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SOFTWARE AS A MEDICAL DEVICE

  • 1.  SOFTWARE AS A MEDICAL DEVICE

    Posted 17-Jul-2020 13:56
    Dear all,
    I need your advise please.
    I'm wondering in which case the software should be considered as a medical device for US , Canada, Europe.
    For example a software used internally to design a specific implant, can I say that it also a device?
    Thank you in advance for your help.
    Rgds,

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    Nadine Adia
    Quebec QC
    Canada
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  • 2.  RE: SOFTWARE AS A MEDICAL DEVICE

    Posted 18-Jul-2020 03:21
    Hi Nadine
    Google MEDDEV 2.1/6, there is a flow chart on page 11 I find helpful to answer your question. Software for the design of an implant is not a medical device. But it is a computer system that requires QA and validation.
    Hope this helps, stay well.
    Hans

    ------------------------------
    Hans Strobel
    CEO & Co-Founder
    dokspot GmbH
    Zürich, Switzerland
    www.dokspot.io
    ------------------------------



  • 3.  RE: SOFTWARE AS A MEDICAL DEVICE

    Posted 18-Jul-2020 11:35
    Hello Nadine,
    You may wish to check the IMDRF organization which developed the SaMD consensus standards which most regulatory authorities recognize. 
    http://www.imdrf.org/docs/imdrf/final/technical/imdrf-tech-151002-samd-qms.pdf
    https://www.fda.gov/media/100714/download#:~:text=Software%20as%20a%20Medical%20Device%20%28SAMD%29%3A%20Clinical%20Evaluation,Administration%20Staff%20Document%20issued%20on%20December%208%2C%202017.

    ------------------------------
    [Peter] [Ackerman]
    [Managing Partner]
    [Advanced Medicals Consortium, llc]
    [Los Angeles] [CA]
    [pa@thehumansystem.com]
    ------------------------------



  • 4.  RE: SOFTWARE AS A MEDICAL DEVICE

    Posted 18-Jul-2020 17:39
    Hello,

    First, software as a medical device (SaMD) and software in a medical device (SiMD) have different regulatory implications. The former is a standalone device which is separately cleared. For Canada, I suggest that you start with this: https://www.canada.ca/en/health-canada/services/drugs-health-products/medical-devices/application-information/guidance-documents/software-medical-device-guidance-document.html  to make a regulatory determination. 


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    Karen Zhou
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  • 5.  RE: SOFTWARE AS A MEDICAL DEVICE

    Posted 18-Jul-2020 21:31
    Hi Nadine,

    Based on the (limited) information that you have provided, it seems that this software used to design specific implant is not a medical device (i.e. not a SaMD), based on the definition of SaMD per IMDRF. However, you will need this software to be validated for audit purposes. 

    Refer to IMDRF guidance, FDA guidance, Health Canada Guidance on SaMD. 

    Also refer to this article in link below:

    https://orthogonal.io/insights/software-as-a-medical-device-samd-basics/

    Hope this helps. 

    Best,
    Hemang.

    ------------------------------
    HEMANG KOTECHA
    Wayne NJ
    United States
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  • 6.  RE: SOFTWARE AS A MEDICAL DEVICE

    Posted 19-Jul-2020 13:07
    Nadine,

    The best resource you can use for determining if software is considered a medical device or not is the IMDRF guidance mentioned above and the recently updated UK MHRA guidance document https://www.gov.uk/government/publications/medical-devices-software-applications-apps.  These documents provide helpful information when considering software as a stand alone medical device application and when it would not be considered a medical device.  Your situation may or may not be a medical device as if this is used for Additive Manufacturing - meaning involved in specific patient configuration, it might be part of the "system."  There would need to be more information about what your software does, but those guidance should help as they have some examples.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 7.  RE: SOFTWARE AS A MEDICAL DEVICE

    Posted 20-Jul-2020 09:56
    As a note though, the exact nature of this design tool matters. For instance, software used by a medical device company to design implants would not meet the definition of a device. However, software sold to a hospital (or surgeon) for use in designing custom implants most likely would be considered a medical device [note: even if it is the same software].

    Thus, I'd encourage you to write a thorough description of the software and its intended use (including site of use, intended users etc) and compare it to the definition of a medical device. As others have noted, if it is not a medical device, it could very well be software being used in your QS and thus should be validated appropriately.

    g-

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    Ginger Glaser RAC
    Chief Technology Officer
    MN
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  • 8.  RE: SOFTWARE AS A MEDICAL DEVICE

    Posted 21-Jul-2020 08:34
    Ginger Glaser brings up a great point.  If software is used in surgeries to design/plan for creating custom devices or surgical approaches/treatment planning, then it is usually regulated as medical  device. (Look under Procode LLZ for  examples).

    With  practice  of medicine, a doctor  may develop and use their own software and may use even within their limited associated  practice (is treated with enforcement discretion).   But once it gets sold to others and used more widely, it becomes regulated and enforced.

    Intended use/risk management will then drive Level of Concern/Safety Class analysis and required software D&D per IEC 62304.


    ------------------------------
    Ginger Cantor, MBA, RAC
    Founder/Principal Consultant
    Centaur Consulting LLC
    River Falls, Wisconsin 54022 USA
    715-307-1850
    centaurconsultingllc@gmail.com
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  • 9.  RE: SOFTWARE AS A MEDICAL DEVICE

    Posted 21-Jul-2020 11:57
    Indeed this is a good point that needs to be noted. there is a nuance to be made on this aspect.
    Thant you so much. It's clear for me.

    ------------------------------
    Nadine Adia
    Quebec QC
    Canada
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  • 10.  RE: SOFTWARE AS A MEDICAL DEVICE

    Posted 21-Jul-2020 11:53
    The software is not sold to an hospital (or surgeon) for use in designing custom implants.
    Thank you for your advise. Much appreciate


    ------------------------------
    Nadine Adia
    Quebec QC
    Canada
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  • 11.  RE: SOFTWARE AS A MEDICAL DEVICE

    Posted 20-Jul-2020 09:18
    Thank you all for your answers and all the supporting documents.
    Everything is now clear, it was very helpful. Much appreciated.
    Rgds,

    ------------------------------
    Nadine Adia
    Quebec QC
    Canada
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