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How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

  • 1.  How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    Posted 21-Jan-2022 12:56
    Hello all,

    As the comparison was done between CEN, EVS, ISO ,and BS standards and found some EN standards are recent but some are not harmonized.
    So for EUMDR how we prepare the list.
    As for my knowledge  we prepare the list with recent EN standards but is it correct as some are not harmonized.
    And how to address the amendments in the list. 
    As per EUMDR ,qualification of each standard is required which we will mention in GSPR. So is it correct.

    Plz give the input



  • 2.  RE: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    Posted 21-Jan-2022 13:37

    HERESY ALERT At this point, whether a standard is harmonized is of no value. It is more important to use the most recent EN standard including any amendments.

    For GS&PR, use the most recent applicable standard. Give preference to EN standards over international standards when they have the same technical content. The list of standards on the CEN/CENELEC website lists the corresponding international standard.

    If the current version of an international standard is ahead of the EN standard, use the international standard as state of the art. At some point, the EN standard will catch up.

    You need to cite the standard you actually used. If it is not the latest, i.e., not state of the art, then you need a plan to implement the latest one. A similar situation applies if the standard changes.

    You need to cite the standard correctly, including all amendments. For example, you should be using and citing EN ISO 14971:2019/A11:2021. By convention, for EN standards, people don't include the standards body that published the standard. You could cite, instead EVS-EN ISO 14971:2019/A11:2021.

    For any standard used, note whether it is harmonized. You cannot tell from the citation.

    You say, "As per EUMDR, qualification of each standard is required". I don't understand the remark. Could you provide more information?



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 3.  RE: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    Posted 21-Jan-2022 13:50

     

     

     

    Dan, for what it's worth, you are not the sole heretic on this matter!

     

    Ted

     

     

     

     






  • 4.  RE: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    This message was posted by a user wishing to remain anonymous
    Posted 23-Jan-2022 16:25
    This message was posted by a user wishing to remain anonymous

    Thanks for the input.

    Qualification means the purpose of use the particular standard or the scope of standard , if I am not wrong.
    This is to be included in the GSPR in front of the particular standard as per MDCG 2021-08 , page no. 5, GSPR and list of standards applied.

    Instead of qualification ,the term used in format is Justification.



  • 5.  RE: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    Posted 24-Jan-2022 11:21

    I looked at MDCG 2021-08 Clinical investigation application/notification documents dated May 2021. It has only four pages, so I didn't find your reference to page 5. However, it does contain another document titled Checklist of general safety and performance requirements, Standards, common specifications, and scientific advice.

    This is in two parts one is a list of the "Standards, common specifications, scientific advice obtained from expert panels according to article 106 MDR". The other is a GS&PR checklist which asks for a list of "Standards and common specifications used in full or in part" and "Justification/ comment in case of deviation"

    In other words, you don't justify using a particular standard or common specification. Rather, justify deviations from the standard or common specification used.



    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 6.  RE: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    Posted 24-Jan-2022 11:42
    Thank you sir for your input.
    But Can we convience the auditor with your input for this particular column as if their is deviation from the state of art standard for particular section in any of clause out of 23 in GSPR then only this is to be filled.



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    Amita Pandey
    Pandey
    Dehradun
    India
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  • 7.  RE: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    Posted 27-Jan-2022 16:54

    When you go through the GS&PR, identify the applicable requirements, and then decide how you will demonstrate that your device meets the requirement. There are many ways available, but the common method is to identify a standard and apply the applicable sections. The order of selecting standards is a) state of the art, b) harmonized standard, c) etc. Some NBs want to reverse the order but that is mistake. The good news is that there are very many harmonized standards.

    When you fill out the column, you need to address any deviations from the standard you selected, not any deviations from the GS&PR requirement. You must meet the GS&PR as written. Note, however, that some GS&PR requirements have multiple clauses. Some may apply and some may not, so you need to careful in determining applicability.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 8.  RE: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    Posted 27-Jan-2022 18:32
    Be sure not to overlook Annex II.4 first paragraph requiring us to justify the solutions (e.g., the standards) adopted to meet the GSPR.

    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2022 by ComplianceAcuity, Inc. All rights reserved.
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  • 9.  RE: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    Posted 28-Jan-2022 13:33
    Ok sir,
    But how to convience the auditor as they asked for the justification/ qualification column to be filled for each standard.
    Earlier it was as a remark column in ER checklist.
    Now what I am doing , just writing in front that so and so standard are for this purpose. And when the clause is not applicable then writing a Justification that device does not contain or belongs to particular clause.

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    AP
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  • 10.  RE: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    Posted 28-Jan-2022 13:36
    Here I would like to add that are these clauses of GSPR have relation with risk management ( Iso 24971 question to be asked during risk management)
    There are many question given as an example to be asked during RMP

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    AP
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  • 11.  RE: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized

    This message was posted by a user wishing to remain anonymous
    Posted 31-Jan-2022 09:45
    This message was posted by a user wishing to remain anonymous

    Out of the 23 clauses which clause covers clinical evaluation/ PMCF to be address.
    Is there any filled format for state of art standards against each clause 
    For all the clauses.
    Some Standards are 13485, 14971, 11135, 11607- 1&2, 25539, 10993 series, 
    10555, etc.
    As the GSPR is common for all types of medical devices which may be very in their applicable standarf.But some are common whether they are applicable or not.
    Like as I listed above and many more
    LIke USP/ EP for sterility
    Bioburden standard etc.