Regulatory Open Forum

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  • 1.  Have you ever switched notified bodies?

    Posted 01-Jul-2016 13:51

    If you have ever changed the notified body you used for ISO 13485 or CE certification, I'd be interested to hear about your experience, including why you switched, for what type of certification, whether the process went smoothly or not so smoothly, and whether the end result was what you were hoping for when you decided to make the switch.

    Thanks in advance,

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------


  • 2.  RE: Have you ever switched notified bodies?

    Posted 01-Jul-2016 14:02
    Julie,

    I will be brief. 

    One of my clients very recently changed their NB mainly because they wanted to work with the more responsive NB.

    But then the new NB is acting to be unnecessarily picky to the level of criticising previous NB's conformity assessment process.

    Thank you.  

    s/ David
    ______________________________________________
    Dr. David Lim, Ph.D., RAC, ASQ-CQA 
    Phone (Toll-Free): 1-(800) 321-8567



    "Knowledge is power only when it is practiced and put into action." - Regulatory Doctor

    NOTICE: This communication (including any attachments) may contain privileged or confidential information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this communication and/or shred the materials and any attachments and are hereby notified that any disclosure, copying or distribution of this communication, or the taking of any action based on it, is strictly prohibited.





  • 3.  RE: Have you ever switched notified bodies?

    Posted 01-Jul-2016 15:30
    Julie,

    In this particular client case, the client directly interacted with the NB. 

    I helped their documentation in response to the NB's audit comments and NB's request for additional documentation including clinical evaluation.

    D





  • 4.  RE: Have you ever switched notified bodies?

    Posted 01-Jul-2016 15:57

    Thanks, David.  Do you know what kinds of conformity their NB was assessing/certifying?  ISO 13485?  MDD?

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com



  • 5.  RE: Have you ever switched notified bodies?

    Posted 01-Jul-2016 16:18
    Julie,

    Class IIb device under MDD



    --

    Thank you.  

    s/ David
    ______________________________________________
    Dr. David Lim, Ph.D., RAC, ASQ-CQA 
    Phone (Toll-Free): 1-(800) 321-8567



    "Knowledge is power only when it is practiced and put into action." - Regulatory Doctor

    NOTICE: This communication (including any attachments) may contain privileged or confidential information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this communication and/or shred the materials and any attachments and are hereby notified that any disclosure, copying or distribution of this communication, or the taking of any action based on it, is strictly prohibited.






  • 6.  RE: Have you ever switched notified bodies?

    Posted 02-Jul-2016 11:50

    Many years ago (just before the required implementation of the IVD Directive - which tells you how long ago) the company I worked for changed from one registrar/Notified Body to another.  We did have at the time a single product that was governed by the MDD and required NB approval.  We did this because we felt that the registrar we were at the time using was excessively focused on compliance.  We wanted compliance, but we also wanted more: attention to the business benefits of a quality system.  I was the person leading the effort. 

    We treated the process as for any significant decision.  We determined the "Musts" and the "Wants" for the new registrar/NB.  We did phone interviews of the candidates.  We got references and called the references.  We assessed the results and then conducted interviews in person with the top candidates to make the final decision.   We were basically happy with the outcome.  We had a new registrar/NB who not only addressed compliance but provided attention to the business benefits. 

    An item that required particular attention was the timing of the labeling for the MDD product with the NB number on it.  I am sure this will be a particular concern for companies making this move nowadays.  It was our motivation in making the move prior to the implementation of the IVDD.

    I seem to recall from reading an early draft of the new European medical device regulations that upon implementation of those regulations, a three party contract will be expected for such changes.  I am not sure this requirement made it into the final texts, but it makes a lot of sense.

    If a client is making this kind of change, they will want to give a lot of attention to the details.

    Bill

    ------------------------------
    William White
    Senior Consultant
    Quality System Strategies LLC
    Elkhart IN
    United States



  • 7.  RE: Have you ever switched notified bodies?

    Posted 05-Jul-2016 21:46

    Thanks, William.  It sounds like you had a clear idea of what you wanted and it worked out well for you.

    I've had experience similar to David's in which the expectations of the new NB were somewhat different than the old one.  I also think expectations working with an NB on one type of certification (e.g., ISO 13485) can lead companies to expect the same performance on a different type of certification (e.g., MDD), and this isn't always going to be the case.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com



  • 8.  RE: Have you ever switched notified bodies?

    Posted 06-Jul-2016 08:43
    Hi Julie,

    At my last company, we switched notified bodies for both ISO 13485 and a number of CE certificates (class I through class III).  We switched in the 3 months coming up to the March 2010 MDD amendment implementation.  The reason for changing NB was to find a service that was more predictable and easier to work with.  The new NB made the process very smooth and relatively easy and we completed it just prior to the March 2010 deadline.  The new NB proved much easier to work with and has predictable and transparent timelines and processes.

    As long as a company's quality system and technical documentation are up to date, then I think a NB change is not something to fear.  But it helps a lot if the new NB has good processes for bringing on transferring companies.

    --
    Julie N. Broderick, RAC
    Broderick Regulatory Consulting, LLC
    P.O. Box 903
    Winchester, MA 01890
    Tel: 781-254-5094