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  • 1.  ISO 62366-1:2015

    Posted 12-Feb-2017 15:50
    We are developing a "clinical sample concentrator" as defined by the FDA in its classification definitions.  These types of products are currently listed as Class I medical devices.  We are interested in taking this product into the EU as a CE-marked device.  We were wondering if ISO 62366 applies to Class I devices or is it related more to Class II and Class III products?  Any advice here is welcomed.

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    Michael Murphy
    Vice President
    Akonni Biosystems, Inc.
    Frederick MD
    United States
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  • 2.  RE: ISO 62366-1:2015

    Posted 12-Feb-2017 17:03

    First, don’t mix classification systems. The US has three device classes and the EU has four for medical devices; there is a different system for in vitro or active implantable devices.

     

    The US has a guidance document that implements ISO 62366-1:2015 and a draft guidance document that identifies a priority list of devices for which FDA expects usability information as part of the pre-market submission.

     

    The EU has a different system. Based on the Essential Requirements in MDD Annex I, determine if usability applies. If so, then implement the harmonized standard EN 62366:2008, based on IEC 62366:2007.

     

    Note that “any day now” the EU will replace the MDD with the MDR. Since we don’t yet have the details, it is not clear which standard would apply.



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    Dan O'Leary
    Swanzey NH
    United States
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  • 3.  RE: ISO 62366-1:2015

    Posted 13-Feb-2017 08:08

    Michael,

    ISO 62366 applies to ALL devices.  The standard defines a risk based HF Engineering program to integrate Human Factors into the design of the device, identify and address user needs and assess and mitigate all potential use errors throughout the life of the product.  You seem to be focusing on a HF Summative Validation study, which may not be required in all cases.  The US requirement is specific to the data that is need to be provided to the FDA, not whether a Human Factors Engineering process is required as part of the design effort.

    In the EU (and I would hazard all in the USA also, although it is not clearly integrated into the USA GMPs outside of design Controls) all classes of device need to meet the essential requirements, of which HF is a key element.  Compliance with ISO 62366 is the harmonized method of establishing that the use and ergonomic requirements have been met, regardless of the need for a Summative Validation study.

    Lee



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    Lee Leichter RAC
    President
    P/L Biomedical
    Fort Myers FL
    United States
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  • 4.  RE: ISO 62366-1:2015

    Posted 13-Feb-2017 13:27
    Hello All,

    First, as Dan mentioned this is an IEC standard not an ISO standard.  I even confirmed on the ISO website just now.

    Second, as Michael said this standard applies to all medical devices - active and non-active, implantable and implantable.

    Third, the most recently published version of the standard is IEC 62366-1:2015 has not been Harmonized under the EU MD or EU IVD Directives but if you follow what a lot of Notified Bodies are pushing you will want to use the state of the art (per Annex I of the MDD which is the Essential Requirements of the Directive).  The state of the art many times means the most recent version of the standard.  IEC and ISO are the source of many EN standards but not all.  In this case the most recent EN version is more recent than the Harmonized Standard. The most current version of the IEC 62366-1 has been adopted by CENELEC and been approved to publish in each EU country thru the appropriate standards body of that country like in the UK it is BSI. BSI published the current version as BSI EN 62366-1:2015 in June of 2015.  So, this version of the standard is an EN standard just not Harmonized thru the MDD currently.  Dan mentioned that the current MDD Harmonized standard is 'EN 62366:2008, based on IEC 62366:2007'.


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    Leonard (Leo) Eisner, P.E.
    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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  • 5.  RE: ISO 62366-1:2015

    Posted 14-Feb-2017 08:54
    Thank you for the clarification! Quite informational.  I am fairly new to regulatory affairs as well.  Learning to navigate through the world of standards and directives has been challenging.

    Whitney Davis

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    [Whitney] [Davis]
    [Global Regulatory Affairs Specialist]
    [Laboratory Products Division]
    [Thermofisher Scientific]
    [Marietta] [OH]
    [USA]
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