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
Principal Scientist & Architect
Philips, Best, The Netherlands
Convener of IEC SC 62B MT40 (MR Equipment safety standard)
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Original Message:
Sent: 05-Sep-2023 13:04
From: Dan O'Leary
Subject: Question about EU Implant Cards/Informative Leaflets
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
Original Message:
Sent: 05-Sep-2023 12:21
From: Thomas Saladin
Subject: Question about EU Implant Cards/Informative Leaflets
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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