Regulatory Open Forum

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  • 1.  MDSAP - Brazil

    Posted 28-Jan-2018 18:04

    Hi,

     

    For a Class II medical device , which is GMP exempt for Brazil (ANVISA) , does this exemption apply for MDSAP ?If we are marketing a Class II medical device to Brazil , do we have to comply with  ANVISA requirements?

     

    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: MDSAP - Brazil

    Posted 28-Jan-2018 18:25
    Please note that the manufacturer of a class II device is not exempt to "complying"with the Brazilian GMP regulation. What happens is that a GMP certificate is not required for Class I and II registrations (cadastro). For all classes, manufacturers still have to comply with the GMP requirements.

    The way MDSAP works in Brazil is that ANVISA can use the MDSAP report to give the GMP certificate (which is required for Class III and IV devices). So, there's no practical use for MDSAP in the case of Class I and II products right now.

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    Marcelo Antunes
    Regulatory Strategy Consultant
    São Paulo
    Brazil
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  • 3.  RE: MDSAP - Brazil

    Posted 01-Feb-2018 11:16
    ​If you are having an MDSAP audit and sell a class II product into Brazil, the Auditing Organization still needs to include ANVISA requirements in the scope of their audit.   It does not matter that there is no resulting GMP certificate.   Manufacturers are still obligated to comply with the ANVISA quality system related requirements.

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    Gary Minks
    Head of QA/RA
    Dedicated2Imaging LLC
    Portsmouth, NH
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