Regulatory Open Forum

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  • 1.  Belgium hospital additional sterilization requirement

    Posted 17-Oct-2023 10:24

    Hello, we had a request from a Belgium Hospital to include disinfection instructions to our IFU prior to sterilization. My understanding is that sterilization is a higher level of decontamination than disinfection. I don't understand why we would need to disinfect before performing sterilization. We already have cleaning instructions prior to sterilization.

    They have said it is a requirement in the regulation, but given that we are CE marked, and our device has passed technical file review for MDR, I don't know if this is an additional requirement for Belgium that I was unaware of. Can someone shed some light on this? 



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    Kimberly Chan
    Lansdale PA
    United States
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  • 2.  RE: Belgium hospital additional sterilization requirement

    Posted 18-Oct-2023 03:59

    Hi there, There is additionnal domestic regulation in Belgiu. Disinfection is required to protect users who handle the device before sterilization.

    https://www.health.belgium.be/sites/default/files/uploads/fields/fpshealth_theme_file/20230414_css-9682_recommandations_sterilisation_vweb_0.pdf



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    Quang Tran
    VP QARA
    Antony
    France
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  • 3.  RE: Belgium hospital additional sterilization requirement

    Posted 18-Oct-2023 05:51

    Kimberly,

    There is a difference between cleaning, disinfection, and sterilisation especially for reusable products.  Cleaning is to remove large foreign matter.  Disinfection may be done to handle safely which is usually an SAL of 10-3 or less.  Sterilisation is then to remove any potential contamination usually an SAL of 10-6.  I do not know specific Belgium requirements, but Quang provided the link and the "usual" rationale is for users handling the device before sterilisation or re-sterilisation.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: Belgium hospital additional sterilization requirement

    Posted 19-Oct-2023 01:38

    Thank you for this super link, Quang!



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    Stefano Brianza
    Dr
    Nidau
    Switzerland
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  • 5.  RE: Belgium hospital additional sterilization requirement

    Posted 19-Oct-2023 11:59

    Thank you for the link!

    I also found it in English:

    https://www.health.belgium.be/sites/default/files/uploads/fields/fpshealth_theme_file/07022020_good_practices_for_the_sterilisation.pdf.pdf

    This seems to be a requirement for the hospital, not the medical device manufacturer. Though, it seems we must accomodate it if we wish to sell in hospitals. Does anyone know of any other country-specific requirements like this?

    The document from the Belgium SHC gives the required disinfection parameters. Is this for the manufacturer to validate? Or are the processes they are referring to validated by the hospital itself?



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    Kimberly Chan
    Lansdale PA
    United States
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  • 6.  RE: Belgium hospital additional sterilization requirement

    Posted 20-Oct-2023 03:22

    HI,

    It is also applicable to all devices you are delivering in Europe that are reprocessed. You have almost one specific requirement per EU country which most of the time are very similar but not equal. For instance here the link in France https://www.legifrance.gouv.fr/circulaire/id/34277 



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    Quang Tran
    VP QARA
    Antony
    France
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  • 7.  RE: Belgium hospital additional sterilization requirement

    Posted 20-Oct-2023 04:12
    Edited by Stephanie Grassmann 20-Oct-2023 04:25

    Dear Kimberly

    Yes, there are other regulatory authorities (RA) who have issued cleaning/ disinfection/ sterilisation/ reprocessing guidelines/ regulations. 

    One example is Swissmedic, the RA of Switzerland for reprocessing. One important note: Swiss regulation prohibits reprocessing of single-use medical devices in comparison to EU countries.

    https://www.swissmedic.ch/swissmedic/en/home/medical-devices/reprocessing---maintenance/reprocessing.html

    https://www.swissmedic.ch/swissmedic/en/home/medical-devices.html -> Swiss medical devices regulations found here.

    Another example is Denmark who issued new rules on reprocessing and reuse of single-use medical devices in 2021. See 2021 news article link below. 

    https://www.bechbruun.com/en/news/2021/new-rules-on-reprocessing-and-reuse-of-single-use-medical-devices

    Recommend to search each RA website of the country in which your product is sold. 

    Best Regards,

    Stephanie



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    Stephanie Grassmann
    Founder & Managing Director of MedTechXperts Ltd
    Biberstein
    Switzerland
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  • 8.  RE: Belgium hospital additional sterilization requirement

    Posted 20-Oct-2023 04:17

    Hi again,

    Pay attention to distinguish Single use MD that are reprocessed even if they are supposed to be be single use from reprocesssed MD (for instance surgical instruments).



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    Quang Tran
    VP QARA
    Antony
    France
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