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EMDN Codes ... Finally

  • 1.  EMDN Codes ... Finally

    Posted 07-May-2021 09:51
    Greetings all,

    For those of you who have not seen it yet, the European Commission opened their website for the EMDN codes a couple days ago European Medical Device Nomenclature (EMDN).  There is a review/comment period, but EMDN away !

    ------------------------------
    Richard Vincins RAC
    ------------------------------


  • 2.  RE: EMDN Codes ... Finally

    Posted 18-May-2021 01:20
    Hi Richard,

    just to clarify: would you say the codes can be taken into use by manufacturers nevertheless right away in any document or form which requires an EMDN code?

    Best regards,
    Tiina

    ------------------------------
    Tiina Tyni
    Regulatory Consultant
    ------------------------------



  • 3.  RE: EMDN Codes ... Finally

    Posted 18-May-2021 02:44
    Hi Tina,

    I would think so, since this is published and available on the Commission site.  I have not had a chance to review this against the GMDN or look through in any strong detail to see how "complete".  It is in a review/comment period, so items may change, and we are still waiting for the mapping of the EMDN to the GMDN which will be a document or contained directly in this database.

    ------------------------------
    Richard Vincins RAC
    Vice President Global Regulatory Affairs
    Oriel STAT A MATRIX - ENTERPRISE
    ------------------------------



  • 4.  RE: EMDN Codes ... Finally

    Posted 18-May-2021 03:20
    Exactly, the upcoming mapping and potential changes after comment period were on my mind as well. So while manufacturers can apply the codes now, they may need to update their code records later on, in worst case scenario.

    Thanks Richard.

    ------------------------------
    Tiina Tyni
    Regulatory Consultant
    ------------------------------



  • 5.  RE: EMDN Codes ... Finally

    Posted 10-Jun-2021 17:46

    Hey all,

    Working on trying to assign EMDN codes. I have a few questions.

    1. What is 'na reagent'? It's used often. I don't know what this is.
    2. Can an IVD instrument have multiple EMDN codes, even if single technical file? For instance we have both hardware and software in our instruments and there are separate codes for each.

    Thanks so much,



    ------------------------------
    Corey Jaseph RAC
    Director of Regulatory Affairs
    Wheatland CA
    United States
    ------------------------------



  • 6.  RE: EMDN Codes ... Finally

    Posted 11-Jun-2021 06:14
    Hi Corey,

    I actually was trying to figure out the NA Reagents phrase myself and thinking maybe it means Not Assigned Reagent or Non-Applicable Reagent.  Personally I think it means Not Assigned Reagent, because if you look at the listing, as an example, Legionella, there is Legionella Antigen, Legionella Antibody, Legionella NA Reagent, and Legionella Other.  All of them have this, so thinking if the test is using not assigned reagents meaning not listed there.  However, there is also "Other" under each one as well.  This might also be some poor translation because if you click on one of them the term in Italian says 'LEGIONELLA, RICERCA CON REAGENTI NAS' which in Italian NAS means Nucleo Antisofisticazioni Sanità which is a review group in Italy similar to a kind-of US FDA/USDA.  Though all conjecture because NAS may mean something completely different - Network Access Storage device :).

    We often put multiple EMDN/GMDN codes for a Technical Documentation file when the "system" is composed of multiple parts.  This is quite normal in my experience, of course you should try to get as specific as possible having 1 EMDN code, but if the system is truly composed of different devices to clearly describe what is contained in the system, multiple numbers may be used.  If you are talking about instruments though unless the software is sold or used completely separate (SaMD) then I would still say the instrument should only have 1 EMDN code.  If it does help clarify the system, then in my experience including is helpful to show the composition of the system.

    ------------------------------
    Richard Vincins RAC
    Vice President Global Regulatory Affairs
    Oriel STAT A MATRIX - ENTERPRISE
    ------------------------------



  • 7.  RE: EMDN Codes ... Finally

    Posted 11-Jun-2021 10:47
    Hi Richard,

    Thanks for your quick response. My instinct was to assign the hardware code, so thanks for the confirmation. I guess we'll wait for clarification on 'na reagent.' :)


    ------------------------------
    Corey Jaseph RAC
    Director of Regulatory Affairs
    Wheatland CA
    United States
    ------------------------------



  • 8.  RE: EMDN Codes ... Finally

    Posted 11-Jun-2021 12:54
    The English phrase "NA Reagents" in the EMDN code list comes from the Italian "Reagenti NAS" in the context of IVDs.  In Italy's associated definitions and glossary documents at https://www.salute.gov.it/portale/temi/p2_6.jsp?id=328&area=dispositivi-medici&menu=classificazione, the phrase "Ricerca con Reagenti NAS" (Research with NAS Reagents) is used.  Accordingly, in this context, I would say that NAS appears to be a reference to Nucleophilic Aromatic Substitution reagents (such as Sanger's Reagent).

    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2021 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------



  • 9.  RE: EMDN Codes ... Finally

    Posted 11-Jun-2021 15:04
    Hi Kevin,

    Thanks for your response. My biochemistry is far back in time. Would 'nucleophilic aromatic substitution reagent be appropriate in all the cases where referenced in EMDN? There are dozens of references, used for almost every reagent detection system.


    Non-exhaustive examples from EMDN list:

    IDENTIFICATION SYSTEMS FOR YEASTS AND FUNGI / NA REAGENTS

    CHLAMYDIA TRACHOMATIS DETECTION BY NA REAGENTS

    CHLAMYDIA PNEUMONIAE DETECTION BY NA REAGENTS

    GONOCOCCAL DETECTION BY NA REAGENTS

    SYPHILIS DETECTION BY NA REAGENTS

    1. PYLORI DETECTION BY NA REAGENTS

    LEGIONELLA  DETECTION BY NA REAGENTS

    LYME  DETECTION BY NA REAGENTS

    MYCOBACTERIAL DETECTION BY NA REAGENTS

    MYCOPLASMA   DETECTION BY NA REAGENTS

    PSEUDOMONAS DETECTION BY NA REAGENTS

    SALMONELLA  DETECTION BY NA REAGENTS

    STREPTOCOCCAL  DETECTION BY NA REAGENTS

    STREP. A DETECTION BY NA REAGENTS

    STREP. B DETECTION BY NA REAGENTS

    STREP. PNEUMONIAE DETECTION BY NA REAGENTS

    SAPHYLOCOCCAL  DETECTION BY NA REAGENTS

    LISTERIA  DETECTION BY NA REAGENTS

    CAMPYLOBACTER DETECTION BY NA REAGENTS

    1. COLI DETECTION BY NA REAGENTS

    OTHER BACTERIOLOGY - NA REAGENTS

    BRUCELLA - NA REAGENTS

    COXIELLA BURNETII (Q FEVER) - NA REAGENTS

    LEPTOSPIRA - NA REAGENTS

    RICKETTSIA - NA REAGENTS

    YERSINIA - NA REAGENTS

    BORDETELLA PERTUSSIS / PARAPERTUSSIS - NA REAGENTS

    DIPHTERIA (CORYNEBACTERIUM D.) - NA REAGENTS

    TETANUS (CLOSTRIDIUM T.) - NA REAGENTS

    HAEMOPHILUS INFLUENZAE - NA REAGENTS

    NEISSERIA MENINGITIDIS - NA REAGENTS

    PROTEUS - NA REAGENTS

    PSEUDOMONAS - NA REAGENTS

    SHIGELLA - NA REAGENTS

    BACTERIOLOGY - NA REAGENTS - OTHER

    C.DIFFICILE BY NA REAGENTS

    HEPATITIS A VIRUS - NA REAGENTS

    HEPATITIS B VIRUS - NA REAGENTS

     

    HEPATITIS B VIRUS - GENOTYPING - NA REAGENTS

    HEPATITIS C VIRUS - NA REAGENTS

    HEPATITIS C VIRUS (HCV) GENOTYPING - NA REAGENTS

    HEPATITIS DELTA VIRUS - NA REAGENTS

    HEPATITIS E VIRUS - NA REAGENTS

     

    HEPATITIS G VIRUS - NA REAGENTS

    HEPATITIS X VIRUS - NA REAGENTS

    HIV 1 - NA REAGENTS

    HIV 1 GENOTYPING - NA REAGENTS

    HIV 2 - NA REAGENTS

    HIV 2 GENOTYPING - NA REAGENTS

     

    HIV P24 - NA REAGENTS

    HIV MULTIPLE - NA REAGENTS

    HTLV I - NA REAGENTS

    HTLV II - NA REAGENTS



    ------------------------------
    Corey Jaseph RAC
    Director of Regulatory Affairs
    Wheatland CA
    United States
    ------------------------------



  • 10.  RE: EMDN Codes ... Finally

    Posted 14-Jun-2021 16:00
    Hey Corey.  Yep, that is my current interpretation based on the commonality of Sanger's Reagents and NAS technology associated with IVD products today.  But as with the other guesses lodged in this thread, my interpretation remains to be more definitively confirmed.

    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2021 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------



  • 11.  RE: EMDN Codes ... Finally

    Posted 14-Jun-2021 17:15
    In my opinion it is referred to the same RNA and DNA sequencing reagents.

    RNA and DNA reagents - NA Reagents = Nucleic acid sequence Reagents - NAS reagents

    K

    ---------------------------------
    Katarzyna Chrusciel
    Engineer

    Italy
    ---------------------------------





  • 12.  RE: EMDN Codes ... Finally

    This message was posted by a user wishing to remain anonymous
    Posted 14-Jun-2021 08:18
    This message was posted by a user wishing to remain anonymous

    Hi Richard,

    Let me ask you about the  EMDN code.
    We are a manufacturer dealing with class 1s adhesive wound care dressings.
    Some of our products correspond to multiple EMDN codes.

    Is it possible to apply multiple codes to the same one product?
    Or do we have to choose the only code that best suits our one product?

    Thank you.


  • 13.  RE: EMDN Codes ... Finally

    Posted 12-Jun-2021 13:47
    The bes resource that I always used for correct assignments of CND codes is the following document:

    https://www.salute.gov.it/imgs/C_17_pagineAree_328_listaFile_itemName_13_file.pdf

    IVD codes are indicated with “W”.

    The reagents are more then 100..

    The text is in Italian language only.

    Best regards
    K



    ---------------------------------
    Katarzyna Chrusciel
    Engineer

    Italy
    ---------------------------------





  • 14.  RE: EMDN Codes ... Finally

    Posted 14-Jun-2021 09:26
    Hello Anon,

    You should generally assign one (1) EMDN code, the best one that fits.  If you have a product which multiple EMDN codes could be assigned, it might be better to contact them to get a new code assigned better describing your product.  The issue you will face in the future when EUDAMED is fully functional their will be an EMDN field which will most likely allow one code to be entered (similar to FDA GUDID) so you will need to find one best matching your product.

    Late reply: I like your response better Kevin :) 'Nucleophilic Aromatic Substitution reagents (such as Sanger's Reagent)' makes more sense.  It will be great when there is more clarification and guidance on the lists.

    ------------------------------
    Richard Vincins RAC
    Vice President Global Regulatory Affairs
    ------------------------------



  • 15.  RE: EMDN Codes ... Finally

    Posted 14-Jun-2021 15:55
    I had previously reviewed the document at https://www.salute.gov.it/imgs/C_17_pagineAree_328_listaFile_itemName_13_file.pdf. The terms and Italian narratives therein don't appear to explain the meaning of "REAGENTI NAS".

    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2021 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------