Regulatory Open Forum

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  • 1.  MDD early renewal

    Posted 08-Jun-2019 20:56
    Hi,
     
    This is with reference to our facility in the US which has its MDD certificate expiring in 2021. The NB has provided the option of early renewal ( valid for 5 years from now) which needs to be applied this month. However in their notification, the NB mentions about the recertification audit & Fees, technical documentation sampling and also state that the renewal is not guaranteed.
     
    Also if we do not apply for the renewal, we can continue with the existing MDD certificate ( until its validity – 2021) , however no significant change applications would be accepted beyond Nov 2019.
     
     
    Does anybody have a similar experience or can you please advise what would be the best approach .
     
    We would have wanted to go with the early renewal which gives the flexibility until May 2024 for total MDR compliance and until May 2020 to go ahead with the significant change application under the MDD.
     
     
     
    Thanks & Regards,
     
    Rashmi Pillay
    Regulatory Affairs Associate

    Ellex 
    3-4 Second Avenue
    Mawson Lakes SA, 5095
     
    T + 61 8 7074 8105
    rpillay@ellex.com
    W ellex.com
    .............................................................................
     
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  • 2.  RE: MDD early renewal

    Posted 09-Jun-2019 04:16
    If you do not think you will be ready for EU MDR Transition by 2021, then you should renew.  However, with that said because renewal is not guaranteed and seeing companies struggle with renewal (already applied MDR-esque requirements) should be completely prepared for the renewal process.  Your quality planning should account for any of those eventualities, as well doing gap assessment of current MDD technical documentation to ensure meeting continued increasing requirements.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 3.  RE: MDD early renewal

    Posted 09-Jun-2019 10:25
    Richard, I would have thought the whole point of MDD renewal would be to avoid struggling with MDR-esque requirements for another 5 years?  And that the main practical trade-off would be that you "can't" change your MDD-certified device for another 5 years?  However, I would think a company should be free to change the device and certify under MDR whenever it is ready, not have to wait 5 years just because it has an MDD certificate.  This would mean paying for 5-year MDD renewal now, and again for x-year MDR certification, but if the change is important enough to be worth the extra cost, then that option should be open?

    Depending on the competitive environment for your devices, I think there may also be a competitive trade-off, as manufacturers of devices that have MDR certification are likely to include this in their promotional activities.

    I wouldn't expect either MDD renewal or certification under the MDR to be guaranteed.  Of the two, If the NB is open to a 5-year MDD renewal, I would expect this path to be the more certain of the two.

    PS  I don't think facilities can be certified to either the MDD or the MDR, only medical devices?

    ------------------------------
    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
    ------------------------------



  • 4.  RE: MDD early renewal

    Posted 09-Jun-2019 08:42
    As the 26 may 2020 will be a bottleneck is interesting to have some more time to prepare the update and have more experience the NB 
    only one important point, your device will not change in this additional period, so difficult for software and other

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    Xavier Canals-Riera
    Director Tecno-med
    BARCELONA Spain
    xcanals@tecno-med.es
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