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    Medical device safety and

    RegulationsBy: Yassir Eltayeb Ali Hassan

    http://www.inquisitr.com

    www.brokerbanksecurities.com

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    Medical device safety and

    Regulations

    Objectives of the lecture

    1. Know the definition and classifications of medical device

    2. Know the Risks associated with medical devices

    3. Describesthe nature of medical device safety as a riskmanagement process

    4. Know the life span of medical devices from their

    conception to disposal

    5. Know the Participantsin ensuring the safety of medicaldevices

    6. Know common framework for medical device regulations

    , regulatory tools and general requirements

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    Medical device

    Medical devices are manyand varied in regardto

    compositionand complexityand may be instruments,

    apparatuses, software, material or other articles.

    Definition

    Medical device means any instrument, apparatus,appliance, software, material or other article, whether

    used aloneor in combination, together with any

    accessories, including the software intended by its

    manufacturer to be used specifically for diagnostic

    and/or therapeutic purpose and necessary for its

    proper application, intended by the manufacturer to

    be used for human beings.

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    Medical device

    Medical devices do not achieve their principal

    intended action in or on the human body bypharmacological, immunological, or metabolic

    meansbut may be assisted in their function by

    such meansmedical devicesact by other means like

    physical, mechanical, or thermal

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    Me ca ev ce purposesMedical device are intended by

    the manufacturer to be used for

    human beings for one or more of

    the specific purposes :

    1. Diagnosis,prevention,

    monitoring, treatment or

    alleviation of disease(Cope/

    Deal with human disease)

    2. Diagnosis, monitoring,

    treatment, alleviation of or

    compensation for an injury

    (Care for human injuries)

    3. Investigation, replacement,

    modification, or supportof the

    anatomyor of a physiological

    process (Meet human

    4. Supportingor sustaining life

    (Maintain human physiological

    functions.)5.Controlof human conception

    6. Disinfectionof medical device

    7. Providing information for

    medical purposes

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    Medical device groupsThe standardsaddr

    essesseveral groups of medical devices.

    The groups are as follows:

    1. Generalmedical device.2. Active medical device.

    3. Activeimplantable medical device.

    4. Implantable medical device.

    5. In vitro diagnostic device.

    6. Non-activemedical device.

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    Medical device groups

    General medical device

    Any instrument, apparatus, appliance, material, or otherarticle, whether used alone or in combination, including the

    software necessary for its proper application, intendedby the

    manufacturer for human use for thepurpose of: diagnosis,

    prevention, monitoring, treatment, or alleviation of disease

    Active medical device

    Any medical device relyingfor its functioning on a source of

    electrical energy or any source of power other than thatdirectly generated by the human body or gravity.

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    Groups of medical devices.An active implantable medical device(AIMDs)

    Any active medical device which is intendedto be totallyor

    partiallyintroduced, surgicallyor medically, into the human

    bodyor by medical instrumentation into a natural orifice, and

    which is intended to remainafterthe procedure

    Examples of AIMDs

    1. bladder stimulators

    2. cochlear implants

    An implantable medical device

    Any medical device intended: to be totallyor partiallyintroduced into the human body or a natural orifice, or to

    replace an epithelial surface or the surface of the eye by surgical

    intervention, which is intended to remain after the procedure

    for at least 30 days and which can only be removed by medical

    or surgical intervention.

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    Groups of medical devices.

    An in vitr o diagnostic device

    Any device which is a reagent, reagent product, kit,

    instrument, equipment, or system, whether used

    alone or in combination, intended by the

    manufacturer to be used in vitro for the examinationof samples derived from the human body with a view

    to providing information on the physiological state.

    A non-active medical device

    Any medical device which is neitheran active

    medical device noran in vitro diagnosticdevice

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    Electromedical devices are different from universal

    electric appliances

    1. Because they are intended to alleviate or heal apatients disease

    2. Enablehis/her further survival.

    3. Have to interact with patients body

    4. Have to be introducedintothe patients body

    5. Remain even for long periods in direct contact

    with the body

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    Demarcation

    1. Personal protective devices: X-ray skirts ,Gloves

    2. Cosmetics ; dental brushes

    3. Universal products; general power supply units

    supplying medical devices

    4. Multipurpose disinfectants: disinfectants

    dedicated to medical devices such as endoscopes

    or contact lenses, are medical products.

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    Demarcation aspects

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    International Electro medical Commission (IEC)

    Responsibility for medical electrical equipment

    standards is within the purview of Technical

    Committee

    The IEChas developeda series of safety standards

    and regulations specifically for electro medicalequipment.

    The IEC defines medical electrical equipment in

    IEC 60601-1

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    Medical device classes

    Classi f ied by IEC depending on:-

    Methodical risk

    Invasiveness

    (uninterrupted) contact time

    Way of interaction with the patient

    Classes :

    1. class I no or insignificant risk

    2. class IIa small risk

    3. class IIb elevatedrisk

    4. class III highrisk

    Classification is performedby themanufacturer himself

    based on product characteristics, intended purpose and

    intended use as defined by him

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    e ca ev ce c asses

    Exampleofhow

    cla

    ssificationisdo

    ne

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    Class I and class II DevicesClass I:-

    Non-life sustaining devices, whose failure posed no risk to life, and

    thus required no need for performance standards .

    Examples

    Tongue depressors and stethoscopes

    Class I I devices :-also non-life sustaining devices, they must meet specific controls

    or performance standards.

    Examples of class I I devices:-

    physiologic monitors, X-ray machines, gas analyzers, bloodpressure cuffs, oxygen masks, infusion pumps, electrically

    powered wheelchairs

    www.robertburridge.com

    l

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    Class III Devices

    Class I I I Devices

    They are supporting life so that their failure is lifethreatening

    Examples of class I I I medical devices are :-

    1. replacement heart valves

    2. Pacemakers

    3. Defibrillators

    4. drug -eluting stent

    A li d P t

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    Applied PartA partof the equipment which in normal use:

    1. Comes into physical contactwith the patient

    2. Can be brought into contact with the patient

    3. Needs to be touchedby the patient

    Types of the applied parts:-

    1. B

    2. BF

    3. CF

    Type B

    Type B is the least stringent classification, and is used for

    applied partsthat are generally not conductive and can be

    immediatelyreleasedfrom the patient.

    A li d P

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    Applied Part

    Body floating BF

    For devices that have conductive contact with the patient, orhave applied parts that are fixed in medium or long term

    contact with the patient, e.g. ECG electrodes

    Cardiac f loating

    Type CF is the most stringent classification, being required for

    those applications where the applied part is in direct conductive

    contact with the heart.

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    Which requirements must be met(in medical device) ?

    1. acceptable risk/benefit ratio; the manufacturermust

    implementa risk management process

    2. The MD must achieve the medicalperformance intended by

    the manufacturer

    3. The MD must be designed and constructed in conformity

    with generally acknowledged state of the art of science and

    technology and following the principles of integrated safety

    4. The MD must meet requirements 13 during their whole

    expected lifetime.

    5. The MD Must fulfill their intendedcharacteristics and

    performance also after storage and transport.

    6. The MD must be accompaniedby all informationrequired forsafe useduring the intended lifetime

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    Risks in medical devices

    1. Electrichazards

    2. Physicalhazards3. Biologichazards due to over dosage of highly

    effective drugs

    4. Hygienic hazardsby transmitting pathogenic germswhen touching contaminated parts

    5. Functional hazards through inaccuracies, malfunction

    and/or breakdown

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    Medical device safety

    To reach optimumassurance of MD safetywe must

    consider several essential elements:1. Absolute safety cannot be guaranteed

    2. Safetyis a risk management issue3. Safety is closely aligned with device

    effectiveness/performance

    4. Safety must be consideredthroughout the life span of

    the device5. Safety requires shared responsibility among the

    stakeholders

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    Medical device safety and risk management

    Hazard is a potential for an adverse event, a sourceof

    dangerRiskis a measure of the combinationof

    1. The hazard

    2. The likelihood of occurrence of the adverse event3. The severity or overall impact.

    Risk assessment:

    Begins with risk analysis to identify allpossible hazards

    Followed by risk evaluation to estimatethe risk of each

    hazard

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    Risk management process

    According to ISO 14971

    This should assurethat risksof a device will sufficiently

    be managedby:-

    Systematic risk analysis

    Risk assessment

    Risk evaluation

    Risk reduction

    Risk monitoring including risks caused by a usersmisuse, mistake or ignorance

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    Risk assessmentThe current approach to device safety is to estimate the

    potentialof a devicebecoming a hazard that could result insafety problems and harm

    Risk assessmentisbased on:-

    1. Experience.

    2. Evidence.

    3. Computation.

    4. Guesswork (An estimate based on little or no

    information).

    Ri k t

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    Risk assessment

    Risk assessment is complex, as it can be influenced by:-

    1. Personalperception / knowledge2. Cultural background.

    3. economicconditions, and political climates.

    In practice, risk assessment of medical devices is based on:-1. The experienceof health careprofessionals

    2. Safety design engineering

    Ri k t d l ifi ti

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    Risk assessment and classification In the United States, governmental risk assessment of

    medical devices is based mainly on recommendations

    from members of 16 medical specialty panels, and devicesare categorized into three classes.

    The European Union and Canada categorize medical

    devices according to theirperceived potential hazards1. Canada assigns four classes of devices based on the level

    of risk class I, II, III, and IV

    2. The European Union assigns three classes with class II

    being sub-divided into IIa and IIb

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    Risk assessment and classification

    In classifying devices, potential areas of hazard

    that needs consideration include:-

    1. The degree of invasiveness

    2. Durationof contact

    3. Thebodysystem affected

    4. local versus systemic effects

    Ri k l i

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    Risk analysisManufacturers need to adopt measures that can identifyand

    quantifyrisks.

    Twocommon techniquesare used for identifyingrisk:-

    1. Fault Tree Analysis (FTA)

    2. Failure Mode Effect Analysis (FMEA)

    FMEA approach

    Considerationis given to what would be the end-consequence

    of failure of a component or element of the device

    Fault Tree Analysis approach

    Considers a fault in the devices and asks what are the

    different causes that could result in the failure

    /

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    Risk/Benefit nature of medical devicesMedical devices should be designed and manufactured in

    such a way that:

    1. When used under the conditions and for the purposes

    intended with technical knowledge, experience,

    education or trainingof intended users, they will not

    compromisethe clinical condition or the safety andhealthof (patients and users )

    2. Risks which may be associated with their use constitute

    acceptable risks when weighed againstthebenefits

    Ri k M t P Fl h t

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    Risk Management Process FlowchartRisk management planning

    Risk analysis

    Risk evaluation

    Risk control

    Evaluation of overall residual risk

    Risk management reporting

    Production /post

    production informationcollection

    The (ISO) has produced a document

    (ISO 14971:2000) providing

    manufacturers with a frameworkIncluding:-

    1. Risk analysis

    2. Risk evaluation

    3. Risk control

    This framework is for :-1. Risk management in medical

    device design, development,

    and manufacturing

    2. Monitoring the safety and

    performance of the device after sale

    l

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    PDCA Cycle

    Plan

    Do

    Check

    Act

    Always remember this

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    Effectiveness/performanceof medical devices

    A device is clinicallyeffective when itproducesthe

    effect intendedby the manufacturer relative to the

    medical condition

    Clinical effectiveness is a good indicatorof device

    performance

    Performance,may include technical functions inaddition to clinical effectiveness.

    Performanceis closely linkedto safety

    Example:-A patient monitor that does not perform well couldpose

    serious clinical safety problems to the patient. Thus, the

    safety and performance of medical devices are normally

    considered together

    Phases in the life span of a medical device

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    Phases in the life span of a medical deviceThe major phases in the life span of a medical device from

    conceptionand development to disposal

    1. Conceptionand development

    2. Manufacturing

    3. Packaging and labelling

    4. Advertising

    5. Sale

    6. Use

    7. Disposal

    Ph i h lif f di l d i

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    Phases in the life span of a medical deviceConception and development

    The scientific principles upon which a device is based are fundamental

    to its safety and performance

    For example, a cardiac pacemakershould deliver a minute electrical

    impulse of a certain size and shapethat simulates the natural

    functioning of the heart. Significant deviationfrom this may

    compromise safety and performance

    Manufacture

    Good, functional medical devices areproducedwhen the manufacturing

    processis adequatelymanaged

    GMP is more commonly referred to as quality systems in

    manufacturing

    Phases in the life span of a medical device

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    Phases in the life span of a medical device

    Packaging and labelling

    The importance of well-designed Packaging systems in deliveringclean,

    sterile and protected medical devices is granted by:-

    1. Properly packaged ; this will Cause little risk to individuals handling

    them, even if the MD isbiohazardous.

    2. Properly Shipping; aMD and its packaging must survive because

    damage can result during transportation and handlingunless the total

    packaging system is designed robustly and can withstandvarious

    stresses.

    3. Well-sealed packaging is essential for those medical devices that

    must be maintained sterile.

    4. Labelling; is crucialin identifyingthe medical device and

    specifyinginstructionsfor itsproper use.

    5. Putting hazard warnings,cautionsand clear instructions.

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    P ases in t e i e span o a me ica evice

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    P ases in t e i e span o a me ica eviceAdvertising

    Advertisement has thepotentialto create expectations andpowerfully

    influencethebelief/ impression in a medical devices capabilities

    medical device marketing and advertisingare regulatedtoprevent

    misrepresentation of a medical device and its performance

    Sale

    The sale of medical devicesby the vendor is a critical stage that leads tothe device beingput into actual use.

    If the vendor is not subject to regulation, then there is higher riskof

    exposingthepublicto low quality or ineffective devices.

    DisposalDevices that are contaminated after use (e.g. syringes) or devices that

    contain toxic chemicals, can present hazards to people or the

    environment and mustbe disposed of properly.

    Participants in ensuring the safety of medical devices

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    Participants in ensuring the safety of medical devices

    1. The manufacturer usually manages the first three phases

    of the medical devices life span

    2. The Vendor includes importers, distributors, retailers andmanufacturerswho sellmedical equipment

    3. The User is usually aprofessionalin a health care

    facility, but may also be thepatients.4. The Public/Patient and the Governmentare also key

    interested parties

    Thepublicare the ultimate beneficiary of medical devices

    while the government has the responsibilityof overseeingthat medical devices sold in the country are safe and

    effective.

    R ibilit f P ti i t

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    Responsibility of Participants

    CONCEPTION

    AND

    DEVELOPMENT

    MANUFACTURE

    PACKAGING

    AND

    LABELLING

    ADVERTISING

    SALE

    USE

    DISPOSAL

    VENDOR USER

    Manufacturer

    The role of the manufacturer

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    The role of the manufacturer

    The manufacturer

    As the creator of the device, must ensurethat it ismanufacturedto meet or exceed the required standardsof

    safetyandperformance

    This includes the three phases:-1. Design/development/testing

    2. Manufacturing

    3. Packaging and labelling

    product being ready for the market

    The role the vendor

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    The role the vendor

    The vendor should:-

    1. Ensure that theproductssold comply/ followwith regulatory

    requirements

    2. Avoidmaking misleadingor fraudulent/deceitfulclaimsabout

    their products

    3. Avoid issuing false compliance certificates

    4. Clearly labelled the refurbished/ reneweddevices

    5. Provideafter-saleservice

    6. Maketraininga condition to the manufacturer or importer in

    accepting to sell the device7. Take responsibility in supportingor training their customers

    8. Participating inpost-market surveillance

    The role of the user and the public

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    The role of the user and the public

    The user should make sure that

    1. He has qualifications and trainingin theproper use of the device2. He is familiar with the indications, contra-indicationsand operating

    proceduresrecommended by the manufacturer

    The public

    They should:-

    1. Be fully aware that all devices carry a certain risk

    2. Promotesafetyand performancethrough:-

    I. Self education

    II. Putting customer pressure on manufacturersto comply with

    standards.

    The role of the government

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    The role of the government

    The government

    Has the responsibility to:-1. Ensure that medical devices sold or made available in the

    country are safe and effective.

    2. Provide leadership in creating healthy cooperation

    among stakeholdersin establishingpolicies and

    regulations that are fair and clearto all.

    Policiesand regulationsshould be reviewed periodically

    to respondto changesin technologiesby makingappropriate (amendments/ corrections).

    overall safety of Electromedical devices

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    overall safety of Electromedical devices

    1. Device safety (constructive safety and functional safety);

    2. Safe application (with consideration of users knowledge,

    foreseeable errors and misuse)

    3. Safe supply (safe electric installation and reliable power

    supply);

    4. Safe disposal (environmentally conscious design and waste

    management).

    Good service or good intended purpose

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    A common framework for medical device regulations

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    Governmental regulation

    of medical devices

    Critical elements for regulatory attention

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    Critical elements for regulatory attention

    PRODUCT USE

    The safety and performance of medical devices depend on two

    critical elements

    Product

    representation

    The third critical element

    Definition of standard

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    Definition of standard

    What are standards

    Standards are documented agreements containing technicalspecificationsor other precise criteria to be used consistently as

    rules, guidelines or definitions of characteristics, to

    ensure that materials,products, process and services are fit for their

    purpose.Types of specifications in standards

    1. Prescriptivespecifications

    2. Design specifications

    3. Performancespecifications

    4. Managementspecifications

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    Purposes of Standards

    1. Provide reference criteria

    2. Provide informationthat enhances safety, reliability and

    performance of products, processes and services

    3. Assure consumers about reliabilityor other characteristics of

    goods or services provided in the marketplace.

    4. Giveconsumers more choice by allowing one firms products

    to be substituted for, or combined with, those of another.

    Wh t i th diff b t t d d d l ti ?

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    What is the difference between a standard and a regulation?

    Regulation

    A Rule that we must follow

    Rules that the Government makes under an Act

    Rules are made real and enforceable by the power that the Government

    gives itself under an Act e.g. Health & Safety Act Regulation for Hearing

    Protection

    Standards

    Not written by Government

    Are written by organizations such as CSA, ANSI, CGSB, etc.

    Typically refer to product performance or how to do a jobHave no authority on their own, but may be adopted into regulations making

    them legal requirements

    May be referred to specifically in a regulation or through a General Duty

    Clause

    Regulatory bodies may adopt all or a part of an existing standard

    References

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    References1. Higson, G. R., & Publishing, I. of P. (2002). Medical device

    safety The Regulation of Medical Devices for PublicHealth and Safety. London: IOP Publishing Ltd 2002.

    2. Tobin, J. J., & Walsh, G. (2008). Medical Product

    Regulatory Affairs Pharmaceuticals, Diagnostics,Medical

    Devices. Weinheim: WILEY-VCH Verlag GmbH & Co.KGaA.

    3. Leitgeb, N. (2010). Safety of Electromedical Devices Law

    RisksOpportunities. Leipzig: Springer-Verlag/Wien.4. World Health Organization - WHO. (2003). MEDICAL

    DEVICE REGULATIONS Global overview and guiding

    principles. Geneva

    d l d l ff

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    Medical Product Regulatory Affairs

    R l ti

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    Regulations

    Regulation of medical devices is intended to protect

    consumer'shealth and safetyby attempting to ensure

    that marketedproducts are effective and safe

    Standards establish basic requirements for safe

    development and implementationof medical devices,minimizingthe riskcaused to the patients when used.

    The new device must beprovennot only safebut also

    effectivein curing a specific disease

    Regulatory bodies

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    Regulatory bodies

    Food and Drug Administration (FDA) in the United

    States

    European Commission (EC) in Europe

    FDA toregulate nearly every aspect of medicaldevices, from testing through marketing

    Medical Product Regulatory Affairs

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    Medical Product Regulatory AffairsThe medical product regulatory affairs aimsto introduceand overview the regulatory affairs framework governing

    thedevelopment,approval, manufacturing and surveillanceof bothpharmaceuticalsand medical devices

    Purpose and Principles of Regulation

    The fundamental purpose of regulation is theprotection ofpublic health.

    Regulation try to insures:-

    1. Safe construction of equipment

    2. safe installation3. Instruction and training of users (safe use)

    4. Regular and careful maintenance (safe use +excellent performance )

    principles and concepts of Regulation

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    principles and concepts of Regulation

    1. Safety2. Efficacy

    3. Purpose

    4. Risk/benefit ratio

    5. Quality

    The core principles and concepts are :-

    To achieve their goal, the regulations rely on a

    number of core principles and concepts

    Product safety

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    Product safety

    Product safety

    Is an underlying principle for all products.Ideally, the product should do no harm

    Thus, the regulations requirethat the

    developeror manufacturer must take appropriate

    steps to demonstrateand ensurethe safety of the

    productunder development

    Efficacy /effectiveness and Risk/benefit

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    Efficacy /effectiveness and Risk/benefit

    To evaluate effectivenessyou must also considerthepurpose of the product as expressedin either an

    indications for use statementin the case of drugs, orintended use statementin the case of medical devices

    Risk/benefit

    you will have to apply the concept of Risk to Benefitwhenmaking ajudgment whether a product should be marketedand what limitations should apply to its use.

    from a regulatory point of view you must ask thesequestions:

    1. Do the benefits outweigh the risks

    2. Does the product enhance public health (the overallbalance)

    Risk benefitE l

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    Example:-Chemotherapy drugs used to fight cancer are known to be have

    significant side effects, including serve nausea and hair loss, while

    they are rarely effective in all cancer patients. However, despitetheir limitations they still provide a vital element in the fight

    against cancer as they can contributeto the cure of what could

    otherwise be a fatal disease

    Quality

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    Quality

    The final element which regulations address is quality

    The two characteristics that you would associate with a qualityproduct

    1. Safety

    2. fitness for purpose

    However, you would also expect product to be

    reliable and consistent

    In the context of medical products, quality means

    a requirement to demonstrate conformanceto agreed

    specificationsor applicable standards

    U d t f th D i Di ti

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    Updates of the Device Directives

    Basic Regulatory Strategy

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    g y gy

    The basic regulatory strategy employed to

    safeguard public health relies on focusing attentionon three main areas of activity:

    1. product development

    2. product manufacture3. market vigilance

    Product Development

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    Product Development

    Beforea product can be marketed, product

    developers must generate sufficient data to :-Demonstrate that the newproducts they wish to bring

    to market are safe and effective

    In the case of all drugs and high-risk medicaldevices these data must be

    1. Presented to the regulatory authorities for review

    if it is satisfactory

    The regulatory authorities will grant a marketing

    authorizationto enable commercial sale

    Product Manufacture and Market Vigilance

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    g

    1. All manufacturingsites must be registered with theauthorities

    2. Regular visits from inspection bodies must be carried out.The purpose of such audits is to Verify: -1. That manufacture is conducted under hygienic conditionsin suitable facilities

    2. Appropriate quality systems are applied to control theprocessMarket Vigilance:-1. Over the lifetime of the product the regulatory authoritiesput in place systemsso that all adverse incidents

    encountered in the market-place can be reported2. The manufacturer is also required to have a system forcapturing such incidents

    3. The manufacturer is obliged to report(the adverseincidents ) to the regulatory authorities.

    The regulatory strategy

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    The regulatory strategy

    EU vigilance communication systems

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    EU vigilance communication systems

    Quality Assurance Systems

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    Quality Assurance Systems

    Different quality systems are specified

    depending on the activities involved, such as :-

    Good manufacturing practice (GMP)

    Good laboratory practice (GLP)

    Good clinical practice

    or more general quality assurance systems for

    design, development, production, installation

    and servicing ((e.g.ISO9001)

    Element of quality systems

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    q y y

    Personnel

    People are a key element

    in all quality systems

    Documentation

    If any thing is notdocumented it does not

    exist or it never

    happened.

    1. Personnel

    2. Documentation

    3. Facilities and

    Equipment

    4. Corrective and

    Preventive Action

    Element of quality systems

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    PersonnelEvery single individual in an organization must

    understand:-1. What their responsibilities are2. How the task that they perform can affect quality

    Jobdescriptions

    should be created to define theduties, responsibilities andauthority levelof each position in an organizationJob specif ications

    are used to identify the qualifications, skills and experience thatare required.

    E ement o qua ty systems

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    q y yPersonnel

    Review of an individual's qualifications, skillsand experiencein comparison to the job

    description will identify the training needsfor

    that individual

    Recordsof all training delivered should be

    documented and maintained in a training record

    that can be made available to auditors for

    examination during an inspection

    Documentation

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    Documentation

    Documentation can be spli t into

    two main categories:-

    1. Proceduresoutlining

    what must be done

    2. Records showing

    what has been done.

    The performance of all tasks must

    be described in detai led

    1. Proceduresdescribing

    recurringtasks are

    usually referred(SOPs)2. General Operating

    procedures (GOPs)

    3. Protocols:- procedures

    describingnon-repetitive

    tasks

    ocument contro unct onDocument control function

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    Required to regulatethe

    authorizationand circulationof

    documents.This involves

    1. The sign-off on a master copy of

    the document by authorized

    personnel2. Recorded circulation of official

    copies to relevant departments.

    3. If a document needs to be

    updated, the revised versionshould be reviewed and approved

    by the same functions that

    approved the original.

    4. The revised version is then issued

    Documentation summary

    Facilities and Equipment

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    q pQuality systems require that facilities and equipment should

    be appropriateto the activities undertaken

    Examples :-1. Surfacesthat are easy to clean and maintain in hygienic

    conditionare a requirement in many situations

    2. Cloth-backedchairs would not be acceptable in a

    laboratory that handled potentially biohazardous materials3. Equipment should be checked at installationto

    demonstratethat it can perform its desired function

    Corrective and Preventive Action

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    1. Quality systems are intended

    to be self-correcting and self-

    improving

    2. The regular internal auditing

    of a quality system is a

    fundamental requirement.

    3. These audits should be

    conducted by personnelindependentof the operational

    area being audited

    4. quality department should

    not audit its own activities.5. The results of such audits,

    together with those from outside

    inspection bodies, will invariably

    identify areas for improvement.

    6. Feedbackfrom the market is

    another key data source through

    customer comments orcomplaintsor through the

    vigilance systems that are

    mandatory for drugs and devices

    7. Data collected on the day-to-day operation(recording of all

    non-conformances, procedure

    deviations, product failures, or

    product recalls)8. A variety of statistical tools

    may be used to analyzethe data

    and identifyunderlying trends.

    Validation &Verification

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    Validation:-Providing confirmation by

    examinationand objectiveevidence that the particularrequirementsfor a specificintended use can be consistently

    fulfilledApplied to either a productdesign or a process.For product validation, the

    objective is to demonstratethatthe productwillmeet the usersneeds when operated undertheintended use conditions

    Verification :-

    Means confirmation byexamination or directmeasurement thatspecified

    requirements are met

    Verif ication tests:-

    1. Nondestructive

    2. Destructive

    References

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    References1. Higson, G. R., & Publishing, I. of P. (2002). Medical device

    safety The Regulation of Medical Devices for PublicHealth and Safety. London: IOP Publishing Ltd 2002.

    2. Tobin, J. J., & Walsh, G. (2008). Medical ProductRegulatory Affairs Pharmaceuticals, Diagnostics,MedicalDevices. Weinheim: WILEY-VCH Verlag GmbH & Co.KGaA.

    3. Leitgeb, N. (2010). Safety of Electromedical Devices LawRisksOpportunities. Leipzig: Springer-Verlag/Wien.

    4. World Health Organization - WHO. (2003). MEDICALDEVICE REGULATIONS Global overview and guidingprinciples. Geneva

    5. www.brokerbanksecurities.com