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Friday, 27 June 2025
By Mitch on Friday, 27 June 2025, 13:00 - Regulations
MDCG 2019-11 rev.1 was published in June 2025. Almost 6 years after the first version.
Despite the passage of time, and the advent of modern AI, nothing has really changed. The rigorous approach is more than ever present in this guide.
Friday, 26 July 2024
By Mitch on Friday, 26 July 2024, 13:12 - Regulations
And this is the Australian TGA who demonstrates that.
Friday, 29 March 2024
By Mitch on Friday, 29 March 2024, 13:42 - Regulations
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!
Friday, 22 April 2022
By Mitch on Friday, 22 April 2022, 14:20 - Misc
A new unofficial SaMD classification scheme. Will it be adopted with the postponement of the MDR?
Friday, 15 April 2022
By Mitch on Friday, 15 April 2022, 14:26 - Regulations
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 - Regulations
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 - Regulations
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 The draft guidance Content of Premarket Submissions for Device Software Functions opens the ball in 2021. This draft guidance will supersede the guidance titled Content of Premarket Submissions for Software Contained in Medical Device, when it is published in its final version.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 - Regulations
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.
Friday, 26 March 2021
By Mitch on Friday, 26 March 2021, 13:38 - Misc
The definition of SOUP, and the requirements related to their lifecycle in IEC 62304 processes, are totally independent of any technology. Making no technological assumption, that's the way the standard is thought, so that it can be applied to any health software.
Cloud-based applications and web technologies make an intensive use of SOUPs. Let's see how IEC 62304 requirements can be applied to these technologies.
Friday, 5 February 2021
By Mitch on Friday, 5 February 2021, 12:40 - Regulations
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.
Wednesday, 9 October 2019
By Mitch on Wednesday, 9 October 2019, 14:39 - Regulations
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?
Sunday, 26 May 2019
By Mitch on Sunday, 26 May 2019, 14:00 - Regulations
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.
Why?
Because of rule 11 of 2017/745/UE Medical Device Regulation (MDR).
Friday, 19 January 2018
By Mitch on Friday, 19 January 2018, 14:15 - Regulations
Here is a quick follow-up of the new version of the FDA Guidance titled Medical Device Accessories – Describing Accessories and Classification Pathways, published in December 2017. This comes a bit in parallel to the Section 3060 guidance described in the previous post on the 21st Century Cures Act.
