Regulatory Open Forum

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  • 1.  EU OBL concept according to MDR

    Posted 17-Nov-2017 04:51
    Dear colleagues,

    We try to explain to our management boarding what the impact of the Medical Device Regulation to the OEM-OBL contracting in the EU will be and we would appreciate your input.

    Please share your knowledge and thoughts.

    Best regards,
    Sofia Panagou



  • 2.  RE: EU OBL concept according to MDR

    Posted 17-Nov-2017 12:00

    Sofia : 

    I am not a real expert in this particular OBL-OEM area. Yet, various presentations I attended about the MDR and its impact on OBL's have highlighted : 

    • OBL must have (access to) the full technical file, including e.g. sterilization validation at subcontractors of the OEM
    • Access to OEM's PMS data
    • Full audit and supply chain oversight
    • Unannounced audits 

    Are you familiar with the following document by the MHRA : Virtual Manufacturing replaces Own Brand Labelling for medical device manufacturers (Version 1.0 of March 2017) ?

    Although applicable under the MDD, upon closer reading, it might well be or close to what is to be expected under the MDR. 

    Again, I am no true expert in these matters, but hope this is useful. With kindest regards,



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    Ary Saaman
    Director, Regulatory Affairs
    Debiotech S.A.
    Lausanne
    Switzerland
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  • 3.  RE: EU OBL concept according to MDR

    Posted 18-Nov-2017 05:53
    Thanks dearly for your response!

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    Sofia Panagou
    QA/RA Manager
    Leoni Fiber Optics Gmbh
    Berlin
    Germany
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  • 4.  RE: EU OBL concept according to MDR

    Posted 22-Nov-2017 16:25
    Good Evening,

    .the following section of the EUMDR (Article 61. (5)) applies - as far as I see - on the OBL-OEM relationship:
    "5. A manufacturer (OBL) of a device demonstrated to be equivalent to an already marketed device not manufactured by him (OEM), may also rely on paragraph 4 in order not to perform a clinical investigation provided that the following conditions are fulfilled in addition to what is required in that paragraph:
    - the two manufacturers have a contract in place that explicitly allows the manufacturer of the second device full access to the technical documentation on an ongoing basis, and
    - the original clinical evaluation has been performed in compliance with the requirements of this Regulation,
    and the manufacturer of the second device provides clear evidence thereof to the notified body.

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    Peter Mikó M.D
    ArtPharm Ltd.
    Gyermely
    Hungary
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