I posted some time ago that it was my sense that compliance and regulatory are now on a collision course. I think you are mixing and matching the two, and that's probably how it is going to be for awhile. I'm fascinated to watch this process play out, and look forward to seeing what kind of beast emerges out the other side.
I would have to say that I both expected and hoped for LESS consistency in the MDR than in the MDD, but I would guess I'm in the decided minority here. Perhaps a minority of one. :)
As for the implementations of major regulations, in my experience, they never really get implemented. Not the MDD, not the QSR, not FDASIA, and certainly not the MDR. It's sort of like moving, where you start to unpack, put away, unpack, put away, but soon life takes over, and some boxes finally get shoved unopened into the attic, where they will sit until the next move. Maybe you didn't need what was in them, or what you needed you replaced before you got around to opening that box, or you simply made do without them.
Everyone will finally settle on how things are going to be done, because everyone involved...EC, CAs, NBs, companies, healthcare providers, patients...need things to get done more than they need to comply with anything.
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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------------------------------
Original Message:
Sent: 14-Dec-2019 08:04
From: Paul Brooks
Subject: Navigating Grey Under EU Medical Device Regulation
As I read posts on RegEx regarding the new European Medical Device Regulation (MDR) I am reminded of the lessons from the implementation of the Medical Device Directive (MDD) in the 90's.
In the early days of the MDD we got lots wrong and lacked enough guidance/clarification from the authorities. We learnt much as we worked through the transition and implementation of the MDD, clarity improved over years and refinement continued. Expectations from authorities evolved and sometimes changed. I think we are much better prepared to understand the MDR today and there are requirements that are quite clear, but there is also a lot still to interpret (significant grey areas – particularly calibrating how much is required). Where things need interpretation there are often many expert opinions, but not all expert opinions are aligned. All opinions need to be weighed and carefully considered against contrary opinions. There is sometimes more than one way to comply. Opinions are invaluable in helping to refine our thoughts and develop resilient solutions appropriate to our specific situations. We always need to look for and take account of guidance's and pay attention to the words from expert engagement organizations, Member States, competent authorities and notified bodies. With the MDR we hope for and expect much more consistency than we initially experienced under the MDD, but still we are all learning from implementing the MDR.
We need to address the requirements and navigate the grey cautiously in a balanced, informed and measured way recording our supporting justifications/rationales. Grey is good, particularly during the transition period, it supports the development of practice that is pragmatic, can be defended and is compliant. As with the MDD over the years our understanding of MDR best compliance will improve, guidance and interpretations will evolve, expectations will be refined and we will all grow more confident of the compliance of our solutions.
Thank you for engaging and sharing on RegEx it is a wonderful example of members supporting as we as a regulatory affairs commuinity work through and navigate the grey.
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Paul Brooks
Executive Director
Washington DC
United States
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