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Rimsys Announces Rimsys AI to Eliminate Repetitive Tasks and Enhance Decision-Making for MedTech Regulatory Teams
Rimsys, the leading Regulatory Information Management (RIM) platform for the MedTech industry, today announced the launch of Rimsys AI, a suite of embedded artificial intelligence (AI) agents.
An overview of 21 CFR Part 812: Investigational Device Exemptions (IDEs)
This document is a summary of the regulation and does include wording taken directly from the regulation itself. The original regulation should be referenced directly, however, for complete information when submitting an IDE request.
What is an investigational device exemption?
An investigational device exemption (IDE) allows a device to be used in a clinical study prior to obtaining market approval to collect safety and effectiveness data. Clinical studies are typically required to support a Premarket Authorization (PMA), but a small percentage of 510(k) applications also require clinical data when a predicate device comparison is inappropriate for the submission.
Before a clinical study is initiated, an investigational device must have an approved IDE, unless it is exempt. Devices may be exempt from IDE requirements if they are noninvasive diagnostic devices, being used for consumer preference testing unrelated to device safety or efficacy, or intended solely for veterinary use or research with laboratory animals. Refer to the full text of 21 CFR 812 for details and additional exemptions.
Part 812 – General Provisions (Subpart A)
Scope
This regulation is applicable to all clinical investigations of devices used to determine safety and effectiveness, except where exempt.
Applicability
Abbreviated Requirements
Investigations are considered automatically approved for IDEs if the device is not considered a significant risk, unless the FDA has specifically notified the sponsor otherwise. In these cases, the sponsor must still obtain IRB approval for the investigation and must comply with other requirements of Part 812, including proper labeling, record keeping, and conformed consent requirements.
Exempted investigations
IDEs are not required for devices that fall into one of the following categories:
- Devices that were in commercial distribution prior to May 28, 1976 that were used or investigated according to requirements in effect at that time. Devices that were introduced after May 28, 1976 but which have been found to be substantially equivalent to devices introduced earlier may also be exempt. This exemption is limited for Class II and III devices from the date an FDA regulation or order calls for the submission of a PMA (in the case of an unapproved Class III device) or establishes a performance standard for a Class II device.
- Diagnostic devices for which the testing is noninvasive and without significant risk, and is not used as a diagnostic procedure without confirmation through another product or procedure.
- Devices undergoing consumer preference testing, or testing of a device modification or combination of already distributed devices, if the testing is not for purposes of determining safety or efficacy and does not put subjects at risk.
- Devices solely for veterinary use.
- Devices intended for research on or with laboratory animals.
- A custom device that is not being used to determine safety or efficacy for commercial distribution.
Definitions
21 CFR Part 812.3 provides definitions for many terms, some of which are listed here.
Institution: A person, other than an individual, who engages in the conduct of research on subjects or in the delivery of medical services to individuals as a primary activity or as an adjunct to providing residential or custodial care to humans. For example, a hospital, retirement home, confinement facility, academic establishment, and device manufacturer. The term has the same meaning as “facility.”
Institutional Review Board (IRB): Any board, committee, or other group formally designated by an institution to review biomedical research involving subjects and established, operated, and functioning in conformance with part 56. The term has the same meaning as “institutional review committee.”
Investigational device: A device, including a transitional device, that is the object of an investigation.
Investigator. An individual who actually conducts a clinical investigation, i.e., under whose immediate direction the test article is administered or dispensed to, or used involving, a subject, or, in the event of an investigation conducted by a team of individuals, is the responsible leader of that team.
Monitor: When used as a noun, this term means an individual designated by a sponsor or contract research organization to oversee the progress of an investigation. The monitor may be an employee of a sponsor or a consultant to the sponsor, or an employee of or consultant to a contract research organization. Monitor, when used as a verb, means to oversee an investigation.
Significant risk device means an investigational device that:
- Is intended as an implant and presents a potential for serious risk to the health, safety, or welfare of a subject;
- Is purported or represented to be for a use in supporting or sustaining human life and presents a potential for serious risk to the health, safety, or welfare of a subject;
- Is for a use of substantial importance in diagnosing, curing, mitigating, or treating disease, or otherwise preventing impairment of human health and presents a potential for serious risk to the health, safety, or welfare of a subject; or
- Otherwise presents a potential for serious risk to the health, safety, or welfare of a subject.
Sponsor: A person who initiates, but who does not actually conduct the investigation, that is, the investigational device is administered, dispensed, or used under the immediate direction of another individual. A person other than an individual that uses one or more of its own employees to conduct an investigation that it has initiated is a sponsor, not a sponsor-investigator, and the employees are investigators.
Sponsor-investigator: An individual who both initiates and actually conducts, alone or with others, an investigation, that is, under whose immediate direction the investigational device is administered, dispensed, or used. The term does not include any person other than an individual. The obligations of a sponsor-investigator under this part include those of an investigator and those of a sponsor.
Subject: A human who participates in an investigation, either as an individual on whom or on whose specimen an investigational device is used or as a control.
Labeling of investigational devices
An investigational device or its packaging requires a label with the following information:
- Name and place of business of the manufacturer, packer, or distributor (per 801.1).
- Quantity of contents.
- Statement: “CAUTION—Investigational device. Limited by Federal (or United States) law to investigational use.”
- Any additional relevant contraindications, hazards, adverse effects, interfering substances or devices, warnings, and precautions.
- If used for animal research, a statement of “CAUTION—Device for investigational use in laboratory animals or other tests that do not involve human subjects” must be on the label.
IDE Labeling cannot have any statement that is false or misleading and cannot represent the device as safe nor effective.
Prohibition of promotion and other practices
An investigational device is intended for use only within an investigation. Therefore, until a device is approved for commercial distribution by the FDA, the sponsor or investigator (or those working on their behalf) cannot:
To continue reading this Regulatory Brief, please download the full document here.
Announcing the Rimsys advisory board
Rimsys Regulatory Management Software, the leading Regulatory Information Management (RIM) platform designed specifically for the medical device industry, is proud to announce the creation of its prestigious advisory board.
By creating an advisory board with the most forward-thinking minds and preeminent talent in the medical device industry, Rimsys is now aligned and positioned to continue its growth and mission as the leading regulatory management software in the medical device industry.
The board members serve as strategic partners in the continued development and success of Rimsys, as a catalyst to achieving its short-term and long-term goals. The board is comprised of trusted thought leaders, known for being change agents in the industry and having the respect of their peers throughout their career and community.
"The management team could not be more pleased with the addition of these board members and involvement they have with the direction of our company. We are fortunate and thrilled to have such talented and experienced industry veterans and look forward to their many contributions,” said James Gianoutsos, Founder & President of Rimsys."
As advocates and ambassadors of Rimsys, the board supports the management team through strategic analysis, consultation, and providing professional expertise and guidance to help navigate and mitigate potential risks, discover opportunities, and define benchmarks for continued success and organizational growth.
"Rimsys is a very unique product in the marketplace, so it’s only fitting that we bring on such unique minds to the board. Their expertise and vision are exactly what is needed to help us improve our business, our technology and expand our product offerings,” said Brad Ryba, CTO of Rimsys."
The current advisory board members include:
John Speer
Jon Speer has over 20 years of experience in the medical device industry that includes quality management, product development, and project management at Creo Quality, Cook Inc., Theron Inc., and Maetrics LLC. Jon is experienced in managing multiple projects and taking medical device concepts through development, regulatory submission, and ultimately to market. Additionally, Jon is an expert in the design and implementation of FDA-compliant quality management systems and is an active contributor at MedCity News, Med Device Online, Quality Digest, QMed, and is the host of the #1 most downloaded podcast in the industry, The Global Medical Device Podcast. Jon currently serves as the Founder and VP QA/RA at Greenlight Guru, an eQMS that is specifically designed for the medical device industry.
Chris Ferguson
Chris Ferguson has over 15 years of global medical device quality and regulatory affairs experience managing class I, II, and III medical devices and consumer products for numerous world-class global organizations. Chris has successfully led global quality and regulatory projects and teams through FDA, ISO, consumer safety audits, and quality system remediation activities and has in-depth knowledge of the current regulatory landscape. Chris currently serves as Director of Quality Assurance for TransEnterix, Inc.
Bruce McKean
Bruce McKean has over 25 years of medical device industry experience as a regulatory professional specializing in quality and regulatory (Q&R) compliance, design controls, and Q&R related mergers and acquisitions. During his career, Bruce has focused on implementing and maintaining design controls, product submissions, quality management systems internal to his company and for newly acquired companies, corporate Q&R internal audit program, and performing Q&R due diligence audits on target companies. Most recently, Bruce has led a corporate-wide MDSAP compliance initiative and is focusing on the EU MDR implementation. Bruce currently serves as Director of Q&R Operations at Philips Healthcare.
Adam Price
Adam Price has over 15 years of medical device industry experience as a quality assurance and regulatory affairs professional. Adam is currently focused on the development of strategies and solutions to establish and maintain compliance in today’s fast-paced regulatory environment to enable businesses to meet the demands of the global market. Adam is cognizant of dynamic and complex market requirements and the need for effective tools and solutions to allow businesses to maintain continued regulatory compliance. Adam currently serves as Head of Post-market Surveillance at Philips Healthcare.
The 510(k) application: if content is king, then communication is queen
Often, the first thing we hear from a consultant or a medical device company regarding an FDA 510(k) premarket notification is that it was delayed because the FDA reviewer did not understand something simple within the application, or completely missed it.
What is wrong with the reviewer? How could they have missed something so simple? I couldn’t have been any clearer!
Sound familiar?
FDA is overworked, under-resourced, and will most likely miss something simple in your file upon reviewing.
As the specification developer, you know the design and history of the product better than anyone. You are providing that entire history in a formal application for review, and hopefully, clearance. A basic understanding of the technology is a must; however, think about the situation from the FDA reviewers’ point of view. 510(k) applications are inherently technical and sometimes need a brief discussion with the FDA reviewer for clarification or a general overview of your device.
Starting this dialog earlier is important for a smooth path to clearance. Part of this process involves requesting a Pre-Submission (“Pre-Sub”). Pre-Subs are a type of feedback that is part of FDA’s Q-Submission program.
Pre-Subs
Pre-Subs are a formal written request from an applicant for feedback from FDA to be provided in the form of a formal written response or a meeting (in-person or teleconference) in which the feedback is documented in meeting minutes. A Pre-Sub provides the opportunity for a submitter to obtain FDA feedback prior to intended submission of a premarket submission (i.e., IDE, PMA, HDE, De Novo request, 510(k), Dual, BLA, IND) or Accessory Classification Request, among others.
Pre-Subs are entirely voluntary on the part of the applicant. However, early interaction with FDA and careful consideration of FDA’s feedback may improve the quality of subsequent submissions, shorten total review times, and facilitate the development process for new devices.
Pre-Subs provide FDA reviewers with an introduction to you and your device rather than just having a 510(k) application dumped on their desk. FDA reviewers appreciate Pre-subs because they can get a sense of when they should anticipate filings and can plan their workloads accordingly.
FDA reviewers, like all of us, only have a certain amount of time during the day. If they are unable to find information easily or do not properly understand something, then they may state that the relevant information is missing from the application or needs further clarification. This kicks the 510(k) application back to you and stops the review clock. That is directly on the industry submitter, not the FDA reviewer.
The bottom line
FDA reviewers are people too. This is an obvious but often overlooked point to make. Sometimes they miss simple (and sometimes seemingly apparent) information. They make mistakes. The last thing you want to do is start yelling or pointing fingers. After all, you don’t want to burn any bridges as you will most likely deal with the same FDA reviewer upon subsequent submissions for similar products. Always be timely, concise, straightforward and respectful.
At the end of the day, keep in mind that your FDA reviewer isn’t as familiar with your medical device as you are. You need to help them understand items that are unclear, and the only way to do that is through building the communication channel early and having constructive conversations.
Did you know Rimsys Regulatory Management Software will keep track of all communications, notes, decisions, and tasks associated with your 510(k) application and other international regulatory submissions? Find out more now with a free demo and we will show you the power of the only regulatory information management (RIM) system platform designed specifically for the medical device industry.
Introducing government submission templates (i.e. 510k, STED, CSDT) and more!
Rimsys released a major revision on Dec. 3, 2018 that included adding registration workflows, registration owners, Kanban boards, new registration dates (e.g. anticipated approvals dates) and registration lifecycle stages.
Rimsys has been working aggressively over the last month to finish up the final touches on our next release, and we are excited to tell you that it has been officially released! These new features will benefit any size of an organization and continues our pathway to better serving the regulatory affairs professionals in the medical device industry.
Here are a few of our features released:
- Document templates – Depending on where you are registering your product, you can now choose or create your own document template that your team can follow to keep you compliant, better organized, and standardize your regulatory process. A few of our templates include: Summary of Technical Documentation (STED) for IVD and non-IVD Medical Devices, ASEAN Common Submission Dossier Template (CSDT), 510k Template, and more!
- Multi-product registrations – You can choose 1 or 1000 products (at the part number level) to register simultaneously into one market.
- Bulk search & replace for essential principles – We have been working with a few of our customers to get this functionality rolled out by the beginning of January. You now have the ability to search / replace / or remove a standard or a document throughout multiple essential principle tables simultaneously. Let’s say you are managing 10 (or even 500) essential requirements checklists…with a few clicks of a button, you can search, find and replace 1 (or all) standards or documents in EVERY table! If you have ever managed an essential requirements checklist before, we can’t stress enough of how HUGE of a time saver this is for you and your team!
- Embedded documents in essential principles – We now automatically embed your objective evidence directly into the Essential Principles PDF record. This means that when you export your essential principles as a PDF, every single document that is linked to it will be embedded directly into the searchable PDF. You never have to go looking for documents again!
- Dashboard updates – Added key metrics so your team can all be on the same page
- Expanded reporting capabilities – Added the ability to drill-down into key metrics
With this release, Rimsys will be better positioned to cater to organizations of all sizes. We have even more features and modules coming out in the coming months that will further enhance the benefit you receive from using Rimsys.
What’s next?
Rimsys has been working hard to be the single source of truth of all things regulatory related for medical devices. One of the most frequently requested features from our customers is the ability to bring regulatory updates on regulations, laws and guidance documents directly into Rimsys. We are happy to report that this feature has been in development for quite some time and we will be releasing in the next couple of months.
MDSAP device marketing authorization and facility registration
What is the medical device single audit program (MDSAP)?
The International Medical Device Regulators Forum (IMDRF) recognized that a global approach to auditing and monitoring the manufacturing of medical devices could improve their safety and oversight on an international scale. This created the Medical Device Single Audit Program (MDSAP) and allows a recognized Auditing Organization to conduct a single regulatory audit of a medical device manufacturer that satisfies the relevant requirements of the regulatory authorities participating in the program.
To date, the MDSAP participating countries include:
- Australia (Therapeutic Goods Administration – TGA)
- Bazil (Agência Nacional de Vigilância Sanitária)
- Canada (Health Canada)
- Japan (Japanese Pharmaceuticals and Medical Devices Agency)
- United States (FDA)
The World Health Organization (WHO) Prequalification of In Vitro Diagnostics (IVDs) Programme and the European Union (EU) are Official Observers, which means they are waiting for the results of the pilot MDSAP program to determine if it’s worth their while to sign on as an official partner.
When does MDSAP come into effect?
Starting January 1, 2019, if you’re selling medical devices into Canada, it’s not optional and you must be certified to MDSAP, or at the very least, show evidence that you are in the process of complying.
As part of the MDSAP auditing program, there are seven chapters an auditor must cover. One of those chapters is specific to marketing authorization and facility registration, which also touches on two other chapters, management and design development. An auditor will be specifically looking for the following:
- Have you complied with requirements to register and/or license your device facility;
- Did you submit device listing information;
- Did you obtain device marketing authorization;
- Have you arranged for assessment of changes and obtained marketing authorization for changes to devices or the quality management system which require an amendment to existing marketing authorization
You must have that information organized in a meaningful way that you can get to it quickly and show, objectively, that you fulfilled the requirements of MDSAP and all of the country regulatory requirements that fall under MDSAP. That also goes hand-in-hand with ISO 13485:2016 where you need a controlled release of products into the appropriate jurisdiction. If you’re trying to be a global leader or a global company, for that matter, in this day and age, you need to have a solid system in place to manage those marketing authorizations worldwide.
Controlled release of product
If you are selling out of the United States, you must comply with the laws of each importing country. That simply means, no matter where you sell outside of the United States, you must meet the importing country’s requirements for marketing authorization. Your regulatory team and business need to be on point by having a robust regulatory system in place that upon product release, you’re meeting those specific requirements. You must have a mechanism in place to ensure that you don’t release product prior to it being properly registered.
That mechanism starts during product realization. Sales, marketing, customer service, engineering, operations, and regulatory teams must all be on the same page. Often times, regulatory is perceived as the bottleneck to product release. However, this is a misconception and is primarily driven by poor planning during the design and development process.
Auditing to MDSAP
Auditors are looking for the standardized process for controlling the release of the product and ensuring that the process has been adequately established and implemented within your facility. MDSAP has a very rigid auditing process to ensure the proper market authorizations have been obtained and facility registrations have occurred.
When your company is audited, an auditor will request records from product outside of the MDSAP participating countries due to the broad jurisdiction of US and international regulations. If the auditor finds issues with those products, they can draw that parallel to determine that your company doesn’t have a controlled product release process and you need to investigate to ensure there isn’t a systemic issue. That means an audit observation and a corrective and preventive action (CAPA) plan need to be established to rectify the issue(s).
What does this mean for medical device manufacturers?
A regulatory professional’s job is worldwide nowadays, which means it is a lot of responsibility, burden and business risk that are on their shoulders. Do you really want all of that being managed by excel files, outlook reminders, and disjointed processes? It must be a fundamental, standardized process, ingrained into your quality management system, that you need in place in order to NOT run into any compliance issues. Your organization must have a standardized process to ensure that your company is releasing good (and approved) product into the market while maintaining any changes to that product (and registration) while it’s in that market.
The requirement is not only that you get the marketing authorization, but you stay compliant when you’re already in that market. That means you must constantly be monitoring for expiring registrations, any type of design changes with your product, and how they affect your marketing authorizations within those countries.
From a quality management system standpoint, you need a good change control process in place that ties directly to your regulatory team. If you don’t have a good regulatory process now, you’re not going to have one later. It’s going to be too late, and the amount of information that your regulatory team must handle today is only going to increase. That’s why you must develop those systems now.
To learn more about the MDSAP, markets where it’s applicable, pros and cons of using MDSAP vs Regulatory Authority inspections, and audit sequence and grading, download our Ultimate Guide to MDSAP.
Top 6 benefits of a regulatory information management (RIM) system for medical devices
The medical device and in-vitro diagnostic medical device industry are in dire need of a robust, practical and easy to use regulatory information management (RIM) system. Without a unified and collaborative system, serious consequences to your business can occur, including an increased risk of non-compliance, increased costs as well as a possible significant reduction in a product’s revenue potential.
1. Revenue impact
Missing registration dates, slow-to-market losses, and long-term, cascading impacts such as loss of customer loyalty have an immediate impact to market capitalization. Moreover, improper release of product due to lack of visibility to regulatory statuses can cause fines and loss of credibility with authorities, which can result in increased scrutiny.
2. Regulatory compliance
Compliant product releases are required in the medical device industry. Automation that creates safeguards to prevent unintentional release of products into markets is a must. Regulators from different markets are working together to identify instances of non-compliance as well as misalignment of information in submissions and other communications. More effective control of the submission, enabled by a unified platform, can lead to a leaner, higher quality submission and a reduced regulatory burden.
3. Faster time to market
Better planning and tracking in a unified system can monitor process metrics, milestones, and automatically informing submissions plan timelines with actual performance. A unified solution connects planning to execution, allowing improved, real-time process monitoring. Teams can quickly spot constraints and take action, allowing the product to get through your process faster.
4. Efficiency and collaboration
Regulatory processes touch multiple functional areas. Regulatory functions have been piecing together disparate systems to achieve marginal improvement. This landscape inhibits the accurate and timely transfer of data and disruption in cross-functional workflow.
5. Efficiency and collaboration
Employee turnover on regulatory teams is linked to the stress and increases greatly if team members consider processes to be inefficient or wasteful. Being able to perform one’s job efficiently and the perception of being part of a high-performing organization contributes to employee satisfaction and retention.
6. Insurance policy
Having a fail-safe in place now for when (not if) your top talent leaves prevent the loss of company and product specific tribal knowledge. Retraining a new employee without the subject matter expert can cause delays and wasted time. A unified system keeps all information within the company.
Introducing project management and essential principle templates
Directly on the heels of our new User Interface (UI) released at the end of September and debuting at the RAPS Regulatory Convergence in October, we are proud to announce another HUGE release.
Project management (for large and small teams)
Properly managing registrations across the world with dozens of stakeholders trying to collaborate on critical information is challenging enough, so we just made it easier for enterprise and large teams to manage everything.
The project management features were frequently requested and will set Rimsys up for further development of Key Performance Indicators (KPIs) to monitor the efficiency of your team and the registration process.
It will also allow Rimsys to further expand reporting capabilities and dashboard metrics so you can easily track and analyze data specific to your team, registrations, products, and countries.
- Registration owner - Assign an owner so you know who is responsible for each registration
- Anticipated approval date - Identify an anticipated approval so you can forecast product releases with other departments
- Registration start date - Automatically creates the registration start date so you can monitor exactly how long a registration takes from start to finish.
- Registration lifecycle stages - Whether you are in the discovery, planning, execution or submission stage of the registration process, you can now keep track with your own configurable buckets.
- Kanban boards - Visually see your registrations in each lifecycle stage and transition them into new stages by a simple drag n’ drop interface.
Essential principles (expansion of templates)
We always had a grander plan in mind. Rimsys was originally set up to include the new EU Medical Device Regulation (MDR) 2017/745 Annex I General Safety and Performance Requirements (GSPR) but now supports Essential Principles Templates that include:
- IVDR 2017/746EU IVDR GSPR
- Australian (TGA) Essential Principles
- Japan (PMDA) Essential Principles
- GHTF/SG1/N68:2012 IMDRF Essential Principles
- Directive 2006/42/EC – Machinery Directive
- and more to come!
The essential principles expansion complies with country entrance requirements and will set Rimsys up for further development of correlation tables. What are correlation tables you ask? Think of this….you create the general safety and performance requirements table for the EU MDR, then with a click of a button, you create the essential principle tables that meet the requirements for all other countries. More to come…
What’s next?
Next month, we will be making a few more major announcements that will bring you new and even better features that will drastically create more value to your company and team. We can’t wait to share the news with you…stay tuned!
