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  • 1.  complaint handling

    This message was posted by a user wishing to remain anonymous
    Posted 17-Feb-2023 12:10
    This message was posted by a user wishing to remain anonymous

    Does the EU IVDR talk about specifics of complaint handling? I looked though it and couldn't find something specific. Is there a guidance that needs to be followed or being ISO 13485 compliant on clause 8.2.2 satisfy the requirements?

    Thanks!



  • 2.  RE: complaint handling

    Posted 17-Feb-2023 12:34

    Neither to EU-IVDR nor the EU-MDR discuss complaint handling. It is EN ISO 13485:2016/A11:2021.

    Your QMS should determine whether a complaint is an incident. If so, that triggers the EU-IVDR or EU-MDR process.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 3.  RE: complaint handling

    Posted 17-Feb-2023 16:52

    Since EN ISO 13485:2016/A11:2021 is not mandated by the EU MDR and IVDR, then both regulations contain various independent clauses demanding a complaint handling system.  Further explanation is given below.

    Remember that the receipt and processing of complaints is generally understood to be a form of "reactive" post-market surveillance (PMS).  The IVDR and MDR implement this primarily by way of their PMS Annexes III.1(a) fifth indent (collection and utilization of complaints) and (b) fourth indent (effective and appropriate methods and tools to investigate complaints).  These are driven by the EU IVDR's/MDR's quality management system requirements in Article 10(9), third paragraph, indents (i) & (j).

    Multiple other complaint handling provisions of the IVDR and MDR feed the aforesaid legislative complaint handling obligation.  For example, the provisions for authorized representatives, importers, and distributors to forward complaints to the manufacturer so that the manufacturer can investigate the complaints.  Competent authorities are also commissioned by the IVDR and MDR to assure proper handling of complaints.

    All this said, if a manufacturer either officially or unofficially applies the EN ISO 13485:2016/A11:2021 clause 8.2.2 provisions for icomplaint handling, then that will certainly be sufficient to fulfill the IVDR/MDR's complaint handling requirements.  This is in particular because, for example, EN ISO 13485:2016/A11:2021 is harmonized for the MDR.



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    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2023 by ComplianceAcuity, Inc. All rights reserved.
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  • 4.  RE: complaint handling

    Posted 21-Feb-2023 13:51

    Some interesting further details about the EU MDR's/IVDR's specific attention to "complaints":

    • The stated scope of "complaints" are "complaints" provided by users, distributors and importers.

    • The EU MDR states various requirements for "complaints" some twelve times.


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    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2023 by ComplianceAcuity, Inc. All rights reserved.
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  • 5.  RE: complaint handling

    Posted 17-Feb-2023 12:45

     Hi,

    ISO 13485:2016 dictates quality process for complaints- complaint handling procedure, IVDR helps with reportability evaluation, what has to be reported, how to report and who has to report and when. 



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    Raje Devanathan
    Amerisource Bergen
    TPIreg, Innomar Strategies
    Senior Manager - Regulatory Affairs, Medical Devices
    rdevanathan@tpireg.com
    3470 Superior Court
    Oakville ON L6L0C4
    Canada
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  • 6.  RE: complaint handling

    Posted 21-Feb-2023 08:16

    Hello Anon,

    While the EU IVDR (and EU MDR) do not specifically state 'complaint handling' system or process, this is inherent to the requirements under Article 10, Article 78, and Annex III for having a post market surveillance system.  The intent by not using customer complaints was done on purpose because post market surveillance includes many different aspects including customer feedback, customer complaints, servicing, technical support, vigilance, etc.  Specifically if you look at Annex III, Point 1, point (a) it does talk about gathering, collecting, and analysing customer feedback and complaints.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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