Regulatory Open Forum

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  • 1.  Possibility to combine IFU for similar products

    Posted 11-May-2017 10:48

    Hi Everyone,

    I would like to ask a question regarding the instructions for use of a medical device.

    My situation is as follows. My company has wide range of similar products with the same intended use and technological characteristics. There is minimum features which change. We would like to start selling in Hungary, but unfortunately we need to translate all the IFUs of all of our products in Hungarian language. 

    In order to minimize the workload and to avoid having to update our current IFUs in every country we sell,  I thought it would be better to create a unique IFU for Hungary alone, including all the models/product families of our products. Is it possible to do that?  If we have different products with the same intended use, is it possible to create a unique IFU for all of them at the same time, separating the products in the IFU?

    Thanks in advance ,

    Regards,



    ------------------------------
    Carmen Herraez
    Carouge
    Switzerland
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  • 2.  RE: Possibility to combine IFU for similar products

    Posted 12-May-2017 04:36
    Hi Carmen,

    Yes, it would be possible to make a single instruction sheet for a range of similar devices, but this should be addressed in your risk analysis with appropriate risk mitigations, such as usability testing of the consolidated document.

    I hope this helps.

    ------------------------------
    Roger Gray
    VP Quality and Regulatory
    Donawa Lifescience Consulting
    Rome, Italy
    +39 06 578 2665
    rgray@donawa.com
    ------------------------------



  • 3.  RE: Possibility to combine IFU for similar products

    Posted 12-May-2017 11:59
    I cannot see any impediment in what you want to do

    ------------------------------
    Lorenzo Muratori
    Elekta
    West Sussex
    United Kingdom
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  • 4.  RE: Possibility to combine IFU for similar products

    Posted 12-May-2017 13:21
    I agree.  The risk question is what are the potential consequences if the user accidentally tries to follow the instructions for one of the models other than the one they are using?

    ------------------------------
    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: Possibility to combine IFU for similar products

    Posted 12-May-2017 19:17
    Yes,  I've seen many companies do this.

    You have to make sure that the intended use is exactly the same or if not, the link between the PN and intended use is very clear.

    Also make sure all warnings and cautions are appropriate to the all products. If not, please make the differences and links to the appropriate products, very clear.

    Hope this helps.​





  • 6.  RE: Possibility to combine IFU for similar products

    Posted 15-May-2017 07:49
    Thanks a lot to everyone for your replies and your recommendations. They were very helpful.

    ------------------------------
    Carmen Herraez
    Carouge
    Switzerland
    ------------------------------