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  • 1.  IEC 60601-1 3.1 edition

    Posted 23-May-2018 16:56
    Hi Everyone,

    I know the compliance with IEC 60601-1 edition 3.1 was effective from Jan 1st, 2018 for Europe. My question is the compliance optional?

    Thanks,
    Sheemah

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    Sheemah Kazi

    Concord CA
    United States
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  • 2.  RE: IEC 60601-1 3.1 edition

    Posted 24-May-2018 05:09
    Hi Sheeman,

    For EN 60601-1 ed. 3.1 the date of cessation of presumption of conformity of superseded standard was 31/12-2017.

    As such, per 01/01-2018 compliance with ed. 3.0 is not sufficient to provide presumption of compliance, as that version of the standard is no longer harmonised.

    It is voluntary to use harmonised standards to demonstrate compliance with the essential requirements of the applicable EU directives for CE marking. It is however the simplest approach, as compliance with a harmonised standard allows the manufacturer to presume compliance with essential requirements covered by the scope of the standard.

    If through your risk management activities and other design verification / validation activities, you can demonstrate that the product is in compliance with all relevant essential requirements you can do that without applying a harmonised standard. It is, however up to the manufacturer to document and argue why the applied methods are adequate and sufficient.

    So yes, compliance with ed. 3.1 is optional, if your applied methods for demonstrating compliance are justified.
    So, I would recommend compliance with ed. 3.1 as the simplest approach.

    If you have a notified body involved in the authorisation proces, I would recommend to agree on your approach with them up front. As compliance with harmonised standards is most often the least cumbersome route.

    Let me know if you need additional clarification.

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    Claus Rømer Andersen
    Hørsholm, Denmark
    claus@roemerconsulting.dk
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  • 3.  RE: IEC 60601-1 3.1 edition

    Posted 24-May-2018 07:24
    Hello,

    I agree with all that Claus said.  

    One additional note is that if you are going into the US market you will want to also make sure that you meet AAMI ES 60601-1 (there are a couple pages of national deviations). Again just like an EU Harmonized Standard the US FDA Recognized Consensus Standards are voluntary.  Canada is pretty similar but you can use IEC or the CAN CSA C22.2No. 60601-1:14.

    Best,


    ------------------------------
    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
    ------------------------------



  • 4.  RE: IEC 60601-1 3.1 edition

    Posted 24-May-2018 11:55

    I don't with the IEC 60601 series very often, but it comes up in my risk management work. Keeping the versions organized in my mind, as a result, is often a problem.

     

    In this case, the most recent question relates to the international version as compared to the EU harmonized version.

     

    People often refer to these standards by edition number rather than by the year of publication as is common with other standards.

     

    I believe that when people say IEC 60601-1 Edition 3.1 this is a synonym for EC 60601-1:2005/AMD1:2012. When I checked the IEC website there is a note that says, "The contents of the corrigendum of July 2014 have been included in this copy."

     

    However, the IEC webpage has a summary table. One of the entries is Edition which says 3.0.

     

    Looking at the history tab there are two entries listed as Edition 3.1

    IEC 60601-1:2005+AMD1:2012 CSV/COR1:2012

    IEC 60601-1:2005+AMD1:2012 CSV

     

    I believe CSV mean consolidated version.

     

    Looking at the TRF table, I infer that current version is IECEE TRF 60601-1K:2015.

     

    My first question deals with the proper documents for, what people call, Edition 3.1. Are they IEC 60601-1:2005+AMD1:2012 CSV/COR1:2012 and IECEE TRF 60601-1K:2015?

     

    When I look at the table of standards harmonized to the MDD it appears the current harmonized standard is EN 60601-1:2006/A1:2013.

     

    With the exception of potential Z Annexes is EN 60601-1:2006/A1:2013 the same as IEC 60601-1:2005+AMD1:2012 CSV?

     

    Because the harmonization process is behind schedule, is there an EU version that is not yet harmonized?



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    Dan O'Leary
    Swanzey NH
    United States
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  • 5.  RE: IEC 60601-1 3.1 edition

    Posted 24-May-2018 07:49
    Hello Sheema,

    Well all voluntary standards are optional in some sense, in that they are "voluntary" unless FDA has required them in a performance or special controls guidance. But  generally, no, it is hard to find another way to satisfy this requirement and justify not doing thos testing.

    Also, not only does FDA expect and thus " require" it, OSHA expects and requires it for worker safety too if it  is a medical device.

    Good luck!

    Ginger Cantor, MBA, RAC
    Centaur Consulting LLC centaurconsultingllc@gmail.com
    (715) 307-1850





  • 6.  RE: IEC 60601-1 3.1 edition

    Posted 25-May-2018 02:29
    Edited by Karthik Hoskere 25-May-2018 02:30
    Hi Sheemah,

    As per my understanding, Compliance to 60601-1, 3.1 ed is mandatory as it is already listed in the OJE and deadline is 31-Dec-17. Incase if the particular standard is still not harmonised, may be you can leverage from that. Considering the fact that particular standard has precedence over the basic standard, you might wait till the particular standard is harmonized.

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    Karthik Hoskere
    Regulatory Operations Sepcialist

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  • 7.  RE: IEC 60601-1 3.1 edition

    Posted 27-May-2018 16:12
    Hi Sheemah,

    You have gotten lots of feedback. 

    Yes, in the US, Canada and Europe the standards mentioned are all voluntary but if you don't use them your burden of proof does go up with the regulator so you might as well use them, as Ginger Cantor mentioned.

    The version of the standard all 3 countries are using is 60601-1, edition 3.1 in the national version and in Canada you can use the IEC version too. The CSV that Dan mentions is a Consolidated version which is something that IEC has been issuing for the last couple years now.  Makes life a lot easier because when you have an edition with an Amendment you see the changes of the Amendment in one consolidated version.  With IEC 60601-1:2005 (3rd edition) + Amendment 1:2012 it is much easier to read what the 496 changes are compared to reading 2 separate documents which is the way used to be published and not something that was easy to deal with.

    The harmonization of most of the MDD EN 60601-2-XX standards has been very problematic and as there is a huge back log that the EU Commission has made for these standards as they have not agreed with the way to deal with the Annex Z's so a majority of the EN 60601-2-XX CENELEC and CEN updated current standards have not been Harmonized under the MDD because of this disagreement with the EU Commission.  So, the Harmonized Standards are not really the 'State of the Art' as required under Annex I (Essential Requirements) of the MDD.  My recommendation to my clients is have them contact their Notified Body and discuss with them to get agreement on a plan (does the client need to do a gap analysis or other analysis from the Harmonized version to the one that is 'State of the Art'?).  The priority of how I approach the 'State of the Art' is 1) Use 'State of the Art' Harmonized Standards, for those that are not Harmonized 2) use the most recent version of the CEN or CENELEC version of the standard, if updated to track with the IEC or ISO version of the standard, and lastly 3) use the most recent version of the IEC standard, if CENELEC or CEN not updated.  An Article in InCompliance Magazine will be published on June 1, 2018, that I authored, that discusses this specific issue and I show examples in the article and much more about finding the right standards for the US, Canada and Europe focused around Medical Electrical Equipment.  The article is titled "How to Stay Up to Date on Ever-Changing Landscape of the Medical Electrical Device Regulatory World", with a sub-title "Standards and Regulatory Update on Medical Electrical Devices".

    Best of luck on your venture with standards and regulations,


    ------------------------------
    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
    ------------------------------



  • 8.  RE: IEC 60601-1 3.1 edition

    Posted 28-May-2018 07:52
    Hi Leonard,


    You know what would be great? If there was a generally equivalent table... E.g., IEC 60601-1:2005+ A1:2012= xxxxxxx.

    I can usually find my way around these, but  with national deviations in many countries, and "Z" annexes for EU, it is confusing to everyone, especially those new to it.

    Does such a table exist?

    Thanks, 

    Ginger Cantor, MBA, RAC
    Centaur Consulting LLC centaurconsultingllc@gmail.com
    (715) 307-1850






  • 9.  RE: IEC 60601-1 3.1 edition

    Posted 01-Jun-2018 10:21

    Leonard,

    I just read your great article published by In Compliance magazine. It provides a clear picture of a complicated subject. Thank you.



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    Dan O'Leary
    Swanzey NH
    United States
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  • 10.  RE: IEC 60601-1 3.1 edition

    Posted 02-Jun-2018 02:57
    Dan,

    Thx for the nice note about my article in InCompliance Magazine.  

    For those that want a link to my article titled "How to Stay Up to Date on The Ever-Changing Landscape of the Medical Electrical Device Regulatory World - Standards and Regulatory Update on Medical Electrical Devices" click here.  Or you can download the whole magazine with this link.

    Enjoy and let me know your thoughts on the article.

    Also, if you want to read previous articles I have written for InCompliance Magazine please go to this link.

    Thx and keep the feedback coming in.  Please feel free to repost these links but if you want to repost any of the articles in full or partially you will need to contact the editors of InCompliance Magazine for their permission.

    Cheers,

    ------------------------------
    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
    ------------------------------