Regulatory Open Forum

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  • 1.  MRI accessories

    Posted 23-Jan-2024 08:50
    Hi, I would like to know during the MRI procedure if one uses the nonmagnetic audio video system would it be considered a device or entertainment system?


  • 2.  RE: MRI accessories

    Posted 23-Jan-2024 09:55

    This depends on the jurisdiction and on the specific intended use.  Each jurisdiction needs to be considered in its own right.

    For the FDA as an example, such systems (e.g., visual projectors intended for patient comfort, room ambiance, and fMRI stimulus) have been considered to be medical devices or accessories to medical devices (and thus regulated as medical devices themselves).  For example, I have a client for whom the FDA officially concurred and established that their system is a medical device (by way of being an accessory to a device or by being a device itself) that falls into FDA medical device Product Code LNH (Nuclear Magnetic Resonance Imaging System) under FDA medical device classification regulation 21 CFR §892.1000.  We have also seen other competitors held to the same standard; one I can think of as recently as 2019.

    For Europe, we've also had a large multinational MRI manufacturer who uses these audio-visual devices consider them to be medical devices with respect to the manufacturer's medical device compliance obligations.



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    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
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  • 3.  RE: MRI accessories

    Posted 24-Jan-2024 02:21

    Hi Shalini,

    In the EU, a product is considered an accessory to a medical device, if it does not fit the definition of a medical device, but it enables a medical to be used as intended. As a consequence, you have to look carefully at the intended purpose of the audio/video system. Is this just to keep someone comfortable during the procedure? Then it probably is NOT an accessory. Would such system help suppressing anxiety and/or help the patient relax and stay in one position? It would probably be considered an accessory. 

    If an accessory, you have to demonstrate that the accessory works as intended. In this situation you need to demonstrate that the device has these effects on the patient. This may involved a study with patients undergoing an MRI procedure. 



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    Ronald Boumans
    MDR Expert
    Super PRRC
    Netherlands
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