Regulatory Open Forum

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  • 1.  FCC compliance

    Posted 28-Feb-2022 02:37

    Our product is Class II implantable device which has RF communication method.

     

    Do we need to be FCC compliance in addition to 21 CFR part 820?

     

    Thanks

     

     

    Assaf Yichia

    QA Manager

    Microbot Medical

    O: +972-4-8200710

    M: +972-52-2048535

    E: assafy@microbotmedical.com

    W: www.microbotmedical.com

     

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  • 2.  RE: FCC compliance

    Posted 28-Feb-2022 13:17
    You can read here some basic information about coordination between FDA and FCC rules:
    https://www.fda.gov/medical-devices/digital-health-center-excellence/wireless-medical-devices

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    Anne LeBlanc
    United States
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  • 3.  RE: FCC compliance

    Posted 01-Mar-2022 01:46
    Thanks Anne. if we pass all relevant tests according to the IEC 60601, which are relevant to our product including IEC 60601-1-2.. is it sufficient for be compliance with FCC requirements or shall we test our product at FCC lab? is there any place for FCC tests? 
    Thanks.


  • 4.  RE: FCC compliance

    Posted 01-Mar-2022 09:28
    60601-1-2 alone is not suitable for FCC compliance. There are a number of FCC accredited test labs you can search for by location here: https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm

    ------------------------------
    Wade Munsch
    Regulatory Affairs Manager
    Biotex, Inc.
    Houston TX
    United States
    Website: www.biotexmedical.com
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  • 5.  RE: FCC compliance

    Posted 01-Mar-2022 11:55
    If your device contains communication radios within the device, i.e., part of the device functionality you will need to do an assessment to the FCC regulations in the USA.  What determines the process is the radio/transmitters spectrum use.  An active medical device that transmits data via Bluetooth and Wi-Fi normally falls under PART 95 (FCC) but it is dependent on the frequency band used by the transmitter/radio.  For example 175kHz radios which are also used in active implantable device may only require a supplier DoC.  THis type of radio will be measured for radiated power level against the general requirement in Par 15.209 to ensure the radiated field is low enough to allow for FCC verification instead of certification (requires a submission to FCC).  Bluetooth components do not fall into this category, however keep in mind some devices may have both types of radios, depending on the intended use/device description/functionality.

    ------------------------------
    [Monica] [Montanez] [MS RAC CQA]
    [Principal Product Development Strategist]
    [NAMSA]
    [Bailey [Colorado]
    [mmontanez@namsa.com]
    ------------------------------



  • 6.  RE: FCC compliance

    Posted 02-Mar-2022 03:15
    Thanks Wade and Monica.

    Can you please clarify who should provide the DoC? the Lab or the company? 
    Is the DoC shall refer to the relevant IEC 60601 series or for FCC?

    Thanks
    Assaf