with subsidies paid to providers. • Residents may also pay care fees • Home and Community – both public and non-government with programmes of funding combining Commonwealth and State funds. • 50% providers are non-profit charitable organisations. 13
  • 14. How can UKTI Australia help British companies? • Carry out in-depth research on the market to your specifications • Find local distributors for your products • Arrange meetings with key potential clients • Help you attend trade fairs and missions • Product launches, industry seminars and PR and marketing support Joe Dodd • Whatever you need to succeed in the Tel: +61 3 9652 1605 Email: joe.dodd@fco.gov.uk market! 14
  • 15. 15 Opportunities for British Business “The Device Market in Australia Some useful facts” Mark Glover Commercial in confidence Commercial Optimisation 18th October 2012
  • 19. 19 Health Expenditure Commercial in confidence Source: Australian Institute of Health and Welfare, Health expenditure Australia 2009-10 @ current prices 19
  • 20. 20 Healthcare Funding in Australia -1 • Medicare – Is funded from taxation and subsidises healthcare for all Australians • Prescribed drugs, Rx from Doctors & Dentists, access to public hospitals • Pharmaceuticals – Subsidised via the Pharmaceutical Benefit Scheme $9.6B (£6.1B) – Patient contribution • General $35.40; Concessional $5.80 • Private Health Insurance – Patients choose Clinician and Hospital Commercial in confidence – Implantable Device reimbursement – Prostheses List – Selected extras • Optical, Dental, Well being 20
  • 21. 21 Healthcare Funding in Australia - 2 • Consumable medical technology – E.g. Rehabilitation Appliances, National Diabetes services, Continence Aids • Implantable Devices – Public Hospitals provides implantable, provide surgery, both restricted by Hospital / State budgets – National Procedure Banding Schedule covers theatre fees and consumables – Prostheses List – private insurers are required by law to pay benefits for a range of prostheses. Commercial in confidence – There are over 9,500 prostheses on the list in 3 categories • Part A – Prostheses • Part B – Human Tissue (includes products that are substantially derived from human tissue) • Part C – Non-implantable devices 21
  • 22. 22 Pharmaceuticals Process to gain PBS listing for registered products Commercial in confidence Source: Department of Health and Ageing, PBPA Policies, Procedures and Methods, 9th December 2011 22
  • 23. 23 PBS Growth – 10 years Commercial in confidence Source: From Discovery to Off-Patent: The Changing World of Medicines and Implications for Policymakers 22 nd Mrch 2012
  • 24. 24 What is a Medical Device A “medical device” is any instrument, apparatus, implement, appliance, implant, invitro reagent or calibrator, software, material or other similar or related material. a)Intended by the manufacturer to be used, alone or in combination, for human beings for one or more of the specific purpose(s) of: – Diagnosis, prevention, monitoring, treatment, or alleviation of disease – Diagnosis, monitoring, treatment, alleviation or or compensation for an injury – Investigation, replacement, modification, or support, of the anatomy or of a physiological process – Support or sustaining life – Control of conception – Disinfection of medical devices Commercial in confidence – Providing information for medical or diagnostic purposes by means of the in vitro examination of specimens derived from the human body And b)Which does not achieve its primary intended action in or on the human body by pharmaceutical, immunological or metabolic means, but which may be assisted in its intended function by such means 24
  • 25. 25 Device vs. Pharmaceutical Commercial in confidence Source: Medical Technology in Australia: Key Facts and Figures 2011
  • 26. 26 Changing needs for medical technology with Commercial in confidence Australia’s ageing population Source: Medical Technology in Australia: Key Facts and Figures 2011 26
  • 27. 27 Value of the medical technology industry in Australia • There is no official source of data • Total revenue 2009-2010 • ~ $7.6B (£4.9B) • ~ $8.4B (£5.4B) with in-vitro diagnostic (IVD) • ~ $9.2B (£5.9B) with IVD & Dental Commercial in confidence • Expected CAGR 9% over the next 5 years Source: Extrapolation of date from contracted provider. Medical Technology in Australia: Key Facts and Figures 2011 27
  • 28. 28 Classification of medical technology Commercial in confidence companies in Australia Source: Data from 240 companies in the MTAA database. Medical Technology in Australia: Key Facts and Figures 2011 28
  • 29. 29 Categorisation of medical Commercial in confidence technology items on the ARTG Source:.Medical Technology in Australia: Key Facts and Figures 2011 29
  • 30. 30 How do I get my product registered? Jeanette Lodge Project Manager – Regulatory Affairs Commercial in confidence 30
  • 31. Agenda • Regulatory framework • Local sponsor responsibilities • Summary of legislation & guidance • Comparison EU v AUS • What is the same? • What is different? • Some TGA specific requirements • Cost and Timelines • TGA Reforms • Post-market requirements • New Zealand
  • 32. Regulatory Framework • Therapeutic Goods Administration (TGA) • Department of Health and Ageing • Regulate medicines, biologicals and medical devices • ARTG • Administers the TG Act 1989 • Devices loosely regulated 1991 > • Act revised in 2002 (to 2007): risk classification • Global Harmonisation Task Force (GHTF) • Office of Devices Authorisation • Ms Andrea Kunca • Reforms ongoing (see later) • Industry association - MTAA
  • 33. Local Sponsor Responsibilities • Located in Australia (legally responsible) • Procedures & agreement with Manufacturer* • Ensure manufacturer: • complies with Essential Principles (declaration) • Applies an appropriate conformity assessment procedure • Holds current conformity assessment evidence • TGA eBS (e Business Services) account • Regulatory Applications to TGA (see later) • Pay fees and annual charges (see later) • Post market requirements (see later) * May also be the sponsor
  • 34. Legislation & Guidance • The Therapeutic Goods Act 1989 ‘The Act’ • The Therapeutic Goods Regulations 1990 • The Therapeutic Goods (Medical Devices) Regulations 2002 (the Regulations) • Guideline: Australian Regulatory Guidelines for Medical Devices (ARGMD) • Additional guideline for boundary products • Relevant state legislation and customs requirements may also apply
  • 36. What is the same? • Basis in GHTF procedures and TGA framework based on EU MDD/AIMDD • TGA has signed MRA with EU and EFTA for several industry sectors, including medical devices • Definition of medical device (accessory also a medical device in Australia) • Device Classes (although classification may vary) • Conformity Assessment Procedures are closely aligned, except for CE Marking process (MDD/AIMDD Annex II to VII = TGA Device Regs 2002 Schedule 3, Parts 1 to 6 – refer TGA table)
  • 37. What is different? EU Australia EU MDD/AIMDD TG Act and Regulations 18 Classification Rules 5 Classification Rules One Class III; Class I ‘Straight’ v ‘Special’ Class III (e.g. medicine, with animal ingredient human, animal, microbial, recombinant) Essential Requirements Essential Principles (e.g. device specific, (e.g. software validation clinical requirements, English labelling/ more stringent) packaging/IFU, other) CE Certification and CE Mark not required, EC Certificate marking accepted under MRA for some devices EU DoC TGA DoC
  • 38. What is different? EU Australia Labelling to include authorised Must include local sponsor name and representative or importer address as well as manufacturer details details Hip, Knee, Shoulder - Class III Transitioning from Class IIb to III (current TGA reforms) CNS contact – Class III Transient use - Class I to IIb; Short, long-term, implantable - III Definition of circulatory system Definition includes common iliac does not include common iliac arteries, therefore some Class III in arteries Aus not EU Separate IVD Directive IVD are subset of medical devices See also TGA website: ARGMD Section 8
  • 39. TGA Specific • TGA Applications: • Lodge manufacturer’s evidence (and periodic updates) • Submit product inclusion application (and any ‘substantial’ changes) • Lower risk products: EC Certificate: Random application audit • Higher risk products: mandatory application audit unless EU or EFTA MRA certificate of conformity can be supplied • Special products: TGA Conformity Assessment audit • Design and type examination: not suitable manufacturers evidence • Grouping under Section 41BE • Class III: UPI plus variants • Formulated devices: ‘random’ audit always conducted • Pay or delay!
  • 40. Cost & Timelines Item Cost (AUD) Timeline Manufacturer’s Evidence nil 1 to 4 weeks TGA Conformity $870 plus $19,400 to 6 to 12 months + assessment $51,200 Class I Inclusion nil Automatic Class Im/s to AIMD $890 to $1,150 4 weeks to decision Inclusion or audit request Application audit nil, $3,360 or $6,170 30 or 60 days + Substantial variations $390 plus $11,800 to Varies with change $30,800 Annual charges $70 to $1,150 N/A
  • 41. TGA Reforms • Increased rigor with assessment of higher risk devices • Four proposed changes (Nov 2010 consultation): • Joint reclassification – in progress • Use of third party assessment bodies • Transparency around grouping • Publication of product details on TGA website
  • 42. Post Market Requirements • Manufacturer v Sponsor responsibilities • May delegate activities by written agreement, but responsibility lies with manufacturer or sponsor • Requirements include: • Adverse event reporting (device monitoring & vigilance), device tracking (maintain audit trail, TGA sampling, inspection or ‘desk-top’ audit) • Recall Procedures • Application for low-volume turnover (LVT)
  • 43. New Zealand • ANZTPA • ‘Piggy-backs’ on TGA process • Medsafe notification required within 30 days of supply of new device • Notification via WAND • Web Assisted Notification of Devices • Can clone TGA eBS details to WAND (although databases no longer linked) • Devices containing medicine component are regulated as medicines
  • 44. Commercial in confidence Where we can help……. 44
  • 45. 45 Commercial Eyes "We take the complexities out of commercialisation so that your products can achieve their full potential" www.commercialeyes.com.au Commercial in confidence Jeanette Lodge: +61 3 9428 1899 jeanette.lodge@commercialeyes.com.au Mark Glover: +61 422 009 582 mark.glover@commercialeyes.com.au
  • 46. Questions, Comments or Follow up? Joe Dodd Tel: +61 3 9652 1605 Joe.dodd@fco.gov.uk Jeanette Lodge Tel: +61 3 9428 1899 jeanette.lodge@commercialeyes.com.au Mark Glover: Tel: +61 422 009 582 mark.glover@commercialeyes.com.au 46