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  • 1.  IFU Readability

    Posted 28-Jan-2022 02:20

    Hello,

     

    Where can I find IFU readability requirements?

     

    Cathy Mills

    Senior Human Factors Design Engineer | Technical Communication

    Medtronic

    Diabetes Group

    18000 Devonshire Street | Northridge, CA 91325 | USA

    Cell 818.617-8691

    Cathy.N.Mills@Medtronic.com

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  • 2.  RE: IFU Readability

    Posted 28-Jan-2022 05:29
    Hi Cathy,

    Check out the following link

    https://ec.europa.eu/health/sites/default/files/files/eudralex/vol-2/c/2009_01_12_readability_guideline_final_en.pdf




    ---------------------------------
    Miriam OReilly


    Hod Hasharon
    Israel
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  • 3.  RE: IFU Readability

    Posted 28-Jan-2022 13:09
    Edited by Kevin Randall 28-Jan-2022 13:10
    For the context of medical device usability engineering rather than pharmaceuticals, I would direct you to ISO / EN ISO 20417:2021 such as, but not limited to, sub-clause 6.3 and Annex B (for devices with a built-in display of the IFU), and for all devices, sub-clauses 6.6.1(e) and 6.6.2(b & p), and for lay users 6.6.3(b, c, d, and maybe e), and also AAMI HF 75 [sections 11, 16, 19 (visual displays), and 24 (mobile device displays)], any and all done within the bounds and paradigms of IEC 62366.

    I also think FDA's guidance document "Applying Human Factors and Usability Engineering to Medical Devices (see 8.1.3 therein) is a useful beacon to help see how to apply the aforesaid standards and principles to instructions for use.  FDA's guidance Do It By Design and also Medical Device Use-Safety: Incorporating Human Factors Engineering into Risk Management may also help.

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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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  • 4.  RE: IFU Readability

    Posted 29-Jan-2022 07:45
    Hello Cathy,

    There are quite a few different requirements for IFU readability depending on medicinal products, OTC products, medical device for professional use.  There has been a couple provided already, but currently a defined requirement for EU MDR is concerning the Summary for Safety and Performance Characteristics (SSCP).  There is also some inference in Annex I, point 23 regarding content of labelling.  Depending on your product and the regulatory region there may be specific regulations or guidance to refer.

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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 5.  RE: IFU Readability

    Posted 30-Jan-2022 15:04
    One minor correction of Kevin reference for FDA is IEC 62366-1 is the current Recognized Consensus Standard.

    Also, in IEC 60601-1-11 home use medical electrical equipment, there is an eighth grade requirement for readability because being used by lay users. 

    20417 is a great resource and is a cross standard document that many standard will be referring too.  I would look to that as Kevin mentioned.

    ------------------------------
    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
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  • 6.  RE: IFU Readability

    Posted 30-Jan-2022 16:41

    One minor correction of Leo's reference to "IEC 62366-1".  My intent is to refer Cathy not just to IEC 62366-1, but also to the IEC 62366 series' "-2" guideline (IEC/TR 62366-2); thus the series/informal label "IEC 62366", which Cathy, a Senior Human Factors Design Engineer at a large global medical device company, will certainly understand.

    Another minor correction of Leo's reference to "IEC 62366-1" is that "IEC 62366-1:2015" is more correct.  Yet we could be even more legalistic by declaring that IEC "62366-1:2015" would also be erroneous.  To resolve that, we'd instead need to say something like "IEC 62366-1 Ed. 1.0 b:2015 plus IEC 62366-1 Ed. 1.0 b cor.1:2016 plus IEC 62366-1 Amd.1 Ed. 1.0 b:2020".

    Also, since we don't know Cathy's intended regulatory jurisdiction, it means that it's potentially misleading to assert the unspecified phrase, "...IEC 62366-1 is the current Recognized Consensus Standard..." without further clarification.  This is because the standards on the U.S. FDA's Recognized Consensus Standards list don't always (if ever at all) carry FDA's brand of consensus recognition in other jurisdictions outside the U.S.  I know of no other jurisdiction that has "recognized consensus" standards.



    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2022 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------



  • 7.  RE: IFU Readability

    Posted 30-Jan-2022 16:49
    Not to mention other adaptations of IEC 62366-1 like EN 62366-1 (i.e., EN 62366-1:2015, i.e., EN 62366-1:2015+A1:2020), and so on and so forth.

    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2022 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------