Regulatory Open Forum

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  • 1.  ISO 13485 Cert and CE Mark under MDD?

    Posted 22-Sep-2020 14:35
    I've had a few inquiries about certification to MDD.  Does anyone know whether NBs are willing/able to take on new clients to "fast track" ISO 13485 certification and device CE marking under the MDD given the transition to MDR on 5/26/21?  Appreciate your opinion on this.

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    Ronald Warren RAC
    San Diego CA
    United States
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  • 2.  RE: ISO 13485 Cert and CE Mark under MDD?

    Posted 23-Sep-2020 02:15
    Hi Ronald,

    "Fast tracking" was a procedure of many NBs so far, and some of them charged significantly higher amounts for the certificates. However, in most of the cases "fast tracking" was illegal, because the whole philosophy was "i pay a lot of money to get the certificate as soon as possible with the lowest possible effort". It seems like a bribe, isn't it?
    So, be careful on that. There are some NBs that will not operate under MDR and might searching for last minute good compensation.

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    Spyros Drivelos
    Medical Devices Expert, RAC
    Agia Paraskevi, Athens
    Greece
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  • 3.  RE: ISO 13485 Cert and CE Mark under MDD?

    Posted 23-Sep-2020 04:40
    Hello Ronald,

    There has been an "expedited" or "guaranteed review period" by Notified Bodies, but as Spyros commented, use some caution.  Notified Bodies repeatedly say in public forums they are only offering a service, nothing more.  However, I personally have an issue with that mentality and hope the National Authorities and Competent Authorities are having serious conversations with Notified Bodies because they are acting as an extension of the Competent Authorities.  It is not "just a service."  Off soapbox ... haha.

    To answer your question, because of the movement of the compliance date to May 2021 many Notified Bodies extended the ability continue re-certifying EU MDD products (the EC Certificate) instead of beginning of this year saying companies would need to move directly to EU MDR.  In fact, some Notified Bodies have said they will take new clients and new EU MDD CE Certification applications up to around the end of this year on a case-by-case basis.  You would have to call around to see who is taking on new clients.  Also keep in mind the issue with getting new ISO 13485 certification/EU MDD quality system certification during current times as onsite audits are not being performed normally - a Stage 2 initial certification most Notified Bodies have stated this needs to be onsite.  I understand many auditing organisations (not just Notified Bodies) are trying to be creative with performing audits considering the current state of the world.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: ISO 13485 Cert and CE Mark under MDD?

    Posted 23-Sep-2020 04:52
    Some of the current NBs are indeed accepting new clients, but I believe without a guarantee that the companies will be actually certified.
    With the current covid situation, most of the audits, including initial audits (not only surveillance) are conducted remotely, which is very tricky and difficult. In general, I do not know if an effort for MDD certificate right now worth the risk.
    Making a contract with an NB right now does not mean that you are going to be certified.

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    Spyros Drivelos
    Medical Devices Expert, RAC
    Agia Paraskevi, Athens
    Greece
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  • 5.  RE: ISO 13485 Cert and CE Mark under MDD?

    Posted 23-Sep-2020 09:06
      |   view attached
    Our NB allowed MDD review from June to Sept due to MDR delay. There is new guidance on sig change (New to me). Our NB is currently reviewing our sub change under MDD and provided us guidance to delay MDR requirements as long as we use the pdf attached for all changes until our cert expires in 2023. We took this pdf and made it into a memo format we can use for each change notice. It's similar to the FDA guidance on when to submit a new 510(k).

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    Edward Panek
    VP, QA/RA
    Blue Spark Technologies
    Research into Neural Nets - https://www.twitch.tv/edosani
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    Attachment(s)