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  • 1.  When to write a Machinery directive EHSR checklist?

    This message was posted by a user wishing to remain anonymous
    Posted 03-Sep-2019 09:54
    This message was posted by a user wishing to remain anonymous

    We are in the final stages of completing our MDD documentation and the applicability of the machinery directive has been raised. The device has small moving parts which would be user-accessible upon opening a cover (finger trapping hazard); multiple cut-out switches on opening the cover have been implemented to mitigate this risk.

    After reading some of the previous posts on this forum and MDD Article 3 (below), I think the machinery directive is applicable.

    "Where a relevant hazard exists, devices which are also machinery within the meaning of Article 2(a) of Directive 2006/42/EC of the European Parliament and of the Council of 17 May 2006 on machinery ( 24 ) shall also meet the essential health and safety requirements set out in Annex I to that Directive to the extent to which those essential health and safety requirements are more specific than the essential requirements set out in Annex I to this Directive.

    Therefore, we need to address the applicable machinery EHSR's* with a checklist in a similar way to the Essential Requirements checklists used for MDD. However, I don't think any of the machinery EHSR's that are more specific would apply to our device.


    In writing this I am talking myself into it, but do I need to create an EHSR checklist for the applicable EHSR's*  and detail out individually why we don't need to address any of them?


    *I have come across a joint industry recommendation doc from COCIR that provides a rationale for which EHSR's are applicable/not covered by MDD.



  • 2.  RE: When to write a Machinery directive EHSR checklist?

    Posted 04-Sep-2019 08:35
    I would recommend you just write a memo stating the exact considerations you summarized here and identifying those exact Clauses of the Machinery Directive you looked at, since IEC 60601-1 has Clauses evaluating moving parts, etc..... That (IEC 60601-1) is what you are complying with, I assume? Create the memo and put it in your regulatory assessment.  

    That approach worked for me with the NB when I worked on large CT Scanners with moving parts (gantries). I addressed it but stated nothing in the MD was more specific or different than IEC 60601-1 requirements.


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    Ginger Cantor, MBA, RAC
    Founder/Principal Consultant
    Centaur Consulting LLC
    River Falls, Wisconsin 54022 USA
    715-307-1850
    centaurconsultingllc@gmail.com
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  • 3.  RE: When to write a Machinery directive EHSR checklist?

    Posted 04-Sep-2019 21:12
    If your medical device which is also "machinery" (i.e. has moving parts) is covered by a particular EU Harmonized Standard (e.g. EN12184 for powered wheelchairs), requirements stipulated for the device under the relevant Harmonized Standard would take precedence over the EHSR of the Machinery Directive.  Therefore, the MDD Annex 1 Essential Requirements checklist along with the Device Risk Analysis per EN ISO 14971 would address all hazards, including those associated with the moving parts, and you would not specifically create a Machinery EHSR checklist.
    Hope this helps.


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    Homi Dalal RAC
    Regulatory Affairs Leader
    Christchurch
    New Zealand
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  • 4.  RE: When to write a Machinery directive EHSR checklist?

    Posted 05-Sep-2019 06:34

    First, I'm surprised that you are moving forward with the MDD, given the pending issues with the MDR. I infer your strategy with your NB is to get the certificate under the MDD and then move to the MDR Article 120 transition.

     

    Given your description of the device, I'm not convinced it meets the definition of machinery in the Machinery Directive Article 2(a). Assume it does.

     

    The MDD says that if your device is covered by the machinery directive, then you must also meet Annex I of the machinery directive, MD. However, when the MDD is more explicit than the MD, the MDD governs.

     

    This means you must go through the MD Annex I, determine which requirements apply and which ones do not. If a requirement applies, then you must determine if there is a more specific requirement in the MDD. The best method is an MD Annex I checklist in which you determine the applicable requirements. If a requirement is applicable, but less specific than the MDD, then cite the MDD Annex I requirement by number.

     

    You will have to follow MD Article 12 to assess conformity and also prepare a Declaration of Conformity.

     

    When you get to the MDR, you will have a similar situation with the MD, Article 1(12). I recommend you do the MDR analysis at same time, since you will be thinking about the issues. Under the MDR, you will not write separate Declarations of Conformity. Instead you will prepare one consolidated DoC.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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