Regulatory Open Forum

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  • 1.  Benefit/risk analysis

    Posted 26-Apr-2021 02:37
    Dear all,

    is there a guideline explaining methodologies to perform a benefit/risk analysis under MDR, and to identify the related thresholds for continuous re-evaluation? I had a look to the FDA guideline, but it is quite generic. I was looking for some technical specifications. 

    Thank you very much

    C.

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    Christian Micheletti
    Project Manager; Regulatory Affairs expert
    Nouvag AG
    Zurich
    Switzerland
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  • 2.  RE: Benefit/risk analysis

    Posted 26-Apr-2021 14:57
    It has been my experience that EN ISO 14971:2019 is generally considered to be state of the art for the EU MDR.  Accordingly, I've found useful its clause 7.4 and its corresponding guidance in ISO/TR 24971:2020 clause 7.4.  Also of note is that recent HAS Consultant output from Europe's ongoing EU MDR harmonization efforts for EN ISO 14971:2019 refers stakeholders to Annex A7.2 of MEDDEV 2.7/1 rev. 4.

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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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  • 3.  RE: Benefit/risk analysis

    Posted 26-Apr-2021 15:26
    Regarding thresholds for continuous re-evaluation, this needs to be set commensurate with the risk and complexity of the subject device, and in conjunction with the corresponding mechanism in the risk management process for ongoing re-evaluation of risk (e.g., see EN ISO 14971;2019 clause 10) along with the associated process for updating the clinical evaluation.  These mechanisms should have a baseline policy for re-review / reassessment of the benefit-risk ratio at a routine frequency, where that frequency can generally be less for lower-risk devices, and more for higher-risk devices.  Then in addition, in order to properly react to emerging quality issues, each time a new/modified risk is identified under the ongoing monitoring called for by EN ISO 14971;2019 clause 10, the benefit/risk ratio should also be considered for reassessment.  As far has more technical specifications in a guidance document, I know of none, but would be glad to hear others' input on that.

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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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