Regulatory Open Forum

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  • 1.  Health Canada IMDRF TOC Format (Medical Devices) - What about the Protocols?

    Posted 06-Mar-2023 18:58

    Hello,

    Preparing to transition from the Health Canada folder structure to Health Canada's adapted IMDRF TOC folder structure (Class 4 medical device). 

    The majority of the sections include an "Overview" folder + 1 folder per "test". The "test" folder is structured to include a Summary file + a Report document.

    If we have separate protocol documents, are these not intended to be submitted? Are protocols provided upon request only?

    Is the expectation to summarize relevant protocol contents in the Summary file ONLY (e.g., purpose, methods, test article justification, acceptance criteria justification, etc.) instead of submitting protocols?

    Thanks!



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    Nomi Steen
    Regulatory Affairs Associate
    Edmonton AB
    Canada
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  • 2.  RE: Health Canada IMDRF TOC Format (Medical Devices) - What about the Protocols?

    Posted 07-Mar-2023 14:18

    Hello Nomi,

    In my experience, the separate protocol documents indeed are not submitted - only the reports.  Typically there is a summary or the protocol/steps of testing can be construed from the testing report.  Typically if the test is completed, then the protocols would be requested as needed.  In fact, find this quite similar to other regulatory agencies.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 3.  RE: Health Canada IMDRF TOC Format (Medical Devices) - What about the Protocols?

    Posted 08-Mar-2023 08:29

    Hi Nomi,

     

    From my experience, if the test reports include enough detail, then the protocols are not required to be submitted.  A good summary can also include any relevant missing information that may have been left out of the report so that questions are avoided from HC.  That said, sometimes it is easier to include the protocol (especially for clinical testing) because it can provide answers to the reviewer that you may not have thought of including in your summary or report and avoid questions.  However, if there are deviations from the procedure outlined in the protocol and the way the study was completed and they are not described/explained in the report adequately (or in your summary) this will raise more questions.  Therefore, it is best to evaluate the situation individually for your company and then decide how you wish to proceed.

     

    Hope this helps,

     

    Shirley

     

    Shirley Furesz, Ph.D., RAC

    Amerisource Bergen

    TPIreg, Innomar Strategies

    Director Regulatory Affairs, Medical Devices

     

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