Software in Medical Devices, by MD101 Consulting

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Friday, 16 May 2025

Team-NB position paper on EU AI Act

The Team-NB published the V2 of a position paper on the EU AI Act in April 2025.
It's interesting to see that this paper was published just before the white paper from BSI.

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BSI White paper: The EU AI Act meets the MDR

BSI Notified Body published in May 2025 a new White Paper on the AI Act and its interactions with MDR / IVDR.

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Friday, 11 April 2025

Team-NB questionnaire on artificial intelligence in medical devices

The team-NB published a questionnaire on artificial intelligence in medical devices in November 2024. This questionnaire is simply a (very long) list of questions that a Notified Body may take one by one, when they review a technical file of a medical device containing AI.

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Friday, 7 February 2025

FDA Guidance on Artificial Intelligence enabled device software functions

The FDA published early January 2025, a long-awaited guidance about Artificial Intelligence Enabled device software functions. This guidance contains FDA's recommendations on how to document an AI-enabled device in marketing submissions.
Almost 70 pages long, this guidance is a monster!

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Friday, 26 July 2024

Once again MDR and rule 11 are proven to be wrong

And this is the Australian TGA who demonstrates that.

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Friday, 19 April 2024

Transition or not, your MDD SaMD may die in 2025, not 2028

Yes, 2025.
Why? Because Windows 10 end-of-support is the 5th October 2025.
Are there any MDD SaMD running on Windows 11? No, Windows 11 was released the 5th October 2021, just after May 2021.
So, all MDD SaMD are officially running on Windows 10. Till the 5th October 2025.
Thank-you Microsoft, you set a regulatory deadline involuntarily!

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Friday, 29 March 2024

New IMDRF document on Medical Device Software

The IMDFR organization published in January 2024 a new document on Medical Device Software: Considerations for Device and Risk Characterization
Say briefly, this document is a gem!

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Friday, 20 October 2023

New version of the FDA guidance on off-the-shelf software use in medical devices

The FDA released in August 2023 a new version of their guidance on off-the-shelf software (OTSS) use in medical devices. It’s worth noting that this guidance didn’t go through a draft version.
Something visible in the content of that guidance.

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Friday, 6 October 2023

Final 2023 FDA Premarket Cybersecurity guidance released

The final version of the FDA guidance titled "Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions was published the 27th September 2023.

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Friday, 16 June 2023

Final FDA guidance on Content of Premarket Submissions for Device Software Functions

The final version of the FDA guidance on Content of Premarket Submissions for Device Software Functions has been published.

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Monday, 9 January 2023

IEC 81001-5-1 was added to the list of recognized consensus standards

The FDA added late December 2022 IEC 81001-5-1 to the list of recognized consensus standards.
That's it. After beating around the bush on this blog on whether UL 2900-x or IEC 81001-5-1 would be applicable to 510(k) submissions and other regulatory clearances, we now have the answer.

We can use IEC 81001-5-1 as:

A good way to make thing (a bit) more simple.

Remark: UL 2900-x can still be applied in the US!

Friday, 6 January 2023

FDA Guidance on Clinical Decision Support Software

The latest version of the FDA Guidance on Clinical Decision Support Software (CDSS) was published in September 2022. Here is a review of the document and a short comparison with the status of CDS with regard to the MDR.

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Friday, 16 December 2022

Manual on Borderline Classification Version 2 - December 2022

The Manual on borderline and classification under Regulations (EU) 2017/745 and 2017/746 - Version2 - December 2022 has been published yesterday.

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Friday, 30 September 2022

NIS2 Directive: are you involved or concerned?

That’s the story of the pig and the hen for breakfast: the pig is involved (ham) and the hen is concerned (eggs). With the NIS2 directive in preparation, a medical device manufacturer will be in either situation.

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Friday, 2 September 2022

MDCG 2022-14: Red Queen Effect

The MDCG published in August 2022 the MDCG 2022-14 position paper on Notified body capacity and availability of medical devices and IVDs.

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Monday, 27 June 2022

MDR: Les Shadoks and MHRA: The Gibis

The UK Government response to consultation on the future regulation of medical devices in the United Kingdom has been published on Sunday 26th June 2022.

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Friday, 10 June 2022

Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submission

The FDA issued in April a new draft guidance on Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions. This guidance will supersede the guidance on Content of Premarket Submissions for Management of Cybersecurity in Medical Devices of 2014, when it is finalized. There’s no word about the draft guidance of 2018. We can suppose that one is obsolete.

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Monday, 23 May 2022

The MDR is born bad

The Medical Device Regulation (MDR) is born bad. The success of a project depends on its timing. It is clear that the MDR has been plagued by a series of setbacks that have hindered its implementation.

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Friday, 13 May 2022

Software as a Medical Device Post-Market Surveillance

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.

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Friday, 15 April 2022

SaMD decommissioning, recall, removal and withdrawal

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.

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