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  • 1.  ‘Medical Device spare part(s)’

    Posted 25-Feb-2022 05:45
    Hello,

    In cases where a spare part is replaced or discontinued, where that doesn’t affect the safety or performance of the MD.
    Does the above pose a requirement for updating the TD?

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    George Magkaniotis
    R&D Systems Test Engineer

    Tyresö
    Sweden
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  • 2.  RE: 'Medical Device spare part(s)'

    Posted 26-Feb-2022 10:35
    Maybe?

    I can imagine cases where the difference is negligible between the original spare part and the replacement you've qualified.

    I can imagine another case where you've had to select a new spare part with different characteristics. Then I'd ask, how do you know the safety and performance of the medical device are not affected? If you know because you've done biocompatibility testing on the new material, or updated electrical safety testing, or mechanical stress testing, then I'd say yes, that information probably belongs in the MD's technical documentation.

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    Anne LeBlanc
    United States
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  • 3.  RE: 'Medical Device spare part(s)'

    Posted 27-Feb-2022 03:31

    Dear George

     

    The Technical Documentation you are referring to, I assume is the Technical File of a CE certified medical device.

    If you change the makeup of your medical device, then the notified body will expect that this change is reflected within your Technical File.

    Changes performed to medical devices and how they are executed and documented may be reviewed in your next notified body QMS audit.

    Best Regards,
    Stephanie



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    Stephanie Grassmann
    Managing Director of MedTechXperts Ltd
    Biberstein
    Switzerland
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  • 4.  RE: 'Medical Device spare part(s)'

    Posted 27-Feb-2022 09:28

    Start with Art. 23 for which there are two cases.

    Art 23(1) covers "an item specifically intended to replace an identical or similar integral part or component of a device that is defective or worn in order to maintain or restore the function of the device without changing its performance or safety characteristics or its intended purpose".

    Art 23(2) covers "an item that is intended specifically to replace a part or component of a device and that significantly changes the performance or safety characteristics or the intended purpose of the device".

    It appears your situation falls under Art. 23(1), so you should be OK to not include it in the TD. Neither the Annex II nor the Annex III technical documentation requires this information.

    However, I'm working with a client whose Notified Body (based in Sweden) reviewed the submitted technical documentation. Under "Design control requirements not adequately demonstrated" the comment is "A list of design changes for each device is not provided". This is not a requirement in the TD.

    In your case, the replacement would be a design change and, under the NBs thinking, would be part of the TD.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 5.  RE: 'Medical Device spare part(s)'

    Posted 28-Feb-2022 12:46
    Edited by Kevin Randall 28-Feb-2022 12:53
    First, I recommend being careful about equating or confusing the scope of the requirements in EU MDR Article 23 (i.e., independent "after-market" commercialization of parts and components) with the separate requirements applicable to the original manufacturer of a finished device and its various parts and components.  For example, I wouldn't apply Article 23 to the scenario where the manufacturer of a diagnostic machine merely uses replacement parts during routine in-house or onsite servicing or repair of a customer's machine.  Article 23 should only get triggered if an economic operator provides separately-labeled/packaged "after-market" parts or components to the marketplace.

    For an original manufacturer of a diagnostic machine who merely uses its own replacement parts during in-house or onsite servicing or repair of a customer's machine, some NBs would expect that a revised spare part is to be reflected in the TD.  For example, BSI expects the TD to contain a Bill of Materials along with component grade, quality, reference codes, supplier details, etc.  Accordingly, some of those TD aspects would generally require a TD update to reflect the revised spare parts, even if the revised part doesn't affect the safety or performance of the MD.

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    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2022 by ComplianceAcuity, Inc. All rights reserved.
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  • 6.  RE: ‘Medical Device spare part(s)’

    Posted 07-Mar-2022 03:54
    Thank you all for your useful input and apologies for my late reply.

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    George Magkaniotis
    R&D Systems Test Engineer

    Tyresö
    Sweden
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