Avoid supply interruption, make sure you have robust, realistic plans to address the new EU MDR legislation
The requirements for the new legislation impact the majority of parties involved in the supply and governance of medical devices to the EU market across the entire lifecycle of each device. It is crucial that your company has a comprehensive, robust and realistic plan in place to define your strategies for transition. If you don’t have such a plan in place, act now – contact Be4ward to understand how we can help deliver your strategy and plan quickly, with minimal impact to your team.
The clock is ticking on the new EU Medical Device and In Vitro Diagnostic Device Regulations. Following approval in March 2017 by the European Council and in April 2017 by the European Parliament, the Medical Devices Regulation (MDR) – Regulation (EU) 2017/745 – and In Vitro Diagnostic Medical Devices Regulation (IVDR) – Regulation (EU) 2017/746 – were published in the Official Journal of the European Union on 5th May 2017. Both Regulations entered into force on 26 May 2017, hence the new MDR rules will apply from 26 May 2020 and the IVDR rules from 26 May 2022.
Billed as the most significant changes to medical device legislation in decades, these regulations seek to increase the safety and effectiveness of medical devices available in the EU market and address weaknesses in the regulations revealed in several high profile incidents. Medical device and in vitro diagnostic device manufacturers large and small who supply product to the EU market will be impacted and need to start planning now on how to transition to the new requirements.
Understand the full impact of the legislation
It is time that you understand the full impact of the legislation and local requirements on your organisation before it is too late, and make sure you are doing the critical path activities you need to be doing now. There are a number of changes being introduced by the new regulations, some of the most significant being:
The role of Economic Operators: Economic Operators (the collective description for Manufacturers, Importers, Distributors, Suppliers, Subcontractors and EU Authorised Representatives) carry the ultimate responsibility for conformity to regulations. The legislation outlines the general obligations of each or these parties, explaining both what they need to do and how they need to do it.
The scope and Classification of products: Whilst the classification system (Class III, Class IIa, Class IIb and Class I) is retained, some rules have been tightened. Some industry commentators anticipate this could result in some devices moving to higher classes of product. Moreover, a number of types of products that were previously exempt from the regulations are now included in scope.
Technical files, common specifications, clinical evidence, conformity assessments and product labelling: Additional requirements have been included to each of these aspects of product registration and approval. These may require further product information or testing to be provided to support approval. Transitioning arrangements for existing products or products currently undergoing conformity assessment are being clarified but some industry experts are concerned that these new requirements could require all products to be registered as they transition to the new legislation.
Vigilance and post-market surveillance: The regulations introduce further requirements for vigilance and post-market surveillance undertaken by both the Economic Operators and the National Authorities.
Quality Management System: All manufacturers and their representatives must have an appropriate quality management system.
Person responsible for Regulatory Compliance: The regulations require that manufacturers and authorised representatives have permanently and at their disposal at least one person responsible for regulatory compliance. This isn’t necessarily an employee, but must be accessible to the organisation. The person is responsible for ensuring the conformity of devices are checked prior to release including that technical documents and certificates of conformity are accurate.
Notified body re-designation: The legislation includes a series of requirements for notified bodies who will be required to be re-designated as part of the regulation. It is targeted to have this complete towards the end of 2018.
Unannounced Audits: Notified bodies will be required to undertake unannounced audits of manufacturers and their authorised representatives. Notified bodies will have to provide schedules of unannounced audits to their National Authorities.
Medical Device Coordination Group: The legislation includes the creation of a pan-EU expert committee, The Medical Device Coordination Group (MDCG). This will comprise representatives from the member states and will assist the Commission in the implementation and operation of the new legislation.
Unique Device Identification (UDI): UDIs will be introduced on all medical devices. They will be placed on the label of the device, implant cards for Class III devices, and in the case of re-useable devices, potentially on the device as well. These UDIs will be used to provide traceability of use of devices.
EUDAMED database: The Commission will establish a centralised EU database for the storage of information on medical devices (EUDAMED). This will facilitate the communication of both pre- and post-approval product information between economic operators, the Commission, member states and in some cases healthcare professionals and the public. It is targeted to have this database available towards the end of 2018.
Be4ward provide independent support
Be4ward has local teams in Europe and North America that can help you and your company understand and implement solutions for the EU MDR legislation. Here are some of the key reasons why you should engage with an independent consultancy like Be4ward:
Your company does not have the internal resources and/or capacity to develop internal knowledge and stay up to date with the evolving legislation and local country requirements. Be4ward is helping many clients understand and stay up to date with the legislation and local requirements.
You want to understand all your options. Be4ward can help you understand that you have options in how to meet the EU MDR legislation deadlines and help you choose the right solutions for your particular situation.
You need help understanding the supply base and selecting appropriate solution provider(s) for your situation. Be4ward have a thorough understanding of the supply base, whilst at the same time being completely independent from it. Therefore, we can help you select the most appropriate solution provider(s) for you.
You need experienced subject matter expert support in your implementation phase. Once you get into implementation, you will likely need incremental resources of varying different skills and knowledge at various times to help design, develop and implement EU MDR capabilities. Be4ward can provide you with these crucial resources to help you succeed in your implementation.
How Be4ward can help
Be4ward work with the world’s largest and smallest Pharmaceutical, Medical Device and Biotech companies and their CMOs to deliver fit for purpose, robust solutions for global legislations. Here are some of our service offerings that will ensure your company efficiently meets the EU MDR deadlines:
EU MDR Strategy Development
Be4ward’s strategy development service brings together a number of our EU MDR products to help organisations develop an initial understanding of how to tackle EU MDR. For more information please contact us at [email protected] to find out more about our EU MDR Strategy Development service and how it can help your company.
Other EU MDR Services
Be4ward provides various EU MDR services that can help your company meet the EU MDR deadlines in a time effective and efficient manner:
Should you have any questions about the EU MDR legislation, please don’t hesitate to contact us at [email protected] for more information.
As member of these renowned organisations, we ensure to provide services using the latest standards and good practices related to your business.