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  • 1.  Health Canada - Amendment requirements for medical devices

    Posted 09-Nov-2021 16:23
    Hello,

    I am seeking some guidance on amendment applications for Health Canada, in particular for class III and class IV medical devices.

    I have located the following resources - the regulations, guidance document and amendment form:
    • https://laws-lois.justice.gc.ca/eng/regulations/sor-98-282/
    • https://www.canada.ca/en/health-canada/services/drugs-health-products/medical-devices/application-information/guidance-documents/guidance-document-guidance-supporting-evidence-provided-new-amended-licence-applications-class-class-medical-devices-including-vitro-diagnostic.html
    • https://www.canada.ca/en/health-canada/services/drugs-health-products/medical-devices/application-information/forms.html

    I have never had the best luck navigating the Health Canada website - for whatever reason I do not find it to be particularly intuitive, and it has been some time since I have had to work on any amendment applications so I am struggling to verify what exactly is required (aside from the form).  I did some research online and found an article on regdesk:

    It is important to mention that the scope of the present Health Canada guidance covers only the approach to be applied by a medical device manufacturer when determining whether the changes made to a medical device qualify as "significant." All aspects related to the submission of an application for an amended medical device license, including its structure, content, as well as regulatory procedures associated thereto fall outside of its scope. The document also provides recommendations on assessing the impact of several changes to a medical device in terms of the impact caused by each change separately as well as their collective impact. Irrespective of the nature of changes made, a side-by-side comparison to a medical device already placed on the market could be applied in order to assess the impact of such changes and their significance. 
    (https://www.regdesk.co/health-canada-notice-on-interpretation-of-significant-changes/)
    Aside from the form, I am not sure what Health Canada is expecting to see in an initial amendment submission for high risk medical devices?  If anybody has recent experiences that they can share, I would greatly appreciate it!

    Thank you!

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    Elizabeth Goldstein RAC
    United States
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  • 2.  RE: Health Canada - Amendment requirements for medical devices

    Posted 10-Nov-2021 09:26
    Hi Elizabeth!  Health Canada's site, while not always intuitive, does have fairly detailed guidance on the preparation and expected content of submissions if you are willing to dig a little.  I tend to use a Google search to find what I need rather than trying to search their site.  Their most used pages will usually pop up.  I used "Health Canada medical device submission format" to find the links below.  

    Did you find this guidance in your search?  HC Draft IMDRF Guidance

    They have a 2021 guidance on new licence submission that also references the guidance above.  I had not read through it before today, but I saved it in my resource files.  Check it out.

    The folder structure can be downloaded by device class.  I haven't done it in awhile, but the last time I downloaded, there were two versions where one was just the empty file structure and the other contained individual guidance for the contents of each folder/subfolder.

    Table 1 in that guidance is not named exactly what it is, but it cover "minor" change content requirements.  R items are required.  CR items are conditionally required. NR items are not required.  O items are optional.  Essentially, you either populate the folder or you delete it.

    It also helps to just take the time to click through links embedded in this guidance to see what else they have provided.

    I hope this helps!

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    Robin Haden RAC
    Sr. Regulatory Affairs Specialist
    New Hill NC
    United States
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  • 3.  RE: Health Canada - Amendment requirements for medical devices

    Posted 10-Nov-2021 16:17
    Thank you

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    Elizabeth Goldstein RAC
    Regulatory Affairs Manager-International
    Irvine CA
    United States
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  • 4.  RE: Health Canada - Amendment requirements for medical devices

    Posted 10-Nov-2021 10:16
    Hi Elizabeth,

    I have found HC to be very accommodating when you have questions. When I had a question, this is what they replied:


    Please follow the folder structure, which indicates what documents you need.

    Folder structure (link below section 4.2)

    https://www.canada.ca/en/health-canada/services/drugs-health-products/medical-devices/application-information/guidance-documents/international-medical-device-regulators-forum.html

    Please submit your application via email (devicelicensing-homologationinstruments@hc-sc.gc.ca) (20MB max. by email) or on a compact disc or USB, following the exact folder structure. Please do not rename or renumber the folders; and all empty folders must be deleted from the folder structure before sending your submission / zip folder to Health Canada. Only one licence application per main folder.

    Link to the Guidance documents: https://www.canada.ca/en/health-canada/services/drugs-health-products/medical-devices/application-information/guidance-documents.html


    If you use Draft Health Canada IMDRF table of contents for medical device applications guidance  section 4.3 it will tell you which sections are applicable give your type of submission.

    Hope this helps
    -Graham 



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    Graham Cuthbert
    Sr. Manager RA
    Gainesville FL
    United States
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  • 5.  RE: Health Canada - Amendment requirements for medical devices

    Posted 10-Nov-2021 16:18
    Thank you

    ------------------------------
    Elizabeth Goldstein RAC
    Regulatory Affairs Manager-International
    Irvine CA
    United States
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  • 6.  RE: Health Canada - Amendment requirements for medical devices

    Posted 11-Nov-2021 08:47
    Hi Elizabeth,

    Health Canada actually has a wiki page now and it contains the most recent changes they have made for post marketing surveillance.

    https://wiki.gccollab.ca/HCmeddev



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    Colleen Powell
    Director of Regulatory Affairs
    Gloucestershire
    United Kingdom
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