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October 25, 2022

Regulatory Briefs

An overview of 21 CFR Part 820 - quality systems for medical device manufacturers

September 23, 2022

4 min read

What is 21 CFR Part 820?

21 CFR 820 is the FDA federal regulation that pertains to quality systems for medical device manufacturers, and it is part of the agency’s set of Current Good Manufacturing Practices (CGMP) for industry. Also referred to as the FDA’s quality system regulation (QSR), the regulation defines design controls and quality processes at all stages of device development in order to ensure that all medical devices marketed in the United States are safe and effective.

21 CFR 820 consists of 15 subparts, which define quality system requirements for each stage and function within the medical device manufacturing process. We define each subpart below.

Federal regulations are organized as Title → Chapter → Subchapter → Part, which means that 21 CFR 820 is short-hand for:

21 CFR Part 820

21 CFR 820 vs ISO 13485

ISO 13485 is the de facto international quality system standard for medical device manufacturers, but this is not currently the standard in the United States. While Part 820 and ISO 13485 are structured differently, they have no conflicting requirements. Therefore, companies that are marketing medical devices in the U.S. and in other markets will need to comply with both ISO 13485 and the FDA’s QSR, as defined in 21 CFR 820. 

However, the FDA is moving towards harmonizing these standards, and on February 23, 2022 issued a proposed rule to amend the QSR to align more closely with the international consensus standard for Quality Management Systems, primarily by incorporating reference to the ISO 13485 standard. The FDA has published FAQ’s about the proposed rule.

21 CFR Part 820 Requirements

Part 820: General Controls (subpart A)

The General Controls subpart contains three sections providing general information about the regulation, including the scope and applicability along with key definitions.

Scope

The regulation defines current good manufacturing practice (CGMP) requirements governing the methods, facilities, and controls used for the “design, manufacture, packaging, labeling, storage, installation, and servicing of all finished devices intended for human use." Specifically, this subpart defines:

  • Applicability:

The requirements of this regulation are intended to ensure the safety and efficacy of all finished medical devices intended for human use that are manufactured in or imported into the United States. Manufacturers that are involved in some, but not all, manufacturing operations should comply with those requirements that are applicable to the functions they are performing. 

Exceptions:

  • This regulation does not apply to manufacturers of medical device components, but such manufacturers are encouraged to use this regulation as guidance.
  • Class I medical devices are exempt from the Design Controls defined in this regulation, except for those listed in § 820.30(a)(2)
  • Manufacturers of blood and blood components are not subject to this regulation but are subject to Biologics good manufacturing practices as defined in Subchapter F, Part 606 of the regulation.

Definitions

This section of the regulation contains definitions for a number of terms used throughout the document. The following are the major definitions related to quality records:

  • Design history file (DHF): A compilation of records that describes the design history of a finished device.
  • Design input: The physical and performance requirements of a device that are used as a basis for device design.
  • Design output: The results of a design effort at each design phase and at the end of the total design effort. The finished design output is the basis for the device master record. The total finished design output consists of the device, its packaging and labeling, and the device master record.
  • Device history record (DHR): A compilation of records containing the production history of a finished device.
  • Device master record (DMR): A compilation of records containing the procedures and specifications for a finished device.

Quality System

The section of the regulation sets the basic requirement for a quality system by stating that “Each manufacturer shall establish and maintain a quality system that is appropriate for the specific medical device(s) designed or manufactured, and that meets the requirements of this part.” 

The term “appropriate” is used throughout this regulation and can be open to interpretation. A manufacturer, however, should assume that all requirements are appropriate and applicable except in cases where non-implementation of the requirement can be shown to have no effect on the product's specified requirements or ability to carry out necessary corrective actions.

Quality system requirements (subpart B)

This section of the regulation defines the overall responsibilities and the resources required for the management of the quality system.

Management responsibilities

Executive management is responsible for establishing a quality policy and ensuring adequate resources to effectively maintain and manage the quality system. In addition, management is responsible for establishing a specific quality plan, consisting of relevant practices, resources, activities, and procedures.

Quality audit

Periodic audits of the quality system are required to be conducted by personnel not directly responsible for the activities being audited. The dates and results of each audit need to be documented, along with the results of the audit. It is expected that corrective actions and, when necessary, reaudits, be performed for any identified noncompliances.

Personnel

Manufacturers are responsible for assigning sufficient personnel with appropriate experience and training to perform all tasks required by the quality system plan.

Design controls (subpart C)

Manufacturers of all class II and class III medical devices, along with the specific class I devices listed in paragraph (a)(2) of this regulation, are required to establish design control procedures that ensure design requirements are met as specified. 

Design controls shall define:

  • Design and development planning - Plans that describe the design and development activities, and responsibilities for these activities and their implementation.
  • Design input - Procedures that ensure design requirements are appropriate and address the intended use of the device.
  • Design output - Procedures that document design output, including acceptance criteria, so that conformance to design input requirements can be adequately evaluated.
  • Design review - Formal and documented reviews of the ensign results that include participation from representatives of all.
  • Design verification - Procedures for verifying the device design that confirm that the design output meets the design input requirements.
  • Design validation - Procedures for validating the device design, ensuring that devices conform to defined user needs and intended uses, and including testing of production units under actual or simulated conditions.
  • Design transfer - Procedures to ensure that the device design is correctly translated into production specification.
  • Design changes - Procedures for identifying, documenting, validating, and managing the verification and approval process of all design changes before they are implemented.
  • Design history file - A design history file (DHF) is required for each type of device and should include or reference the records necessary to demonstrate that the design was developed in accordance with the approved design plan and device requirements.

Document controls (subpart D)

Medical device manufacturers are required to put in place document controls for all documents required in this regulation.

Document approval and distribution

One or more people must be assigned to review and approve documents prior to issuance. The approval must be documented, include a date and the signature of the approver, and be made available at all locations where applicable. Procedures must also be in place to ensure that obsolete documents are removed and/or prevented from being used.

Document changes

Similar to document approval procedures, changes to documents must be approved, reviewed, and documented. Records of all changes must be maintained.

Purchasing controls (subpart E)

To continue reading this Regulatory Brief, including a definition of the remaining subparts and a comparison of 21 CFR 820 to ISO 13485, please download the full brief.

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Actionable regulatory insights and process optimization for MDR/IVDR compliance

September 13, 2022

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Why a regulatory information strategy is critical for successful MDR/IVDR transitions

August 30, 2022

eBooks

CE marking guide for medical devices in the EU

July 28, 2022

4 min read

This article is an excerpt from the CE marking guide for medical devices in the European Union.

Table of Contents

What is CE marking?

CE marking is a symbol that consists of “CE, “ which is the abbreviation of the French phrase "Conformité Européene" meaning "European Conformity". The term initially used to describe “CE” was "EC Mark" but it has officially been replaced by "CE marking" according to the EU Directive 93/68/EEC. CE marking is used in all EU official documents, although you will still see "EC Mark" being used in common language. If you are using EC Mark in your documentation, you should change that terminology to CE marking in the future.

The letters ‘CE’ appear on many products traded on the Single Market in all the member states of the European Union plus Iceland, Liechtenstein, Norway and Switzerland. Simply put, The CE mark is a mandatory compliance mark, informing the consumer that the product is compliant with all applicable EU directives and regulations where the CE mark is required.

The Single Market was established in 1993 and is still considered one of the most significant achievements of the European Union. The main goal was to ensure the movement of goods and services freely within all the member states and to establish high safety standards for consumers. The CE mark indicates that goods and services do not need to be verified when shipping into another member country. To further support this movement, in April 2011, the Single Market Act was established to boost growth and strengthen confidence in the economy even further.

Why is CE marking important?

CE marking is required for many types of products, not just medical devices. The CE symbol can be found on bicycle helmets, toys, laptop batteries, wheelchairs, construction equipment, gas appliances and cell phone chargers - to name a few. CE marking is required for products manufactured anywhere that are sold in the EU, and only for those products for which EU specifications exist and require CE marking. The CE marking signifies that the product has been found to meet the general safety and performance requirements (GSPRs) of the European health, safety and environmental protection legislation and allows the product to be sold in the EU. 

CE marking responsibilities

Manufacturer responsibilities for CE marking

Medical device manufacturers are responsible for properly and legally CE marking products before they leave the warehouse.

Most Class II and III medical devices, along with IVDs and some Class I devices, require a conformity assessment performed by a Notified Body to ensure that all legislative requirements are met before it can be placed on the market. Manufacturers of most Class I devices can self assess conformity. This process needs to demonstrate that all the legislative requirements are met, including any testing and inspections, and that all necessary certifications are obtained.

The European Commission lists 6 steps that manufactures should follow to affix a CE marking to their devices:

  1. Identify the applicable directive(s) and harmonized standards - see EU standards for Medical Devices, In Vitro Diagnostic (IVD) devices, and Implantable Medical Devices.
  2. Verify product specific requirements using the essential principles identified in the above standards.
  3. Identify whether an independent conformity assessment by a Notified Body is necessary. Notified bodies will be required to verify compliance with relevant Essential Requirements for most medical devices classified as IIa, IIb, or III - along with sterile class I devices. See the Notified and Designated Organization (NANDO) database for available notified bodies.
  4. Test the product and check its conformity.
  5. Create and keep available the required technical documentation.
  6. Affix the CE marking and create the EU Declaration of Conformity.

Importer responsibilities for CE marking

If you are importing medical devices into the EU, it is your responsibility to review all the technical documentation and maintain a copy, or to make sure that it’s available to you upon request. 

You should verify:

  • That the device has been CE marked and that the EU declaration of conformity has been completed.
  • That the manufacturer has designated and established an authorized representative.
  • That the device is labeled appropriately and contains instructions for use (IFU).
  • When applicable, that a UDI has been assigned to the product.
  • Whether or not the product is registered in EUDAMED (registration is currently voluntary).

Take action:

  • List your name and address on the device or packaging, in addition to the manufacturer’s information.
  • Keep records of complaints, non-conformities, recalls, etc. on file.
  • Report any noticed non-conformity or product complaints from end users to the manufacturer and authorized representative immediately.
  • Maintain a copy of the EU declaration of conformity and any other relevant certificates.

Distributor responsibilities for CE marking

If you are a distributor, you are responsible for reviewing the technical documentation provided to you so that you can verify the product is safe to put on the local market. You must also be sure the product is labeled correctly with the CE marking symbol clearly visible. The technical file documentation contains all of the information that is necessary to show conformity of the product to the applicable requirements.

You should verify:

  • That the device has been CE marked and that the EU declaration of conformity has been completed.
  • That the device includes all the appropriate labeling, including instructions for use.
  • That if imported, the importer has complied with all the EU regulations.
  • When applicable, that a UDI has been assigned to the product.

Take action:

  • Report any noticed non-conformity to the manufacturer, importer, and authorized representative immediately.
  • If a product appears to be out of compliance to the regulations and could pose a serious risk, the information should be reported to the Competent Authority, and  to the manufacturer, importer and authorized representative.
  • Any complaints or reports from end users about the product should be reported to the manufacturer and, if necessary, to the importer and authorized representative.

Important note: If the importer or distributor markets the product under their own company name, then they become responsible for CE marketing, and take over that role from the manufacturer. 

What countries require or accept CE marking?

CE marking is mandatory when importing products into the European Union, which is part of the larger European Economic Area (EEA). The EEA Agreement, established in 1992 and made official in 1994, is an international agreement that enables the extension of the European Union’s single market to non-EU members. It consists of the 27 EU countries plus the four European Free Trade Association (EFTA) countries - Iceland, Liechtenstein, Norway and Switzerland. Today, the EFTA has 29 Free Trade Agreements (FTAs) with 40 countries and territories outside the EU. Because these countries operate in the single market, this allows free movement of goods and services across all of the EEA. 

Source: European Environment Agency (EEA).

Which medical devices require a CE mark?

All medical devices sold in the EU require a CE mark. While a CE mark is not required for items such as chemicals and pharmaceuticals, it can be required for combination devices and medical device software. For these two situations, how do you know if your product requires a CE mark?

To continue reading this ebook, including an overview of CE mark costs, and the associated technical documentation/general safety and performance requirements (GSPRs) that manufacturers are required to maintain please register to download the full version

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Regulatory AMA - What do you want to know about UDI?

July 20, 2022

Blogs

A look at the FDA Total Product Life Cycle Advisory Program (TAP)

By

Bethaney Lentz

February 5, 2024

4 min read

The Total Product Life Cycle Advisory Program (TAP) is a voluntary pilot program launched by the FDA’s Center for Devices and Radiological Health (CDRH) in October 2023. The TAP Pilot is one of the commitments between the FDA and industry as part of the MDUFA V reauthorization, which aims to provide faster patient access to safe and effective medical devices, increase innovation, improve patient safety through enhanced surveillance and data collection, and provide a more efficient regulatory process for FDA and industry.  

Taking a medical device from concept to commercialization in the United States is often a long and challenging process that involves participation and adoption from FDA, clinicians, payers, and patients. The TAP program is addressing the obstacles that device manufacturers often encounter throughout this process with:

  • Early and frequent interactions: FDA will provide more opportunities for sponsors to interact with the agency early in the development process, which can help to identify and address potential issues early on.
  • Strategic input from stakeholders: The program will involve input from a variety of stakeholders, including clinicians, patient advocates, and payers, which can help to ensure that the development of new devices is meeting the needs of patients and the healthcare system.
  • Proactive, strategic advice from CDRH: FDA will provide proactive and strategic advice to sponsors throughout the development process, which can help to reduce the risk of regulatory delays.

Currently, TAP program membership includes the companies or individuals developing the medical devices, the medical device sponsors, dedicated staff within the CDRH, stakeholders consisting of clinicians, patient advocates, payers, and academic experts, and independent advisors. However, It is unclear if independent advisors will continue to be part of the program as TAP expands. Additionally, specific individuals involved in the TAP program at a given time will vary based on the device being developed and the stage of the development process.

While currently still in its pilot phase, the TAP program is open to a limited number of medical devices. To be considered for the program, device manufacturers must have breakthrough designation with no previous pre-submission meetings. The TAP program started with 15 cardiovascular devices last fall and is now at 31 enrolled devices as of February 2024. Enrollment could reach as high as 60 devices by the end of 2024.

As part of the MDUFA V reauthorization, the TAP Program shares the goal of facilitating the development of high-quality, safe, effective, and innovative medical devices. Additionally, the TAP Program strives to reduce device development time and costs through early and frequent feedback from FDA, increase innovation with more predictable and efficient regulatory pathways for new devices, and improve patient access to new devices.

Overall, the TAP program’s focus is on improving the medical device landscape by addressing various challenges and opportunities throughout the product lifecycle. The program's success will be measured by its ability to expedite development, foster innovation, ensure device quality, and ultimately, improve patient access to these potentially life-changing technologies. For more information about the TAP program and enrollment in it, visit FDA’s website.  

MedTech
Blogs

Are FDA risk classifications and submissions any different for SaMDs? [VIDEO]

By

Bethaney Lentz

January 23, 2024

4 min read

The number of software as a medical device (SaMD) is growing and with it are questions about how to effectively obtain market clearance for them. One question we hear often is, “Are FDA risk classifications and submissions any different for SaMDs?” Currently, the FDA is regulating SaMDs the same way it’s regulating traditional medical devices. As a result, you’ll still have the same three risk classifications, Class I, Class II, and Class III.

The submission process is also the same. Most Class I devices are 510(k) exempt, and most class II devices would fall under a 510(k) or De Novo submission depending on whether or not substantial equivalence can be made to another US-marketed device. Most Class III devices require PMA submissions.  

There have been discussions about FDA pre-certification programs and following IMDRF guidelines for SaMDs, which would alter the submission process and also the risk stratification of SaMDs. However, none of these discussions have matured. The FDA continues to mirror their risk classification and submission guidelines for SaMDs and traditional medical devices.

Watch the full answer to this question from our recent panel discussion with subject matter expert, Prabhu Raghavan of MDQR Solutions, below.



You can also download the full replay here to get answers to other common SaMD questions such as:  

  • How is the FDA regulating AI/ML in SaMDs?
  • What is a Predetermined Change Control Plan (PCCP) for machine learning-enabled medical devices?
  • What cybersecurity considerations sh ould be made when taking SaMDs to market?

MedTech
Blogs

An introduction to standards for medtech companies

By

Bethaney Lentz

January 3, 2024

4 min read

A standard is a published document that is established by consensus and is approved by a recognized body (ISO, IEEE, UL, etc.). It outlines requirements, specifications, guidelines, or characteristics that are used in a repeated way to ensure that materials, products, processes, and services are developed for a specific purpose. Think of it as a formula for an agreed upon way of doing something that establishes the best way of performing a function. It could be developing a product, managing a process, or even supplying materials to a manufacturer.

Why are standards important?

Standards enable technology to work seamlessly across industries and markets and help to build consumer trust that products and services are designed to work together in an efficient way. They form the fundamental building blocks for product development by establishing consistent requirements that can be universally applied, practiced, and understood. For example:

To ensure standards stay relevant and are aligned with technology changes, many standards organizations require that their standards be reviewed periodically and updated as necessary.

Is an industry standard the same as a regulation?

No, but there is a very close relationship between the two. Simply put, a standard is a guideline whereas a regulation includes laws. Industry standards are used voluntarily (although strongly encouraged) while regulations are not voluntary because they are a requirement from a government agency or similar authority, i.e. ISO 13485 is a standard and building codes are regulations.

  • Standards are technical documents, driven by consensus that are crafted by experts.
  • Regulations are sometimes based on standards, created by a variety of individuals and entities, while overseen by federal, state, and/or municipal authorities.

It's important to note that while standards aren't mandated by law, many regulatory authorities recognize standards and recommend adherence to them in order to promote safety and quality.

What kind of standards are medtech manufacturers responsible for tracking?

The medical device industry has the responsibility for the design and manufacturing of a wide range of products used to diagnose and treat illnesses to improve health in patients. Medical device standards help ensure that a manufacturing or design process can consistently produce the quality required to serve patients and healthcare professionals around the world.

Some of the more common standards used by the medtech industry include, but are certainly not limited to:

ISO 9001 – A general standard (not industry specific) for quality management and implementing a rigorous quality system. For medtech specifically, it helps with the management of the quality control process by helping to keep costs low, improve accountability and simplify regulatory compliance.

ISO 13485 – This standard is designed for medtech specifically and expands on the framework set up by ISO 9001. Compliance with this standard helps with quality control, process validation, and risk management, often referred to as the risk management standard.

ISO 14971 – This standard specifies terminology, principles, and a process for the risk management of medical devices, including software and in vitro. This helps to identify hazards that may be associated with devices and to minimize those risks.

IEC 60601-1 – Medical Electrical Equipment, general requirements for basic safety and essential performance of equipment.

ISO 10993 – Biological evaluation of medical devices that includes biocompatibility testing of materials used to design product parts that would come into contact with a patient, testing for skin sensitization, and irritabilities.  

ISO 15223 – Symbols to be used with information to be supplied by the manufacturer. This standard identifies symbols that are globally accepted to be used in a broad spectrum of medical devices. These symbols can be placed on the device, on the packaging, or on any accompanying information such as instructions for use.  

ISO 45001 – This standard outlines the requirements for occupational health and safety management systems that can be employed in the medical device industry to help reduce occupational risk.

Where do I get these standards?

Standards used to design and build medical devices need to be purchased, and you must always maintain the most current revision of that standard to ensure proper adherence to it. They can be purchased as electronic copies, or you can request a paper copy for your files. You can purchase them directly from the standard organization (ISO, IEC, ASTM, UL, etc.). There are also organizations services that will provide standards from many organizations, serving as your to be your one-stop shop.

How do I know when standards change?

The best way to manage how you receive information about changes to industry standards would be to implement an electronic standard tracking system. These systems help to:

  • Give you early notifications of changes
  • Mitigate your company's risk by ensuring you're up-to-date
  • Save you time by eliminating the tracking on your own
  • Ensure your standards are up-to-date

Using manual processes such as spreadsheets to manage standards updates can be difficult, time-consuming, and lead to compliance risks - especially when a high number of standards and markets are involved. There are a variety of standards management tools to help medtech companies monitor and manage global standards, including Rimsys.

How can Rimsys help?

Rimsys’ regulatory management software offers standards management to help you stay ahead of the mayhem by providing:  

  • Access to a library of over 1.6 million global standards through a partnership with IHS Markit
  • The ability to link standards to individual products to more easily assess the impact of changes across your product portfolio
  • Automatic alerts when standards are changed, superseded, or withdrawn to reduce compliance risks and enable faster reaction times
  • Bulk updates to your essential principles/GSPR tables when standards change for easier maintenance and compliance

For more information, visit www.rimsys.io/solutions/standards-management.

MedTech
Blogs

Why should you invest in your regulatory team? Easy Medical Device podcast interview

By

Bethaney Lentz

December 19, 2023

4 min read

Recently, our Founder and CEO, James Gianoutsos, was a guest on an episode of the Easy Medical Device podcast. Hosted by Monir El Azzouzi, a quality and regulatory professional with over 16 years of industry experience, the Easy Medical Device podcast explores a wide range of topics, news, and challenges to help medtech quality and regulatory professionals gain valuable insights that will help them excel in their roles.

In the episode, Why should you invest in your regulatory team?, James and Monir explore the limitations of traditional cost-center approaches to resourcing and preparing budgets for regulatory affairs teams and discuss the benefits of treating regulatory affairs as a revenue function. Hear their thoughts about:

  • How regulatory affiars teams are typically structured
  • The importance of the RA job function on revenue
  • The impact AI will have on regulatory affairs
  • How digital tools can enable RA teams

James also provided tips RA professionals can use to convince their stakeholders to invest in regulatory affairs teams. He emphasized that getting buy-in often involves a mindset shift that will change the dynamic of the conversation. For example, when planning for a renewal, think about the financial impacts of missed renewals rather than the sheer volume of renewals you're doing.

When you're trying to convince your leadership team, don't talk about how many renewals I did for this product in a particular month. talk about the dollar figures you saved the company or retained on the market.

For more tips, listen to the full interview on the Easy Medical Device website.

MedTech
Blogs

Taking SaMDs to market in the US: How is the FDA regulating adaptive machine learning algorithms?

By

Bethaney Lentz

December 14, 2023

4 min read

Rimsys recently held a panel discussion, Taking SaMDs to market in the US. During it, Prabhu Raghavan, Principal at MDQR Solutions, and Rimsys Chief Solutions Officer, Brad Ryba, shared an overview of SaMDs and provided their insights about getting and maintaining market clearance for them in the United States. Topics ranged from FDA risk classifications and submissions, cybersecurity best practices, and machine learning algorithms, which brought about an important question: How is the FDA currently regulating adaptive machine learning algorithms in SaMDS?


Adaptive machine learning algorithms use post-market data in real time and evolve their models based on the data they're consuming. As such, every patient utilizing a device with adaptive machine learning algorithms may have a new model compared to the previous patient. While the FDA doesn't have any formal guidance on the subject just yet, manufacturers can work with the FDA to get a plan in place for maintaining a state of validation post market.

Watch the snippet from the webinar to learn about taking a staged approach with the FDA to get a proper validation plan in place.

To watch all discussion topics, download the webinar replay here.

MedTech
Blogs

The five guiding principles for machine learning-enabled medical devices using PCCPs

By

Bethaney Lentz

November 8, 2023

4 min read

On October 24th, 2023, the FDA, Health Canada, and the MHRA published a joint document providing harmonization for machine learning-enabled medical devices (MLMD) that use predetermined change control plans (PCCPs). PCCPs are plans proposed by the manufacturer that state the specific modifications to a MLMD, the process for implementing these modifications, and the assessment of impacts from them.  


The document details five guiding principles for MLMDs in an effort to set a foundation for PCCPs and encourage collaboration on them. According to the UK government’s website, these principles are:  

  1. Focused and Bounded: Describing specific changes that a manufacturer intends to implement.
  1. Risk-based: The intent, design, and implementation of a PCCP are driven by a risk-based approach that adheres to the principles of risk management.
  1. Evidence-based: Demonstrating that benefits outweigh the risks throughout the product lifecycle.
  1. Transparent: Provide clear and appropriate information and detailed plans for ongoing transparency to all stakeholders, from patients to healthcare professionals.
  1. Total Product Lifecycle Perspective: Improve the quality and integrity of a PCCP by continually considering the perspectives of all stakeholders.

Here are some examples of how these principles could be applied:  

  • Focused and bounded: A manufacturer of an MLMD that diagnoses cancer might develop a PCCP to implement a change to the algorithm that improves its accuracy in detecting a specific type of cancer.
  • Risk-based: A manufacturer of an MLMD that monitors a patient's vital signs might develop a PCCP to implement a change to the algorithm that reduces the likelihood of false alarms.
  • Evidence-based: A manufacturer of an MLMD that delivers medication to patients might develop a PCCP to implement a change to the algorithm that improves the accuracy of the dosage.
  • Transparent: A manufacturer of an MLMD might publish a white paper that describes the device's algorithm and how it was developed and tested. The manufacturer might also make available a user manual that provides clear instructions on how to use the device safely and effectively.
  • Total product lifecycle perspective: A manufacturer of an MLMD might collect feedback from patients and healthcare professionals on how the device is performing after it is marketed. The manufacturer might also use this feedback to identify and address any potential problems with the device.


The five guiding principles for MLMDs using PCCPs are based on the 10 guiding principles for Good Machine Learning Practices (GMLP) published in 2021, which were designed to help medical device manufacturers develop and deploy machine learning models that are safe, effective, and high quality. Similarly, the goal of these five guiding principles is to help MLMD manufacturers develop and maintain safe and effective products that meet the needs of patients and healthcare professionals. They are also intended to streamline the regulatory process for MLMDs, making it easier for manufacturers to bring new products to market and make updates to existing products in a timely manner.


If you’re looking for additional information about MLMD requirements in the US, join Rimsys and MDQR Solutions for Taking SaMDs to market in the US on Thursday, November 30th, at 1 PM ET. We’ll discuss the various types of SaMDs, considerations to make when obtaining market clearance, and how the FDA is regulating AI/ML in devices. Those interested in attending can register here: Taking SaMDs to market in the US.


MedTech
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