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Testing requirements prior to initiating medical device clinical trial

  • 1.  Testing requirements prior to initiating medical device clinical trial

    This message was posted by a user wishing to remain anonymous
    Posted 02-Jul-2019 09:38
    This message was posted by a user wishing to remain anonymous

    Hello all, 

    I have a question related to testing requirements prior to initiating a clinical trial.

    We'd like to conduct a pilot study for a prototype class 1 device to determine efficacy. The device is to be used by the subjects in the CROs office (will not be brought home with subjects).

    I was wondering what type of electrical or safety data the IRB would require, and was informed by the IRB that we must provide a safety statement and justification as to why the device is not NSR.

    Does anyone have experience in what typically goes into a safety statement? I've reviewed ISO 14155 Annex B for info that goes into the investigator's brochure, and see safety related items there (for example, electrical, mechanical, reliability, biological safety, design calculations, etc).

    If various off-the-shelf electrical components are used/assembled into the device, does this typically require electrical safety testing, or can justifications related to design and use of off-the-shelf components be made? 

    Any advice is much appreciated!



  • 2.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 03-Jul-2019 11:45
      |   view attached
    ​You may need to meet 61010-1 Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use - Part 1: General Requirements
    Additionally, there may be a Part 2 safety standard per the attached list that applies to your device.

    ------------------------------
    Stephen Teresi
    Regulatory Specialist
    Oakwood Village OH
    United States
    ------------------------------



  • 3.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 06-Jul-2019 13:43
    Edited by Nina Joyce 06-Jul-2019 15:27
    Hi! By the nature of your question and comments added about electrical safety, I am assuming that the device is: An electronic device ( with Off-the-Shelf Software/Firmware? or software code customized for your specific application?). I didn't see that you mentioned anything related to Software, so I am assuming that the device is no software controlled. 

    Although you are not providing the Device Intended Use (which makes it difficult for anyone to give you suggestions about testing), I also agree with Stephen. Based on the limited information provided, IEC 61010-1 seems to be the most suitable electrical safety testing standard to use for testing your device.  

    Important considerations provided by FDA that you can use as a reference to write your assessment. 

    • "The risk determination (SR or NSR) is based on the proposed use of a device in an investigation, and not on the device alone." 
    • "What is the nature of the harm that may result from the use of the device? " 


    Each time that I have to write a Safety Assessment, or a justification of why the device is not NSR, I review FDA Guidances or regulations, and I use wording similar to the wording included in the guidance. In your case, I would write something like this: 

    Rationale for NSR Device:

    Per 21 CFR 812.3(m), the "x" investigational device meets the definition of a Non- Significant Risk Device. The "x" device is considered Nonsignificant risk devices are devices that do not pose a significant risk to the human subjects intended to be used by the subject in an office environment, and under supervision of the CRO staff. The "x" device is NOT intended to be used as:  

    • An implant that presents a potential for serious risk to the health, safety, or welfare of a subject;
    • Purported or represented to be for use supporting or sustaining human life that presents a potential for serious risk to the health, safety, or welfare of a subject;
    • 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.

    I do have a lot of experience on writing safety assessments, however, I need to know your device's intended use (this is not considered confidential information, a large list of intended uses is available on FDA's website). 

    A safety assessment is written after you complete the Safety Testing applicable to your device. I guess you can write it before completing the testing, but you need to have very clear, and formally documented in a test plan, what kind of testing you are going to complete. 
     
    Note: The fact that you are using off-the-shelf electrical components to assemble the device, does not justify not to complete Safety Testing. Yes, you have to complete Electrical Safety Testing to evaluate and confirm that the entire system works as intended. 

    My recommendation is to search for similar devices approved or cleared by FDA. You can find files with the testing that they have completed. 


    Best of luck to you, 

     


    ------------------------------
    Nina Joyce
    Bay Village OH
    United States
    ------------------------------



  • 4.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 07-Jul-2019 13:09
    I am not sure why IEC 61010-1 Laboratory equipment standard is mentioned.  I would think if we are talking a medical device the IEC 60601-1 would apply which is for medical electrical equipment and systems.  I have found IRBs vary in their understanding of electrical safety issues and for a clinical limited run there are only a couple electrical safety tests that probably apply.  I would need a much better understanding of the device to provide any assistance.  You wouldn't need to test the device to all the applicable clauses of the standard and this is somewhat subjective.  You will want to fully test the device after clinicals against the applicable standards.  You want to make sure safe enough so allowed to run the clinical.  You will have to follow what was noted in the above response but the level of testing doesn't need to be to every applicable requirement of the standard as you don't have a production or pre-production level device to test too.

    ------------------------------
    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Phone: (503) 244-6151
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
    ------------------------------



  • 5.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 07-Jul-2019 19:21
    Leonard,

    I agree with you, We all would need a much better understanding of the device to provide any assistance. 

    I believe that Stephen mentioned the IEC 61010-1 (and I agreed with his opinion) because we are assuming that the electronic device used in an office environment by the CRO staff is an in-vitro diagnosis device (IVD) with electric or electronic components.

    Great to see people sharing their opinion. 





    ------------------------------
    Nina Joyce
    Bay Village OH
    United States
    ------------------------------



  • 6.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 07-Jul-2019 19:26
    If you are in search of a Third Party Certified Lab, I recommend you Intertek or F2Labs. I have used their services for many years, and I like how thorough they both are with their evaluation. 

    After you provide them all the details of your device, they will determine the testing needed, and all clauses and sub-clauses applicable to your application. 

    I hope the safety assessment that I provided you (per your request) was good as a start point. 

    Have a good week.

    ------------------------------
    Nina Joyce
    Bay Village OH
    United States
    ------------------------------



  • 7.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 07-Jul-2019 20:28
    Actually, I disagree with Nina on the recommendation of one of the labs (F2 Labs) and also the test labs aren't allowed (by their ISO 17011 or 1725 certification) to provide you with a test plan, that is really the job of the manufacturer.  Also, if you don't steer the lab correctly you may not get what you need and you need to be clear with them.  I have worked at test labs and this is what I deal with all the time.  Also, Intertek will do a reasonable job but depends on the specific office, the engineer you are working with, etc for any test house.  F2 labs is not a US NRTL from what I know of Intertek is.  Also, I don't think F2 Labs is a CB scheme test lab so you need to think long term for the relationship what you want and need in the future not the short term of just clinical testing.

    If you need help with dealing labs, setting up test plans, reviewing the product against safety students standards that is what my firm does.


    ------------------------------
    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Phone: (503) 244-6151
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
    ------------------------------



  • 8.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 07-Jul-2019 21:31
    Leo said it perfectly, but I want to say it again, because it bears repeating:

    "If you don't steer the lab correctly you may not get what you need and you need to be clear with them."

    I would probably put it a bit more strongly and say that you probably won't get what you need.  And you need to know what that is; you can't expect the lab to know.  It's not their product; it's yours.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 9.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 08-Jul-2019 08:14
    I have often seen IEC 61010-1 used and accepted by agencies if there is no patient contact.  But I do agree with Leonard's comment.on use of a NRTL.  UL is another good choice, as well as Intertek, and there are many reviewing consultants out there who can help you develop the test plan.. But I am not aware that many TEST standards require a manufacturer developed test plan (ISO 13475 and QSR do).  The 4th edition EMC standard (IEC 60601-1-2:2014) requires it, and it was a mind shift for companies who were  just to telling the test lab to " test to the standard"...now you need a plan and rationale written ahead of testing, as it really shoukd be!


    ------------------------------
    Ginger Cantor, MBA, RAC
    Founder/Principal Consultant
    Centaur Consulting LLC
    River Falls, Wisconsin 54022 USA
    715-307-1850
    centaurconsultingllc@gmail.com
    ------------------------------



  • 10.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 08-Jul-2019 08:24
    Claiming to be a non significant risk device.
    I would start with the risk management activities and come out with a conclusion that the residual risk is addressed properly.
    All you need to do is a proper risk management which calls for risk control measures and the testing (IEC 60601) activities as risk effectiveness check.


    ------------------------------
    Kamal Solomon
    Gurgaon
    India
    ------------------------------



  • 11.  RE: Testing requirements prior to initiating medical device clinical trial

    This message was posted by a user wishing to remain anonymous
    Posted 08-Jul-2019 13:17
    This message was posted by a user wishing to remain anonymous

    Thank you all so much for the info and discussion!

    Yes, I did not give background on the intended use and realize that makes it difficult to give advice! It is a device intended to physically remove dental plaque and improve gingival health when used in conjunction with standard oral care. There are no diagnostics, and it does have patient contact. 

    I'll review the standards mentioned to see what may be applicable to our prototype. We of course will go through all relevant tests on the final device before listing, but at this point with a very "prototype level" device with components that will not be in the final product, I'm looking to see what testing we should carry out as the IRB's comment seemed quite vague. 

    Thanks again!

     




  • 12.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 08-Jul-2019 14:50

    Considerations for testing:

     

    Test Description                          UL/CSA 61010-1:2012 Ed.3

    Ground Bonding                                                  6.5.2.4

    Creepage and Clearance Distances                  6.7.2.1

    Dielectric Withstand following Humidity        6.8

    Handle Strength                                                   7.5.2

    Static Force                                                            8.2.1

    Impact                                                                    8.2.2

    Corner Drop                                                          8.3.1

     

    Fault Test – Protective Conductor                    4.4.2.3

    Compliance after Faults                                     4.4.4

    Input Power                                                         5.1.3

    Marking Durability                                              5.3

    Accessible Limits; Normal Condition                6.3.1

    Accessible Limits; Single Fault Condition         6.3.2

    Capacitance                                                          6.10.3

    Normal Temperatures – Surface                      10.1

    Normal Temperatures – Other                         10.3

     

     

    Other testing may also be applicable.  You'll need to coordinate with an NRTL for test plan.   

     

     

    Stephen Teresi

    Regulatory Compliance

    Field & Safety Instruments

     

    Thermo Fisher Scientific

    One Thermo Fisher Way I Oakwood Village, OH 44146

    Work Cell:  (440) 370-4788

     

     






  • 13.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 08-Jul-2019 14:55
    Sounds like probably the product falls under IEC 60601-1 and associated standards, not to IEC 61010-1 which is for laboratory equipment.  IEC 60601-1 has a Particular standard for dental equipment (IEC 60601-2-xx or IEC/ISO 80601-2-xx).  If your device doesn't contact the patient how does it remove plaque or improve gingivitis?  I assume the device produces some type of energy (i.e. sound, ultrasound, power, etc.) that breaks up the plaque and improves gingivitis.  If so, energy transmission still would fall under IEC 60601-1.  Please see my signature line, I am the "IEC 60601 guy".

    Typically for a clinical that you are submitting to one or more IRBs you (or a consultant supporting your company for Compliance Engineering) need to decide on the test plan and it tends to be shorter than normal test plan for IEC 60601-1 and may apply some of the additional standards like a Particular Standard, IEC 60601-1-2 (EMC), etc. as applicable but the reason for the reduced test plan is one meets the requirements of the IRB and realizing the product will change before further design and production of the device.  Primarily, you will want to make sure it is electrically safe to the patient, doesn't cause trouble in the environment it is being used for a Clinical Investigation, biocompatible, and many other risk concerns that should be considered in the Risk Analysis.

    ------------------------------
    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Phone: (503) 244-6151
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
    ------------------------------



  • 14.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 08-Jul-2019 15:32
    I don't totally agree with Stephen.  Some of these tests will not be able and some additional ones may apply.  Providing a list blindly without seeing and understanding the product and reviewing the full details about the product is subject to lots of issues.  Also, a NRTL can't provide you a test plan, as Julie & I have said multiple times in this conversation for a Clinical IRB test plan.  A NRTL is a certification safety test house and needs independence.  A NRTL is not required for clinical IRB safety testing but for the long run makes sense to consider to establish the relationship.  You want to prove the device is safe but some of the clauses noted won't end up in a Clinical IRB test plan as can justify out for the well controlled Clinical environment

    ------------------------------
    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Phone: (503) 244-6151
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
    ------------------------------



  • 15.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 08-Jul-2019 16:07

    Yes, I agree with Leonard.  Well said!

    Use the appropriate Safety Standard and note the National Differences if intend to market overseas. Take a critical look at voltages.

    Consider EMC status, Radio Compliance if applicable, RoHS, Radiation Safety if applicable, Laser Safety if applicable,

    And a Technical Construction File for CE generating a DoC if interested in European market.

     

     

    Stephen Teresi

     

     






  • 16.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 08-Jul-2019 17:29
    As others have mentioned, testing per EMC 60601-1-2 4th Edition and  IEC 60601-1 3.1 Edition may be needed.  Assumes Clause 14 (software related) is NOT required and your device does NOT have essential performance. The 4th Edition of IEC 60601-1-2 (2014-02) has special considerations related to Essential Performance and Risk Management related to ISO 14971. IEC 60601-1-6 evaluation will require a review of the usability engineering process and outputs of the process. The testing house should have ILAC approval through NVLAP accreditation. Sometimes, it requires a CB EMC test report with EMC CB Scheme certificate (CB certificates can only be issued for IEC standards). We have used UL in the past. You may want to reach out to them and their RM reviewer should be able to provide a project scope for your device. Good luck,
    Jo

    ------------------------------
    Jo Huang RAC
    Sr. Regulatory Affairs Specialist
    Athens TX
    United States
    ------------------------------



  • 17.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 08-Jul-2019 17:58
      |   view attached
    Asking for CB EMC certificate and report is not worth doing in almost any case.  The CB Scheme does not require EMC under IEC 60601-1-2 for a CB certificate and test reports for IEC 60601-1, ed. 3.1, 3.0, or 2.0 per OD-2055, ed. 2.1, attached.  Look at the Annexes.

    Essential Performance is required in IEC 60601-1 and most IEC 60601-2-XX or IEC/ISO 80601-2-XX Particular standards and risk management is a huge part of the whole series.

    BUT as I have said too many times in this thread for clinical pre-testing you don't need to do the whole test plan per the IEC 60601 applicable standards in the series plus software lifecycle per IEC 62304, plus the usabil;ity per IEC 60601-1-6 & 62366, and other collateral and potentially Particular standards.

    I dare say I tend to recommend to clients not to go with UL unless well entrenched with UL as they tend to be too conservative and projects drag on because of that.  Also, note I used to work at UL for 9 years and I have many work associates I interact currently with at UL mostly in the standards development world but I keep in contact with UL staff as well in the medical space.  I am heavily interconnected with many test labs in various places in the US and around the world as I am a member of the WG14 which is the interpretations  group for IEC 60601-1 and most members of this WG are test labs.  I am also involved heavily in the development of the next version of IEC 60601-1 (draft edition 3.2).

    ------------------------------
    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Phone: (503) 244-6151
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
    ------------------------------

    Attachment(s)



  • 18.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 08-Jul-2019 18:02
    PS NVLAP accreditation is not a requirement for Safety but typical of EMC labs.  ILAC approval not connected with some other accreditations so sometimes not worth it but really depends where in the world the device will be sold.

    Knowing the countries the product will ultimately be sold in will help shape the request to the tests lab and understanding the implications of the different options the test lab may offer will impact what lab you may select along with lead time, how well accepted the lab is, etc., etc.


    ------------------------------
    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Phone: (503) 244-6151
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
    ------------------------------



  • 19.  RE: Testing requirements prior to initiating medical device clinical trial

    Posted 08-Jul-2019 19:05
    Edited by Julie Omohundro 08-Jul-2019 19:07

    I will stay out of the details of electrical safety testing.

    I would take it that what the IRB meant was that it has no idea what electrical or safety data it should require, and that it is looking to you to provide not only data, but an explanation as to why the data you have provided are adequate to assure that subjects will not be at serious risk to their health, safety, or welfare due to their participation in the study. 

    What they really want is a CYA statement they can use to support a determination of non-significant risk, one that they can give to their lawyers, should the need arise.  From their response, I think they probably don't know or care anything about any electrical standards.  IRBs are (at best) experts in patient safety, not device safety.  You should care about the standards if they have been identified in your risk analysis as a measure you must take to reduce risk to subjects to non-significance.  Probably all you need to tell the IRB is that the device has been tested and shown to conform to electrical safety standards.  If they ask which standard or version or part, I would love to know, so I can knock myself over with a feather.

    Just FYI, the notion of a nonsignificant risk device is in error, and FDA's guidances talk instead about nonsignificant risk studies, which is really the whole point.  (Because it's easier to write a guidance that hopelessly confuses the matter than to correct a regulation.)  If the IRB knows any of this, please let me know, as I have another feather.



    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------