Regulatory Open Forum

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  • 1.  Question about EU Implant Cards/Informative Leaflets

    Posted 05-Sep-2023 12:22

    Hi all,

    I have a question regarding patient implant cards (required under certain circumstances per MDR Article 18) and their accompanying informative instruction leaflets, as described in guidance MDCG 2019-8 v2. This guidance notes that the outer dimensions of the implant card should be the same as those of a credit card, i.e. 85.60 mm x 53.98 mm.

    However, I do not see that there is any stated requirement on how thick the implant card should be (e.g., whether it can be as thin as paper or must be as thick as a credit card), or any requirement on the material the card should be constructed with. I also do not see any requirements on dimensions or materials for the informative instructional leaflet.

    I would expect that if there were any requirements, they would be listed in MDCG 2018-9. Is anyone aware of any such requirements for the EU/MDR that are stated elsewhere?

    Thanks!



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    Thomas Saladin
    Regulatory Affairs Specialist
    Minnetonka MN
    United States
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  • 2.  RE: Question about EU Implant Cards/Informative Leaflets

    Posted 05-Sep-2023 13:05

    With no specific requirements, think about how the implant card is used.

    I have four, issued in the US, and I carry them in my wallet. The requirement is that they fit in a wallet (credit card size) and that they are durable. For examples, think of other things that have similar requirements such as a Social Security card, a Covid vaccination card, and a business card.

    If you print them on heavy business card stock, you should be good to go.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 3.  RE: Question about EU Implant Cards/Informative Leaflets

    Posted 06-Sep-2023 02:51

    Good morning,

    As MRI community we have spent a lot of time to get an "MR Conditional", "MR Safe" or "MR Unsafe" (see ASTM F2503) icon travel with the implant.
    Unfortunately, it appears that this has not made it to the legal requirements for those cards.

    Can we as RAPS community help make this happen? Any suggestions?

    It's really important to prevent patients from unduly being denied access to MRI, which an implant carrier will need during their lifetime as much as any other person.

    fyi - the MR systems will (per Edition 4 of IEC 60601-2-33) be required to implement a user interface to enter the MR Conditional parameters found on the implant label, and provide a safe exam condition.



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    Johan van den Brink
    Principle Scientist & Architect
    Philips, Best, The Netherlands
    Convener of IEC SC 62B MT40 (IEC 60601-2-33)
    ------------------------------



  • 4.  RE: Question about EU Implant Cards/Informative Leaflets

    Posted 06-Sep-2023 02:55

    Good morning,

    As MRI community we have spent a lot of time to get an "MR Conditional", "MR Safe" or "MR Unsafe" (see ASTM F2503) icon travel with the implant.
    Unfortunately, it appears that this has not made it to the legal requirements for those cards.

    Can we as RAPS community help make this happen? Any suggestions?

    It's really important to prevent patients from unduly being denied access to MRI, which an implant carrier will need during their lifetime as much as any other person.

    fyi - the MR systems will (per Edition 4 of IEC 60601-2-33) be required to implement a user interface to enter the MR Conditional parameters found on the implant label, and provide a safe exam condition.



    ------------------------------
    Johan van den Brink
    Principal Scientist & Architect
    Philips, Best, The Netherlands
    Convener of IEC SC 62B MT40 (MR Equipment safety standard)
    ------------------------------



  • 5.  RE: Question about EU Implant Cards/Informative Leaflets

    Posted 06-Sep-2023 09:36

    In my response I forgot to cover the informative instructional leaflet. The situation is similar to the implant card.

    The patient will probably store the leaflet with other important papers such as insurance policies, deeds, etc. The leaflet should match the common practice in the country.

    In the US use letter size paper (8½″×11″). Use heavier paper stock such as 24 pound.

    For the rest of the world use A4 letter size paper and a heavier paper stock.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 6.  RE: Question about EU Implant Cards/Informative Leaflets

    Posted 05-Sep-2023 22:02
    Edited by Nivedita Namjoshi 05-Sep-2023 22:03

    Hello Thomas,

    I hope you are well. 

    Per my knowledge, there is know specified requirement regarding the thickness of the patient implant cards. We made an implant card using a Card stock and dimensions as specified in the MDCG guidance. The general idea is to have the required information about the implant clear, concise and legible for patients. 

    I hope this helps!

    Nivi



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    Nivedita Namjoshi
    Massachusetts
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  • 7.  RE: Question about EU Implant Cards/Informative Leaflets

    Posted 06-Sep-2023 04:04

    Good day Thomas,

    As others have mentioned, there is no thickness requirement, but it is up to the Manufacturer to meet the needs of their patients.  The implant card containing information about the implant should be the size and durability it can be carried around in a wallet or similar.  If the implant card is thin paper, then more than likely it would not last very long - a receipt in my pocket barely lasts a day.  We have used heavy stock in the past as well, but not too thick in case the user also wants to laminate the card to protect it even further.



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