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  • 1.  Eu MDR_ UDI DM

    This message was posted by a user wishing to remain anonymous
    Posted 19-Oct-2023 09:03
    This message was posted by a user wishing to remain anonymous

    Hi All,

    EU MDR Annex VI Cluase 4.13. ''In the case of single finished devices made up of multiple parts that must be assembled before their first use, it shall be sufficient to place the UDI carrier on only one part of each device.''

    Does this clause apply to finished devices made up of multiple parts that can be re-assembled after their first use? e.g. the device must be assembled before first use, however it can be disassembled/reassembled during it life as one or two of the components can be replaced (spare parts).

    Thanks.



  • 2.  RE: Eu MDR_ UDI DM

    Posted 20-Oct-2023 02:20

    If the spare parts are just that and not devices in their own right, they don't need their own UDI. Article 23 specifies what should be considered a spare part. I would expect the IFU to specify what maintenance is needed.

    If replacing these parts becomes a form of refurbishing, there is possibility of this involved legal person becoming the manufacturer.



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    Ronald Boumans
    MDR Expert
    Super PRRC
    Netherlands
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  • 3.  RE: Eu MDR_ UDI DM

    Posted 20-Oct-2023 05:43

    Anon,

    While the UDI requirements in the EU MDR/IVDR have specific requirements, there are still quite a few areas which still need to be addressed.  The information you posted is correct, that if a device has multiple parts being put together as part of the initial assembly, then there is only the one (1) UDI needed.  As an example, if you have a laser type of device with the main console, a screen, a handpiece, a cart, a moving arm, etc., these all need to be put together before the first use.  The actual laser device, then just needs one UDI.

    When looking at Unique Device Identification (UDI) it is more important how this is viewed from the user's perspective and not always about what the regulation says or does not say.  If there is a spare part which needs to be tracked through the use activity then it should probably have a UDI.  This way when there is a complaint or issue with the part or component, this is an easy way to identify the part.  While there is no clarity in the regulation, spare parts, components, or other parts may benefit from UDI for traceability purposes.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: Eu MDR_ UDI DM

    Posted 20-Oct-2023 13:15
    Edited by Kevin Randall 20-Oct-2023 13:18

    I advise that devices that "can be", "re-assembled after their first use" for purposes of medical device maintenance and spare part replacement are not the direct intent or context of Annex VI.C.4.13.  Instead, Annex VI.C.4.13 is for a different category of devices, specifically, those that "must be assembled before their first use" (even though these may indeed need to be re-assembled after subsequent maintenance).

    For example, a device that comes assembled for the user but later requires disassembly for cleaning or reprocessing or maintenance after use would not be the intended focus of Annex VI.C.4.13.  Instead, the former would simply be subject to other general UDI carrier requirements for any single finished device along with, as applicable, the requirements for reusable devices.  And for such devices, the UDI need only be placed on one part (if at all) anyhow (notwithstanding packaging and labels); thus Annex VI.C.4.13 doesn't even need to be leveraged for such devices if one is simply trying to avoid having the UDI on multiple parts of the device.

    Annex VI.C.4.13 is born from the IMDRF's approach to UDI and thus the IMDRF's approach is worthy of employing (per the MDR preface). I haven't seen that IMDRF principle be convoluted with device maintenance and spare part replacement.

    Remember also that if the replaceable spare parts are Annex VI.C.3.6 components, then those would indeed need their own UDI.



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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: Eu MDR_ UDI DM

    Posted 23-Oct-2023 12:19

    The original use case for this "exception" was in the GHTF UDI guidance document and was based on multi-piece surgical instruments.  The original GHTF text was more limited - "A single finished medical device made up of multiple parts that have to be assembled may have the permanent UDI Carrier [Direct Mark] only on one part. It should be on the device that provides the primary mode of activation."  We expanded and "simplified" this in the original (2013) IMDRF UDI guidance to "A single finished medical device made up of multiple parts that have to be assembled may have the UDI Carrier only on one part" to move away from method in which UDI was applied. This then became the MDR requirement mentioned.  However, the original use case still applied.

    If the device can be disassembled and then reassembled, do you have confidence that the original 2 (or more) pieces are the same, original single medical device?

    Thanks - Jay 



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    Jay Crowley
    Vice President, Medical Devices and UDI Practice Lead
    USDM Life Sciences
    jcrowley@usdm.com
    +1-805-880-2591
    Baltimore MD
    United States
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