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  • 1.  EU MDR 2017/745 Annex III - Technical Documentation

    Posted 01-Nov-2021 05:03

    As part of the new technical documentation requirements for medical devices, manufacturers are required to create a procedure for "methods of communication with competent authorities, notified bodies, economic operators, and users."

    I can't seem to find many good resources on this to make sure all bases are covered, has anybody else, and if so please do share them!

    Many Thanks



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    Jack Bacon
    Leeds
    United Kingdom
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  • 2.  RE: EU MDR 2017/745 Annex III - Technical Documentation

    Posted 01-Nov-2021 13:48

    Start with ISO 13485:2016, 7.2.3 second paragraph. Expand you implementing SOP to cover the regulators in the MDR which should include your Authorized Representative, Notified Body, and Competent Authority.

    I add Authorized Representative because some have my clients have an Authorized Representative that reviews the Technical Documentation, etc. as if they were a Notified Body.

    To satisfy the Annex III requirement point to the SOP.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 3.  RE: EU MDR 2017/745 Annex III - Technical Documentation

    Posted 01-Nov-2021 15:23
    Edited by Kevin Randall 01-Nov-2021 15:25
    When setting up your EU MDR Annex III "methods of communication with competent authorities, notified bodies, economic operators, and users.", be sure to clearly address each of these categories.  For example, if we only included methods for communicating with ARs, NBs, and CAs, then such methods will fall short of the cited Annex III requirement.

    Also, don't forget that the cited requirement is specifically in regards to post-market surveillance.  Accordingly, be careful not to convolute this EU MDR Annex III post-market surveillance requirement with the general customer communication (e.g., basic product information, customer enquiries, contract review, order handling, etc.) of ISO 13485 clause 7.2.3.

    Ultimately, this procedure should say something like:

    1. The organization communicates with its Authorized Representative in accordance with the corresponding procedures in this CE Marking SOP, in the written mandate executed between the organization and Authorized Representative, in the design change procedures, in the EU Serious Incident Reporting SOP, and in the Recall SOP.
    2. The organization communicates with Notified Bodies (if any are involved) in accordance with the corresponding procedures in this CE Marking SOP, in any contracts executed with the Notified Body, in the design change procedures, in the EU Serious Incident Reporting SOP, and in the Recall SOP.
    3. The organization communicates with Competent Authorities by way of the organization's PRRC and Authorized Representative in accordance with the EU Serious Incident Reporting SOP and the Recall SOP.
    4. The organization communicates with its importers and distributors in accordance with the corresponding contract(s) and Complaint Handling SOP, and also by way of the Order Fulfillment SOP.
    5. The organization communicates with customers and other stakeholders in accordance with the EU MDR Post-Market Surveillance SOP, the Complaint Handling SOP, and the Recall SOP.


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    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2021 by ComplianceAcuity, Inc. All rights reserved.
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  • 4.  RE: EU MDR 2017/745 Annex III - Technical Documentation

    Posted 02-Nov-2021 03:28
    Hello Anon,

    That is a really good list Kevin provided as indeed important to address all of those external entities which the company interacts with and most importantly this "communication" and what this means.  I would just offer a suggestion is do not write a procedure just to have a procedure to address point in Annex III.  Yes, you need to have a procedure because it will be asked for, but consider how your company does business.  Review your processes to have procedure ... or even procedures ... addressing how communication occurs with each of these parties.  Review processes related to all external parties even sister companies, subsidiaries, contract manufacturers, or even other regulatory agencies (FDA, HC, TGA).

    Think about this, we start with a general Communications procedure which details the different sources of communication, which is then separated into sections in the procedure or makes references to other procedures.  Also as stated, make sure to clearly define types of communication which occurs.  As an example, SOP 22 Communications > Section 2.1 Customer Communication > Section 2.1.1 Customer Orders - references SOP 34 Customer Orders > Section 2.2.2 Technical Support - references SOP 38 Servicing and Technical Support > Section 2.2.3 Customer Complaints - references SOP 42 Customer Complaints.  As with the EU MDR many processes are inter-related and definitely pushes a process approach so again instead of just writing a procedure, map out your communication processes, activities, inputs, outputs, to show document how these are done.  But yea, make sure to have a procedure(s) :).

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 5.  RE: EU MDR 2017/745 Annex III - Technical Documentation

    Posted 02-Nov-2021 03:51
    Thank you very much Richard, that's great feedback, I appreciate your help!

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    Jack Bacon
    Leeds
    United Kingdom
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  • 6.  RE: EU MDR 2017/745 Annex III - Technical Documentation

    Posted 03-Nov-2021 09:06
    Richard

    This is a great plan.   During an audit I recently had to physically point out the different SOPs that included communications, and that worked for now. BUT someone else might not remember all the underlying processes/procedures during the next audit.

    A very high level pointer would work too, as long as it stays high level and is consistent with what it is pointing to.




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    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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  • 7.  RE: EU MDR 2017/745 Annex III - Technical Documentation

    Posted 02-Nov-2021 03:50
    Thank you very much for the feedback Kevin its a great help!

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    Jack Bacon
    Leeds
    United Kingdom
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  • 8.  RE: EU MDR 2017/745 Annex III - Technical Documentation

    Posted 02-Nov-2021 03:49
    Thankyou for the advice, good tip with the EU Authorized Rep!

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    Jack Bacon
    Leeds
    United Kingdom
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  • 9.  RE: EU MDR 2017/745 Annex III - Technical Documentation

    Posted 02-Nov-2021 10:47
    Also, don't write a procedure to just meet a requirement as Richard said but write it to meet your own company processes specifically.  Also, try not to write convoluted and long SOPs as users won't use them and then they will only be used by those that write them and you will end up with SOPs that you get non-conformances against.  Make them as simple and clean as possible. The easier to use the more likely they will be followed.  Read-only training is not always the best option as I have seen many companies fall into that trap and fail during audits for training.

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    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
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