Regulatory Open Forum

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  • 1.  MDD Harmonized Standards

    Posted 29-Mar-2020 12:07

    There is a new Commission Implementing Decision on harmonized standards for the MDD. You can download it at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.LI.2020.090.01.0001.01.ENG&toc=OJ:L:2020:090I:TOC

    One important point is Article 3, "The harmonized standards for medical devices drafted in support of Directive 93/42/EEC and listed in Annexes I and II to this Decision may not be used to confer presumption of conformity with the requirements of Regulation (EU) 2017/745".

    For 13485 the harmonized standard becomes EN ISO 13485:2016 with EN ISO 13485:2016/AC:2018.

    For 14971, the harmonized standard remains EN ISO 14971:2012.

    There is a similar list for the IVDD at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.LI.2020.090.01.0033.01.ENG&toc=OJ:L:2020:090I:TOC

     

     

     



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 2.  RE: MDD Harmonized Standards

    Posted 29-Mar-2020 20:26
    Interesting move, maybe also interesting timing?

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    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
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  • 3.  RE: MDD Harmonized Standards

    Posted 30-Mar-2020 01:46
    To be honest, I do not get what this means.  There are still so many that are out of date and some not on the list.  What is the point of publishing something when it is still out of date, even for the EU MDD?  Companies should be using current industry practices - meaning using the current version of standard - which is expected by most regulatory authorities and auditors.  At least the ISO 13485 standard is now current.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: MDD Harmonized Standards

    Posted 30-Mar-2020 09:53
    I agree seems a bit odd.  Maybe it means something. Maybe that will become clearer in time, maybe not.  Or maybe it just means some socially distanced people had some extra time on their hands and decided to update their list instead of reorganizing their closets.

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    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 5.  RE: MDD Harmonized Standards

    Posted 31-Mar-2020 06:18
    From what i know, there was a lot of pressure to the EU to harmonize some standards, because they stopped harmonizing from 2017.
    So, they just harmonized some standards that are useful for the devices which are used throughout the Covid crisis.
    In my opinion, it is a stupid move and very sloppy. I do not see the point of harmonizing some standards for a "dying" directive. Are they going to harmonize this year also standards for MDR? I do not think so...

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    Spyros Drivelos
    Medical Devices Expert, RAC
    Agia Paraskevi, Athens
    Greece
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  • 6.  RE: MDD Harmonized Standards

    Posted 01-Apr-2020 19:21
    I have wondered if this might be related to the EC's proposals to keep the "dying" MDD on life support for another year, by which  time, who knows, it might be the MDR that is dying.  Perhaps as they proposed keeping the MDD for another year, they wanted to avoid the criticism that "the standards haven't even been harmonized"?  Although I agree with Richard that everyone should be using the most current version of the standards, harmonized or not, I think the proposal drags things into the political realm, and I'm doubtful politicians understand any of this, while "those standards haven't even been harmonized" just doesn't sound good.

    I have also wondered if updating the list served as an opportunity to say that these standards "may not be used to confer presumption of conformity with the requirements of Regulation (EU) 2017/745".

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    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------