Regulatory Open Forum

 View Only
  • 1.  Introducing electronic IFU's

    This message was posted by a user wishing to remain anonymous
    Posted 06-Apr-2023 08:30
    This message was posted by a user wishing to remain anonymous

    We are a manufacturing Class IIa medical device company and a Class 3 in Canada, distributing products in Europe and MDSAP Countries. We also are looking into distributing in Ukraine and Russia in the near future.  Our Quality System is currently in compliance with applicable regulations.  For Europe we are in compliance with MDD 93/42/EEC, transition to MDR 2017/745 is in process.
    As part of the labelling improvements, we would like to introduce electronic IFU's.  We are wondering if we need to notify our NB to review and approval prior to implementation?  If yes, what would we need to do?  Any guidance would be greatly appreciated



  • 2.  RE: Introducing electronic IFU's

    Posted 06-Apr-2023 10:12
    Edited by Kevin Randall 06-Apr-2023 12:24

    Both Regulation (EU) 207/2012 (the eIFU regulation for the MDD) and Regulation (EU) 2021/2226 (the eIFU regulation for the EU MDR) require that conformity with those regulations be reviewed by a European notified body where applicable (i.e., for those device classes/types requiring notified body involvement for conformity assessment).

    Since "notified body" is, to my humble knowledge, only a European legislative term/concept, I'll forego further attention regarding MDSAP countries, Ukraine, and Russia.



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



  • 3.  RE: Introducing electronic IFU's

    Posted 06-Apr-2023 12:22

    Just fixed the typo in the EU MDR regulation number...



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



  • 4.  RE: Introducing electronic IFU's

    This message was posted by a user wishing to remain anonymous
    Posted 10-Apr-2023 08:09
    This message was posted by a user wishing to remain anonymous

    Thank you so much for the information regarding eIFU, it has been very useful.




  • 5.  RE: Introducing electronic IFU's

    Posted 07-Apr-2023 03:00
    Edited by Hans Strobel 07-Apr-2023 03:01

    Hello

    Some information upfront: A key question is if you plan eIFU in addition to paper IFU or as a replacement. Assuming it is the second (and assuming that your device is used exclusively by healthcare professionals) you have to set up an eIFU System. All eIFU regulations require the following for such a system:

    • a process that allows the intended user to request a paper IFU free of charge
    • system risk analysis
    • definition of requirements/processes and computer system validation (described e.g. in ISO 13485 and 21 CFR Part 11)
    • For the EU a fundamental requirement is that your device is covered by EU Reg 2021/2226 Article 3. 


    Now to your question: Depending on the situation and answers to the above I propose mentioning your plan to your notified body to get an initial response on the process. If the device is eligible for eIFU according to 2021/2226 Article 3, they will (in our experience) assign a reviewer to audit the eIFU System and confirm that it meets the requirements. For non-EU jurisdictions, such a system audit will be part of a regular QMS review. 

    Kind regards,

    Hans






    ------------------------------
    Hans Strobel
    www.dokspot.io
    ------------------------------



  • 6.  RE: Introducing electronic IFU's

    Posted 09-Apr-2023 07:35

    Hello Anon,

    To add a further comment, there are plenty of Directives and Regulations which may apply to medical devices/IVD medical devices and are not specifically reviewed or require notification to their Notified Body when complying or implementing.  There has already been some comments about informing the Notified Body, maybe in context of a significant change, but personally I would not view this as a notification to the Notified Body.  My reason for this is the electronic IFU regulation does not require specific Notified Body oversight - some could argue it does through the EU MDR/EU IVDR.  However, during any re-certification audit or surveillance audit, this is something an auditor can confirm compliance by the organisation.  As electronic instructions for use are spoken about in the EU MDR/EU IVDR this can be an area audited when claiming compliance (Annex I - GSPR); just like RoHS, REACH, EMC, etc., as long as the auditor has the qualifications and knowledge to audit those areas.  There are different electronic instruction requirements in different countries - these would need to be reviewed for each.



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



  • 7.  RE: Introducing electronic IFU's

    Posted 06-Jun-2023 10:00

    Hello, 

    maybe this article can be useful for you? 

    eIFU for Medical Devices: Country Specific Regulations and Benefits | MakroCare

    Hope it helps you! 



    ------------------------------
    Agnieszka Fronczak
    Regulatory Affairs Manager
    Neu-Ulm
    Germany
    ------------------------------



  • 8.  RE: Introducing electronic IFU's

    Posted 06-Jun-2023 12:30

    Electronic IFU must also contain all the information foreseen as mandatory for the drafting of the IFU of any medical device by Annex I, Chapter III, point 23.4. of the MDR. Where the certification process involves an NB, compliance with the Electronic IFU framework will be verified by the NB itself in the Article 52 MDR assessment procedure.



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