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Technical File: Class IIa Devices EU / Class III Canada

  • 1.  Technical File: Class IIa Devices EU / Class III Canada

    Posted 10-Apr-2019 10:45
    Hi 
    I am revising our Technical File for a Class IIa family of products in the EU that are Class III in Canada.  I would like to have one file for this family that covers the EU and Canadian TF requirements.
    My initial though was to revise to BSI's "Medical Device Documentation Submissions Best Practice Guidelines
    https://www.bsigroup.com/globalassets/meddev/localfiles/ja-jp/documents/bsi_best_practice_guidelines.pdf

    or NB-MED/2.5.1/Rec5  Technical Documentation

    or other?

    any thoughts on which way to go...?

    Thank you in advance,

    Craig

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    Craig Jolicoeur CQE
    Quality and Regulatory Manager
    San Marcos CA
    United States
    ------------------------------


  • 2.  RE: Technical File: Class IIa Devices EU / Class III Canada

    Posted 10-Apr-2019 11:42
    Edited by Vidya Jayaraman 10-Apr-2019 14:10
    Are you creating these 'combined' TFs for just easier document control? because there are some different requirements (ERC for EU, different forms for Canada etc) that you may be aware of. We typically don't version control Canadian files because amendments are handled differently.
    That being said, I would follow the best practices guidelines if your NB is in fact BSI. They are very particular on having clean, bookmarked pdfs.

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    Vidya
    RA Specialist
    Marlborough MA
    United States
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  • 3.  RE: Technical File: Class IIa Devices EU / Class III Canada

    Posted 10-Apr-2019 17:04
    Are you creating these 'combined' TFs for just easier document control?
    Yes
    And thank you for the additional information.

    Craig

    ------------------------------
    Craig Jolicoeur CQE
    Quality and Regulatory Manager
    San Marcos CA
    United States
    ------------------------------



  • 4.  RE: Technical File: Class IIa Devices EU / Class III Canada

    Posted 10-Apr-2019 17:13
    I must however add that when you submit these files for review to BSI or HealthCanada, the file structures are very different. BSI expects a book marked pdf where as Canada needs several folders.

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    Vidya
    USA
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  • 5.  RE: Technical File: Class IIa Devices EU / Class III Canada

    This message was posted by a user wishing to remain anonymous
    Posted 10-Apr-2019 19:20
    This message was posted by a user wishing to remain anonymous

    I found it much easier to maintain a separate spreadsheet for demonstrating compliance with HC requirements regardless of class. I would list all the applicable CMDR regulations verbatim, the standards that facilitate meeting those requirements and a reference to the objective evidence that demonstrates compliance. Once completed, I signed it and placed it into the DHF where it is available for inspection.

    I think this would be easier for an because the CMDR requirements are clearly stated and are therefore easier to audit.


  • 6.  RE: Technical File: Class IIa Devices EU / Class III Canada

    Posted 10-Apr-2019 21:37
    I think the BSI format may follow the same format as the MEDDEV?

    ------------------------------
    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
    ------------------------------



  • 7.  RE: Technical File: Class IIa Devices EU / Class III Canada

    Posted 11-Apr-2019 09:41
    I would think so. I prefer the pdf guidelines because it covers both content and submission instructions and also makes references to STED guidance.

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    Vidya
    USA
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  • 8.  RE: Technical File: Class IIa Devices EU / Class III Canada

    Posted 12-Apr-2019 01:04
    There are a number of ways to compile Technical Documentation for CE Marking and Health Canada, but note that you should reference any current use methods.  As an example, Health Canada is going away from STED and will use the IMDRF RPS structure.  As Vidya indicated BSI has a structure which they want to have bookmarked, which loosely follows STED.  But regardless whether you follow STED or RPS structure, there is much more content contained in the regulatory submission that is not covered by either the STED or RPS inclusively.  If you intend to create a singular Technical Document file structure, would recommend you spend some time looking at STED, RPS, the BSI guidance (if you indeed use BSI otherwise you should inquire with your own NB on their expected structure), and Health Canada guidance to compile a singular file that will meet all of the requirements.  It might be able to be done, but can be difficult because the content for each are slightly different.  That is why IMDRF created the RPS, though it is unfortunate it is not more detailed because using a "one submission" approach needs to be more detailed, hopefully some of the further guidance from IMDRF will get more detailed and sometime in the near future we can indeed have one submission for multiple countries.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 9.  RE: Technical File: Class IIa Devices EU / Class III Canada

    Posted 12-Apr-2019 01:46
    The technical file should contain all the documentation related to your product.  What documentation you include in a regulatory submission is a different matter.

    ------------------------------
    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
    ------------------------------



  • 10.  RE: Technical File: Class IIa Devices EU / Class III Canada

    This message was posted by a user wishing to remain anonymous
    Posted 29-Apr-2019 11:10
    This message was posted by a user wishing to remain anonymous

    Is this document applicable to medical devices and IVD's as well? The content mentions medical devices, but the title is for IVD's. Just want to make sure what the current version of this document for medical devices is.
    http://www.imdrf.org/docs/imdrf/final/technical/imdrf-tech-180327-rps-ivd-toc.pdf

    Thank you!