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.
Original Message:
Sent: 28-Jan-2022 13:35
From: Amita Pandey
Subject: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized
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
Original Message:
Sent: 27-Jan-2022 18:32
From: Kevin Randall, RAC
Subject: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized
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.
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Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
Principal Consultant
Ridgway, CO
United States
© Copyright 2022 by ComplianceAcuity, Inc. All rights reserved.
Original Message:
Sent: 24-Jan-2022 11:21
From: Dan O'Leary
Subject: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized
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.
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Dan O'Leary CQA, CQE
Swanzey NH
United States
Original Message:
Sent: 22-Jan-2022 01:49
From: Anonymous Member
Subject: 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
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.
Original Message:
Sent: 21-Jan-2022 13:37
From: Dan O'Leary
Subject: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized
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
Original Message:
Sent: 21-Jan-2022 12:55
From: Amita Pandey
Subject: How to prepare applicable standarf list with state of art standards for Class III implants as not all the standards are harmonized
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