Regulatory Open Forum

 View Only
  • 1.  Document Control - Marketing Literature

    This message was posted by a user wishing to remain anonymous
    Posted 02-Apr-2019 08:14
    This message was posted by a user wishing to remain anonymous

    Hi All,

    We have an internal debate on which marketing literature needs to go through our QMS document control system.
    My input was anything that has Instructions for Use or any type of record based information from the DMR that a physical property/composition/or related is displayed.  Am I missing anything?

    Some would like to put everything in the QMS (easier to manage) - unhappy marketing people. 
    I would like to proposes a solution that would keep us compliant and be the least restrictive to the marketing team.

    Any thoughts would be appreciated.

    Thank you,


  • 2.  RE: Document Control - Marketing Literature

    Posted 02-Apr-2019 12:00
    In my experience, we control websites, marketing material, promotional materials, pamphlets, brochures, etc., anything that makes a claim about the device or communicates its intended use. 

    The term 'labeling' is defined in the FFDCA as including all printed matter accompanying any article. The term 'accompanying' can be interpreted to mean more than just physical or electronic labeling with the product itself.  This can extend to posters, brochures, marketing material, websites, etc. It's important to review and control marketing/advertising material to ensure the product is being advertised per its intended use, and any claims made are substantiated with data.

    ------------------------------
    Brittany Gibson BSc
    Director, Quality and Regulatory Affairs
    Winnipeg MB
    Canada
    ------------------------------



  • 3.  RE: Document Control - Marketing Literature

    Posted 03-Apr-2019 06:23
    Everything ! ... with a Austin Powers guff laugh.  In my own experience, based on the classification of the device, we put all marketing literature through quality system review, assigned a number, revision level, etc., especially for higher risk Class II products and Class III products.   Lower classification products like Class I maybe you have more flexibility about not controlling every marketing brochure.

    There are different ways to handle marketing literature not being so unwieldy for your marketing personnel, like at one company we had a completely separate marketing approval process.  This was a process that was handled by marketing, it was an approval, numbers were assigned, but quality and/or regulatory also approved the marketing literature.  Purpose for review was to confirm claims, statements, and references to clinical information.  Under the EU MDR, this is going to be even more critically reviewed since the clinical evaluation needs to align with statements, risk, and claims that are made in any type of marketing literature.  I worked at a couple companies managing marketing literature like Brittany mentions, we controlled everything including websites.  The regulatory aspects must be reviewed to make sure no claims, indications, or intended purpose of the device is being made that is not consistent with the regulatory filings, safety of device, and performance requirements.

    ------------------------------
    Richard Vincins RAC
    Vice President Global Regulatory Affairs
    ------------------------------



  • 4.  RE: Document Control - Marketing Literature

    Posted 04-Apr-2019 11:20
    We review (cross-functional review involving marketing, legal, RA) and document control every 'use' related material but add to QMS document control system only those materials that will be sent to regulatory authority i.e. DFUs, patient/physician guides and labels. Product brochures/catalogs go through so many revisions (SKU related, not use/risk statements or manufacturer change) that it becomes cumbersome to control everything via a Change Order. Any promotional material created by sales is vetted thoroughly by a team of legal, clinical and RA members.

    ------------------------------
    Vidyalakshmi Jayaraman
    RA Specialist
    Marlborough MA
    United States
    ------------------------------