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  • 1.  MD Symbol for accessory

    This message was posted by a user wishing to remain anonymous
    Posted 30-Aug-2022 09:41
    This message was posted by a user wishing to remain anonymous

    Is the MD symbol (taken from ISO 15223-1:2021) required also for accessories Lebel?



  • 2.  RE: MD Symbol for accessory

    Posted 31-Aug-2022 02:10
    Edited by Somashekara Koushik Ayalasomayajula 31-Aug-2022 02:10

    Hi Anon,
    I assume you are asking this question in scope of EU regulations.

    By definition accessories to medical devices are not medical devices by themselves. They are referred as ‚devices' and requirements of regulation (EU MDR) apply.

    As they are not medical device by themselves, indicating with MD does not apply for them, as that would be a contradiction.



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    Somashekara KOUSHIK Ayalasomayajula, ASQ-CMDA
    Senior Associate
    Medidee Services
    Germany
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  • 3.  RE: MD Symbol for accessory

    Posted 31-Aug-2022 04:58
    Hello,

    Agree with Somashekara generally, just keep in mind there might be some exceptions depending on what kind of accessory is the subject of the discussion.  Also there may be difference of opinions between regulatory reviewers, so at a minimum make sure documenting justification and rationale for the accessory and why maybe the symbology would not be included.  Sad as that may be, it really depends on what is the accessory and if a reviewer might disagree.

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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: MD Symbol for accessory

    Posted 31-Aug-2022 14:55

    If the accessory inherently meets the jurisdiction's official (i.e., statutory; legislative, etc.) definition of "medical device", such as the EU MDR's Article 2(1), then the symbol is appropriate and expected.  In that case, the "accessory" instead needs to just be categorized as a "medical device", not an accessory.

    In contrast, the U.S. includes the term "accessory" in its statutory definition for device, in which case the MD symbol (if used at all for a U.S. label) would be expected for an accessory.

    Canada's statutory definition of device, like the U.S.'s, includes "accessory", and thus would be handled like the U.S., where the MD symbol (if used at all) would be expected for an accessory.



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    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2022 by ComplianceAcuity, Inc. All rights reserved.
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  • 5.  RE: MD Symbol for accessory

    This message was posted by a user wishing to remain anonymous
    Posted 01-Sep-2022 09:15
    This message was posted by a user wishing to remain anonymous

    Thank you all for your response -  it is very helpful 🙂