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  • 1.  Service instruction labeling for servicable parts

    This message was posted by a user wishing to remain anonymous
    Posted 11-Mar-2024 09:10
    This message was posted by a user wishing to remain anonymous

    Hello,

    I would like to know how do we treat service manuals that are used by field personnels?

    Some consumables are used only for checks to ensure the system meets the required calibration.

    For EU, do we usually CE mark this operations manual and the product?

    Is there a need to follow the requirements for all the labeling laid out under 21 CFR 801 for servicable parts?

    Do we genrally treat these as a part of our regular labeling approval process or can we be more lenient with these?

    Thanks,



  • 2.  RE: Service instruction labeling for servicable parts

    Posted 13-Mar-2024 23:25

    Hello Anon

    Spare parts do need to be appropriately labeled. They are usually not medical devices in themselves, in which case they must not be labeled as medical devices. The CE marking only goes onto things that meet the requirements of one of the CE-marking regulations or directives, which spare parts most often do not.



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    Anne LeBlanc
    United States
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  • 3.  RE: Service instruction labeling for servicable parts

    Posted 14-Mar-2024 18:46
    Service manuals are generally considered to be part of the device "labeling", specifically part of the instructions for use. Consequently, we need to "treat" them accordingly (e.g., as controlled design outputs, labeling, Device Master Record / Medical Device File elements; etc.).  This requirement is established by U.S. medical device law (e.g., via the statutory definition of "labeling") and likewise by other authorities like the IMDRF, EN ISO 20417, EN ISO 13485, etc.
     
    To give definitive direction about the consumables question, we need more details (description, specific intended use, etc.) about the consumables that you state are used only for checks to ensure the system meets the required calibration.  For example, if such consumables are controls or calibrators needed by users and are replenished in ongoing fashion for the device to continue functioning as intended, then such consumables can ultimately be considered to be part of the finished device and thus need to be identified, labeled, traced, etc., accordingly.  On the other hand, if the consumables are just general laboratory items, then that helps get them apart from finished medical device or device component regulatory control.
     
    Europe's Union MDR requires the CE mark to appear in any instructions for use.  Consequently, the CE mark needs to appear on the service manual and operations manual since the Union MDR (and EN ISO 20417, EN ISO 13485, IMDRF etc.) considers these to be part of instructions for use.
     
    21 CFR Part 801 generally governs requirements for the label on a finished device rather than on a device component (e.g., raw material, piece, part, etc., such as a replacement part). But if a replacement part is sold/marketed/distributed separately for a particular medical intended use (e.g., such as for user DIY replacement of worn parts on medical devices), then the Part 801 label requirements would take effect for such item.  Yet if such replacement part is not being sold/marketed/distributed for such an end use but rather arrives for example by way of, or on behalf of, a manufacturer's own (or contracted) service technician who does the field servicing, then the labeling requirements for such part are governed by 21 CFR 820.60 Identification rather than Part 801.


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    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright by ComplianceAcuity, Inc. All rights reserved.
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  • 4.  RE: Service instruction labeling for servicable parts

    Posted 15-Mar-2024 02:34

    If the device falls under the IEC / EN / ISO 60601 Series of standards then service manuals can be separated or incorporated into the IFU but there are specific requirements that need to be met if incorporating the service manual into the IFU and also if the service manual is separate.  Refer to clause 7 of IEC 60601-1 for general guidance.  Also, IEC 60601-1 and the rest of the series of 60601 standards have a lot of marking and labeling requirements including IFU and Service Manual requirements to be aware of.

    ISO 20417 does capture a lot of IEC 60601-1 marking and labeling requirements but not all of them.  ISO 20417 is much more global of a standard than IEC 60601-1 is when it comes to marking and labeling requirements for medical devices.



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    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
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