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  • 1.  Medical Device End of Life Plan

    This message was posted by a user wishing to remain anonymous
    Posted 14 days ago
    This message was posted by a user wishing to remain anonymous

    Hello RAPS Expert,

    Does anybody have "end of life" plan for the medical device product(s) that defines warranty periods, use periods, complaint handling, adverse event handling, GUDID, listings, regulatory queries, etc.?

    Actually, we are class I (non sterile, non measuring) Medical devices manufacturer  and our devices can use for many years. However, we do provide warranty for 2 years only and have expected device life for 10 years.

    Thanks



  • 2.  RE: Medical Device End of Life Plan

    Posted 14 days ago

    An end of life plan is based on the device.  As an example, electronical device sold in Europe needs to be disposed of in accordance with the WEEE directive.   The warranty has nothing do to with the End of Life.



    ------------------------------
    Armin Beck
    CEO
    SunTrixConsulting LLC
    El Dorado Hills, CA
    1-925-212-7683
    armin.beck@suntrixmedical.com
    ------------------------------



  • 3.  RE: Medical Device End of Life Plan

    Posted 14 days ago

    The QMS and DHF should cover the necessary activities across the full product lifecycle.

    At the end of commercial distribution of a device type, the process should make sure you know to de-register it in the applicable jurisdictions.

    At the end of life, the customer should know if the device can go in an ordinary waste stream or if special decommissioning is needed, e.g. for electronics, batteries, radioactive materials...



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    Anne LeBlanc
    United States
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  • 4.  RE: Medical Device End of Life Plan

    Posted 14 days ago

    Good day Anon,

    I posted previously concerning a basic structure of an "end of life" plan for a medical device if you search a little. The end of life plan needs to be structured according to type of device because it can vary significantly between single-use-disposable product, a durable piece of equipment, or an implant.  There are many considerations to be made such as inventory, complaints, adverse event reporting, servicing, support, registrations, etc.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Principal Strategy Consultant
    NAMSA
    ------------------------------



  • 5.  RE: Medical Device End of Life Plan

    Posted 12 days ago

    As is kind of indirectly hinted in these replies, the end-of-life and disposal of the device needs to be considered in your risk management process and documented in your Risk Management File. ISO 14971:2019 indicates it is a lifecycle standard and this means it includes decommissioning and disposal of the device. This includes all medical devices such as single use and capital products.  Don't forget any by-products from the use of your devices, such as fluids in IVDs.  The end-of-life plan needs to be connected to your Risk Management File or referenced in the RMF. 



    ------------------------------
    Edwin Bills
    Edwin Bills Consultant
    ASQ Fellow CQE, CQA, CQM/OE, RAPS RAC
    Member ISO TC 210 JWG1
    elb@edwinbillsconsultant.com
    ------------------------------



  • 6.  RE: Medical Device End of Life Plan

    Posted 13 days ago

    Anne:

    I agree with you regarding the DHF, and in particular the need of a disposable plan needs to come out of the Health Hazard Analyse where the entire life cycle is evaluated.



    ------------------------------
    Armin Beck
    CEO
    SunTrixConsulting LLC
    El Dorado Hills, CA
    1-925-212-7683
    armin.beck@suntrixmedical.com
    ------------------------------



  • 7.  RE: Medical Device End of Life Plan

    This message was posted by a user wishing to remain anonymous
    Posted 10 days ago
    This message was posted by a user wishing to remain anonymous

    Thanks to all experts!

    You gave me great guidance to deal this situation.