Friday 13 May 2022
By Mitch on Friday 13 May 2022, 13:55
Post-Market Surveillance (PMS) is one of the strengthened requirements of the Medical Device Regulation (MDR). Performing an effective PMS can be a time consuming task, shared by several departments of MD manufacturers. This is also true for SaMD.
Friday 15 April 2022
By Mitch on Friday 15 April 2022, 14:26
We saw in the previous post how the lifetime of a SaMD can be defined. Let's continue with the operations that can affect this lifetime.
Friday 25 February 2022
By Mitch on Friday 25 February 2022, 14:28
Medical device regulations require the manufacturers to define lifetime for their devices. In the case of SaMD, this requirement needs some interpretation.
Monday 6 December 2021
By Mitch on Monday 6 December 2021, 13:32
Great news! The FDA announced their list of new or revised guidances for 2022. Software is going to be privileged, with 6 guidances on Clinical Decision Support software, SaMD risk categorization, cybersecurity, QMS SW, and Artificial Intelligence / Machine Learning. The draft guidance Content of Premarket Submissions for Device Software Functions opens the ball in 2021. This draft guidance will supersede the guidance titled Content of Premarket Submissions for Software Contained in Medical Device, when it is published in its final version. This little change in the title is a sign of the times.
Monday 8 November 2021
By Mitch on Monday 8 November 2021, 13:56
That is the question.
MD manufacturers are pressed by end-users to implement changes. Especially SaMD, where the users are used to receiving new versions weekly or monthly. Thus, Class I MDD SaMD manufacturers are pressed to find a way to qualify their software changes as non-substantial according to the MDCG 2020-3. Otherwise, they can't deliver new versions to their end-users, blocked by the deadly MDR rule 11 and its class IIa trap.
Wednesday 26 May 2021
By Mitch on Wednesday 26 May 2021, 00:01
This is the end of MDD, and class I SaMD.
Thursday 4 March 2021
By Mitch on Thursday 4 March 2021, 17:50
Friday 5 February 2021
By Mitch on Friday 5 February 2021, 12:40
A Notice was published in the Federal Register the 15th January 2021, about the exemption of a long list of medical devices from premarket notification. This list, found in table 6 of the Notice, contains 83 class II devices.
Yet, we have to wait for 120 days, to see this Notice published with the list in its final version.
Friday 25 December 2020
By Mitch on Friday 25 December 2020, 13:55
After the MDCG guide 2019-11 for the MDR, the MDCG 2020-16 gives the regulatory oversight on In-Vitro Diagnostic medical devices (IVD MD) classification; including software qualified as IVD MD. Let's see the consequences for software.
Friday 20 November 2020
By Mitch on Friday 20 November 2020, 14:01
The MDR 2017/745/EU and IVR 2017/746/EU define requirements, present in the Annex VII of both regulations, addressing the conformity assessment process that Notified Bodies shall put in place. It would be an understatement to say that this process will take some time.
Friday 6 November 2020
By Mitch on Friday 6 November 2020, 12:23
While the winds of Covid are blowing a bad air on Europe, the UK MHRA published in September 2020 the guidance on regulatory status of medical devices, IVD and AIMD from 1 January 2021.
Friday 4 September 2020
By Mitch on Friday 4 September 2020, 14:34
The FDA published in July the final version of the Guidance on Multiple Function Device Products. Despite the absence of the word "software" in the title, it addresses at first software medical devices. It also addresses hardware devices, but we will focus on software in this post.
Sunday 3 May 2020
By Mitch on Sunday 3 May 2020, 14:20
So we have a new guidance on cybersecurity for medical devices: the MDCG 2019-16. This is not the one we expected so quickly, but we're not going to complain about the existence of this guidance! It was published in December 2019. At last I found time to write a review.
This guidance covers a broad range of topics applicable to all stakeholders in the medical device supply chains, and to end-users. It explains a bit why it is 46 pages long.
Friday 6 December 2019
By Mitch on Friday 6 December 2019, 14:10
So we have a corrigendum (almost 100% sure. A vote by the EU Parliament is still in the pipe December the 16th, though). To corrigendumize: that's a neologism I propose to name bug fixing activities in legal matters. I corrigendumize, you corrigendumize, they corrigendumize! Any resemblance to "randomize" is purely coincidental!
Thursday 31 October 2019
By Mitch on Thursday 31 October 2019, 14:03
Here we are! White smoke over the European Parliament! The MDCG 2019-11 guidance on qualification and classification of medical device software (MDSW) was published the 11th of October 2019.
Wednesday 9 October 2019
By Mitch on Wednesday 9 October 2019, 14:39
We know that Drug Prescription Assistance Software are software as a medical device, thanks to the European Court of Justice. But how to CE mark that kind of software?
Friday 26 July 2019
By Mitch on Friday 26 July 2019, 13:34
The ANSM French Competent Authority published in July 2019 a draft guideline on cybersecurity for medical devices. The European medical device sector should greatly applaud this initiative. This is the first and only guideline on cybersecurity with regard to the European medical device regulations.
Friday 19 July 2019
By Mitch on Friday 19 July 2019, 14:10
The GMED notified body has published a guide on substantial changes: named Guidance document for the interpretation of significant changes in the framework of article 120: “Transitional provisions” of Regulation (EU) 2017/745. This guide addresses changes according to the article 120 of the MDR. It's a decision tree in the same vein as FDA guidances on deciding when to submit a new 510k.
As a manufacturer, your mission, if you accept it, is to answer "No" for all your products CE marked with the MDD.
For hardware, be prepared to place your design in the freezer.
For software, be prepared to place your design in liquid nitrogen.
The guidance is on the page on white papers of GMED website.
Sunday 26 May 2019
By Mitch on Sunday 26 May 2019, 14:00
Today is the 26th of May 2019. Rings a bell? In one year exactly, your class I MD software will be living in borrowed time on the EU market.
Because of rule 11 of 2017/745/UE Medical Device Regulation (MDR).
Tuesday 26 March 2019
By Mitch on Tuesday 26 March 2019, 16:21
To be software as a medical device or not to be.
That is the question.
And you rely on Competent Authorities to determine whether software is a medical device or not.
For example, you have some practical examples on the ANSM website (google translate is my Friend): here is the lastest version.
And you wish you had a way to be noticed by the ANSM when the page changes. Hell no, no way.
Especially you wish you had been noticed when the ANSM change their mind on telesurveillance software: here is the previous version on archive.org if you want to compare with the latest.
Before: examples showing that communicating data, like tele follow-up is not a MD, with the invocation of expert function (found in MEDDEV 2.1/6 only for qualification of IVD, not MD) to exclude software without such function.
After: examples showing that tele surveillance is a MD (exit the expert function).
Arrgghh, This isn't Good Regulatory Practice.