Medical Device Blog – QA & Regulatory Updates from Emergo Group

As medical device quality assurance and regulatory affairs professionals, it can be challenging to stay on top of changes happening in our industry. Few people have the time to read lengthy articles these days and although many online newsletters exist, they are often packed with PR releases, ads or unrelated information. That\'s why we started this blog for QA/RA professionals in the medical device and IVD industry. The idea is to give you short updates on quality and regulatory topics that may be of interest to you. No fluff, just straight to the point. We hope you\'ll enjoy the content.

European Med-Tech Trade Groups Join Forces

European medical technology association Eucomed and the European Diagnostic Manufacturers Association (EDMA) are forming a single industry trade federation to more effectively lobby on behalf of their medical device and IVD manufacturing members.

The associations will name a joint chief executive to oversee activities and develop organizational strategies; however, Eucomed and EDMA will continue to operate as separate legal entities. Furthermore, the new joint federation is open to membership for other European industry trade groups, as well.

A top priority in the short term for the federation will be cooperating with EU policymakers hammering out a new regulatory framework for medical devices.

EDMA Study: European IVD Market Stagnating

A new report examining European in vitro diagnostic (IVD) market performance in 2010 sees flat or negative growth across most major EU member states due to cost containment measures and worsening economic conditions.

According to the European Diagnostic Manufacturers Association’s (EDMA) study, the European IVD market totaled €10.5 billion last year, with revenue growth of only two percent from 2009. Cardiology testing and diabetes-related IVD sectors as well as products for managing hospital-acquired infections showed the strongest growth rates in 2010, but all other testing areas showed flat or negative growth.

EMDA attributes these rates to European governments’ placing of limitations on IVD testing volumes and reimbursement to balance budgets. (Efforts by governments to implement ill-conceived austerity measures are also not helping.)

Germany remains Europe’s largest IVD market, but IVD revenue growth there was -0.01% in 2010 following a decision by the Federal Joint Committee to end reimbursement for some diabetes-related tests via statutory health insurance.

In France, new laws allowing consolidation of private laboratories also boosted procurement consolidations in 2010. Growth in the glucose self-testing segment totaled 6.4%, but all other IVD segments remained flat over the same period. Price decreases, Cost per Reportable Result (CPRR) efforts and more demanding customers all affected poor growth rates overall, according to EDMA.

The Italian IVD market showed modest growth (1.1%) last year, but late payments of as many as 700 days plagued the region; the market in Italy will likely face greater challenges as the country’s economy worsens.

Spain’s IVD market also grew slightly in 2010, by 0.5%, but EDMA expects pricing pressures to make Spanish market conditions more challenging for IVD manufacturers.

The UK has no official IVD reimbursement system in place, but cost containment efforts there have nonetheless driven laboratory consolidations. Efforts to contain the National Health System’s budget are also drawing more private-sector providers into the British IVD market.

It is difficult to see European IVD growth rates improving substantially going forward, as Continental governments large and small continue tightening health care-related budgets under the questionable assumption that austerity will stave off recession. 

HC Extends Premarket Review E-Submission Program to Class III Devices

Starting November 1, 2011, Health Canada will extend a pilot program requiring both paper and electronic submissions of premarket review documents for Class IV medical devices to Class III devices, as well.

According to a new HC guidance for industry, the pilot program’s extension to Class III applications are part of the regulator’s ongoing transition to accepting stand-alone electronic submissions. The guidance covers medical device license applications as well as medical device license amendment applications for Class III and IV medical and in vitro diagnostic devices. The program also applies to documents including Screening Deficiency Letter responses, Clarification Requests and Additional Information Letters associated with premarket review submissions.

The HC guidance lists file and data formatting, naming and structuring requirements and suggestions, and also requires letters of attestation from manufacturers verifying that the content of their electronic submissions matches that of their paper filings.

Electronic premarket review submissions will help expedite the device review process, HC argues, and improve data management as well.

Mexico to Ease IVD Registration Process

Mexican medical device regulators plan to establish simplified registration for in vitro diagnostics and other low-risk products, and to exempt another 1,700 health products from medical device registration requirements altogether in an effort to increase market competition, improve public health and boost job creation.

According to officials at COFEPRIS (document in Spanish), the regulator’s moves are based on methods endorsed by the Federal Regulatory Improvement Commission (COFEMER) and recommendations from the Organization for Economic Cooperation and Development (OCDE).

Along with IVDs, COFEPRIS plans eased registration for hygienic products, healing products and dental supplies. As for the 1,700 products that will no longer require registration as medical devices, COFEPRIS will publish a list of these goods in August on its website, www.cofepris.gob.mx.

Simplified registration requirements for IVDs should boost the Mexican market’s appeal for IVD manufacturers looking to expand into new markets. Emergo Group will continue to monitor the situation for further details.

 

Markets: MexicoTags: COFEMER, COFEPRIS, IVD, Mexico, OCDE

Code of Conduct for Notified Bodies Goes Public

Notified Bodies BSI, TÜV Rheinland, TÜV SÜD, LNE-GMED and DEKRA/KEMA have made public a code of conduct they drafted earlier this year in accordance with Directives 90/385/EEC and 93/42/EEC.

Although a majority of the Association of Notified Bodies members endorsed the Code of Conduct for Notified Bodies, the document did not garner enough support to become a condition of membership in the association. The Code was developed in response to concerns regarding notified body competency among EU regulators, governments and industry trade groups, according to BSI.

Although the Code was just published in recent weeks, the five notified bodies (the NB5) authoring the document plan to begin work on an “improved” version for release in October, with the goal of maximizing the adoption rate of the Code among European notified bodies.

In the current Code, the NB5 reaffirm their accountability to Competent Authorities, and their obligations to comply with all international standards, laws and regulations of member states.

The NB5 also identified various issues left out of the latest version of the Code, which they acknowledge renders the document incomplete in terms of covering all Notified Body activities. Issues to be addressed in the next version of the code include incorporating the IVD Directive, defining requirements for reviews of devices using animal or human materials, and addressing the Conformity Assessments laid out in MDD Annex III and AIMD Annex 3 (Type Examination), and also MDD Annex IV and AIMD Annex 4 (Batch Certification).

The extent to which those issues are addressed in the next iteration of the Code will no doubt help determine how influential this effort by the NB5 ultimately proves.

Recast of EU’s Hazardous Material Regulations to Impact Medical Devices

The European Union’s Restriction on Hazardous Substances (RoHS) Directive covering electronic devices will soon also cover medical devices.

The law has been fashioned to improve collection and recycling rates of electronic devices across the EU, as well as to cut down on illegal exporting of electronic waste products from the EU.

According to a Massdevice.com report, medical devices and IVD products had previously been exempted from the RoHS, but that exemption will not be extended except for active implants. As such, medical devices and monitoring and control instruments will have three years to comply with RoHS following the directive’s adoption; IVD products will have five years to comply.

The law has been fashioned to improve collection and recycling rates of electronic devices across the EU, as well as to cut down on illegal exporting of electronic waste products from the EU.

The European Parliament adopted the text of the RoHS recast late last year; MassDevice.com cites reports from BSI that final approval of the law is imminent.

The RoHS currently restricts lead, mercury, cadmium, hexavalent chromium, PBB and PBDE; according to BSI, the directive’s list of restricted substances is likely to expand. 

EU: Broad Support for IVDD Revisions

Comments following European Union regulators’ public consultation on proposed revision to Directive 98/79/EC indicate strong support for adopting a risk-based classification for in vitro diagnostic devices (IVDs).

Among 116 manufacturers, notified bodies and other medical device industry stakeholders that provided comment, 93% of respondents saw the adoption of risk-based IVD classification based on the Global Harmonization Task Force (GHTF) model as a positive development, allowing for greater flexibility, stronger public health protections and timely market access for new products.

The cost of such a reclassification, however, was also highlighted by some respondents. Specifically, classification according to GHTF standards would necessitate greater regulatory involvement to handle conformity assessment procedures. In turn, manufacturing costs would increase, ultimately driving up prices for end users as well.

Nonetheless, respondents noted that additional costs would likely be offset by improved public health protections, and suggested a five-year transitional period for manufacturers to adjust to the new risk-based classification and its ensuing requirements. In addition, a risk-based IVD classification incorporating the GHTF model would boost European exports, some participants stated, but only if such classification were based on that model—otherwise, additional regulatory costs would not be offset by any financial benefits.

At this point, the EU Commission may discuss and consider these comments and then provide a draft which will likely include GHTF classification rules.

If EU regulators end up adopting these classification rules, Europe will become the second major market after Australia to implement GTHF risk-based classification rules for IVDs.

Certain IVDs Now Subject to Application Audits by Australia’s TGA

The Therapeutic Goods Administration (TGA), Australia’s medical device regulator, has specified which in vitro devices (IVDs) will be required to undergo application audits.

According to Australia’s Therapeutic Goods (Regulations) 2002, eight types of IVDs fall under the application audit requirements:

  • Non assay-specific quality control materials for monitoring Class 4 IVDs
  • IVDs for self-testing applications
  • IVDs for point-of-care testing
  • Class 3 IVDs for detecting sexually transmitted agents
  • IVDs to monitor treatment of infections diagnosed with Class 4 devices
  • IVDs supplied for use according to the pharmaceutical benefit scheme
  • IVDs used in national screening programs
  • IVDs whose original manufacturing evidence does not fully satisfy Australian conformity assessments

IVD manufacturers and their sponsors whose products do not qualify for the mandatory audit requirements, however, should not consider themselves off the hook. The TGA also has the authority to select applications for such devices for non-mandatory audits, as well. In either case, the TGA will send written request to the sponsor for information necessary to conduct the application audit.

An application audit by the TGA will entail review of a manufacturer’s technical documentation; any data or documentation deemed by the regulator to be relevant to demonstrable compliance with safety and performance Essential Principles, conformity assessment procedures or advertising or supply information is fair game.

Sponsors should not submit application audit documentation until the TGA formally requests that information, advises the regulator’s website.

Taking advantage of elabeling for IVD companies

In 2007 the European Commission released MEDDEV 2.14/3 REV 1 which opened the door for IVD companies with professional use products to place their Instructions for Use (IFU) online instead of placing multilingual paper inserts inside product packaging. That could be a huge cost savings to some IVD companies  but one key requirement makes it difficult for IVD companies to take advantage of elabeling. The MEDDEV stipulates that companies must provide a toll-free number in every European country where the product is sold. That's a big challenge since there is no real pan-European toll-free phone number. However, we thought that you might be interested in knowing that one of our partners offers a reasonably priced elabeling service for IVD companies.

Markets: EuropeCategories: Regulatory ComplianceTags: eLabeling, IVD