Regulatory Open Forum

 View Only
  • 1.  Happy EU MDR Compliance Day !

    Posted 26-May-2021 05:00
    Edited by Richard Vincins 27-May-2021 03:44
    Hope you are all ahead of schedule, getting QMS reviewed happily, and Technical Documentation reviews complete !  Should be a fun few years moving through the transition grace period !

    Corrected from Erik, absolutely right we are in the grace period now - good luck with legacy devices !

    ------------------------------
    Richard Vincins RAC
    Vice President Global Regulatory Affairs
    Oriel STAT A MATRIX - ENTERPRISE
    ------------------------------


  • 2.  RE: Happy EU MDR Compliance Day !

    Posted 27-May-2021 02:11
    Actually we already had four years of transition period, now we're in the 'phasing out of legacy devices' period, also popularly known as 'grace period', which I find a bit of a misleading characterisation myslef.
    But this raises a good point: because the MDR system was still under construction so much, most of the market did not really experience the previous four years as a meaningful transitional period.

    ------------------------------
    Erik Vollebregt
    Partner
    Amsterdam
    Netherlands
    ------------------------------



  • 3.  RE: Happy EU MDR Compliance Day !

    Posted 27-May-2021 07:24
    All I can add is that the EU has implemented a bureaucratic nightmare, and the whole MDR should at most apply to Class IIb and Class III devices.  My firm is pulling our Class Is device from the market because the margins don't bear the increased costs.  And yes, the period between the 2017 adoption of the MDR and the Date of Application was largely meaningless, as implementation guidances were not forthcoming for the most part until 2020, and many are still lacking.  Plus, there is the NB nightmare.  We could blame all of this on COVID, but I don't think the EU had it in one bag to start with and hastily (don't confuse that with quick, they aren't quick with anything) foisted a stifling regulation on the industry that will be detrimental to the healthcare of the people under their dominion.  Hate to say it, but at least FDA thinks things through a bit better.

    ------------------------------
    James Bonds J.D.
    Director Regulatory Affairs
    Atlanta GA
    United States
    ------------------------------



  • 4.  RE: Happy EU MDR Compliance Day !

    Posted 27-May-2021 10:28
    It was like a marathon that turned into a sprint at the end with QMS and PMS updates... 

    It will be interesting to see how many devices leave the market the next few years.

    ------------------------------
    Alyssa Roelli
    Regulatory Projects Manager
    Diversatek Healthcare
    Milwaukee WI
    United States
    ------------------------------



  • 5.  RE: Happy EU MDR Compliance Day !

    Posted 27-May-2021 11:22
    Edited by Ed Panek 27-May-2021 11:23
    And with Brexit and Switzerland issues!  We made all the QMS changes and EORI requirements yesterday and trained everyone so we can begin our MDR application formally with our NB in a few weeks. As James says above me though, I am not certain these changes make the users of our IIa device much safer.

    ------------------------------
    Edward Panek
    VP, QA/RA
    Med Device
    USN Veteran
    Research into Neural Nets - https://www.twitch.tv/edosani
    ------------------------------