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) :).
------------------------------
Richard Vincins RAC
Vice President Global Regulatory Affairs
------------------------------
Original Message:
Sent: 01-Nov-2021 15:23
From: Kevin Randall, RAC
Subject: EU MDR 2017/745 Annex III - Technical Documentation
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:
- 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.
- 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.
- 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.
- 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.
- 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.
------------------------------
Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
Principal Consultant
Ridgway, CO
United States
© Copyright 2021 by ComplianceAcuity, Inc. All rights reserved.
Original Message:
Sent: 01-Nov-2021 13:48
From: Dan O'Leary
Subject: EU MDR 2017/745 Annex III - Technical Documentation
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.
------------------------------
Dan O'Leary CQA, CQE
Swanzey NH
United States
Original Message:
Sent: 01-Nov-2021 05:02
From: Jack Bacon
Subject: EU MDR 2017/745 Annex III - Technical Documentation
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
------------------------------
Jack Bacon
Leeds
United Kingdom
------------------------------