As you indicate, the current lists of harmonized standards, according to the regulations, do not have a deletion date and application date column and I do not know either, if it is because these standards are for the first time harmonized standards under the regulations or if it is because as soon as they are published in the OJ they are considered to be in application, this will be seen during the updates, but as of today, as soon as a standard is harmonized under the regulations, i.e. is published in the OJ, it enters in application.
One question I have is about standards that are not yet harmonized, from when do they represent the state of the art? I always give the example of the ISO 14971:2019 standard which is not harmonized either under the directives or under the regulations and yet for NBs represents the state of the art and therefore must be applied. Who decides this and where can this information be found?
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PASCALE
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Original Message:
Sent: 27-Sep-2021 10:30
From: Dan O'Leary
Subject: European regulations (2017/745 & 2017/746) and standards
The post says, "for [a] harmonized standard it must be applied immediately after publication in the EUOJ". Is this true?
Under MDD and many other lists of harmonized standards there is a column "Date of cessation of presumption of conformity of superseded standard" which provides the end of the transition period.
The first list of MDR harmonized standards doesn't have that column. As I see it, it could be for two reasons. My expected reason is that, for the time a standard appears on the list there is no superseded standard, so the column would be blank, However, when a standard is superseded eventually, the column will reappear. My unexpected reason is a change in the approach from a transition period to immediate and overnight implementation.
The immediate and overnight approach applied to EN ISO 14971:2012. The reason given was that all manufactures already comply with the MDD, so the new version of the standard had no new information. It turned out that, for nearly all manufactures, the assumption did not hold.
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Dan O'Leary CQA, CQE
Swanzey NH
United States
Original Message:
Sent: 26-Sep-2021 02:41
From: PASCALE BLANGARIN
Subject: European regulations (2017/745 & 2017/746) and standards
Dear Leonard,
Thanks for your answer, yes for an harmonized standard it must be applied immediately after publication in the EUOJ, but before the harmonization what is the application date, like ISO 14971:2019 which is not still harmonized the date of application was, if I remember well, the 1st February 2020 and my question is for all the standards that we can use when is it mandatory or advised (state of the art) to applied them after the publication of a new version?
Thanks for your answer
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PASCALE
Original Message:
Sent: 25-Sep-2021 01:00
From: Leonard Eisner
Subject: European regulations (2017/745 & 2017/746) and standards
Now when Standards are Harmonized in the EU there is no transitions anymore. So, they would be effective immediatley.
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Leonard (Leo) Eisner, P.E.
The "IEC 60601 Guy"
Principal Consultant, Eisner Safety Consultants
Phone: (503) 244-6151
Mobile: (503) 709-8328
Email: Leo@EisnerSafety.com
Website: www.EisnerSafety.com
Original Message:
Sent: 24-Sep-2021 11:15
From: PASCALE BLANGARIN
Subject: European regulations (2017/745 & 2017/746) and standards
Dear all,
I have a question concerning the date on which a standard, harmonized or not, must be respected, i.e. when it was published, from when does it represent the state of the art? Is there a site that indicates this information?
Thanks at all for your answer
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PASCALE
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