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.
Original Message:
Sent: 03-May-2024 01:58
From: Richard Vincins
Subject: Medical Device End of Life Plan
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
Original Message:
Sent: 02-May-2024 21:18
From: Anne LeBlanc
Subject: Medical Device End of Life Plan
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
Original Message:
Sent: 02-May-2024 19:43
From: Armin Beck
Subject: Medical Device End of Life Plan
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.
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Armin Beck
CEO
SunTrixConsulting LLC
El Dorado Hills, CA
1-925-212-7683
armin.beck@suntrixmedical.com
Original Message:
Sent: 01-May-2024 17:00
From: Anonymous Member
Subject: Medical Device End of Life Plan
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