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  • 1.  What regulations in EU apply to pharmacy vial filling robot?

    This message was posted by a user wishing to remain anonymous
    Posted 13-Mar-2024 09:07
    This message was posted by a user wishing to remain anonymous

    Good afternoon, forum.

    Can anyone direct me to which regulations would apply in EU to a "high-speed, vial filling robot for 'behind the counter' pharmacy/clinical use?" There is no intended use/indications for use statement that make it an actual medical device that I can find. Further, a clinician or pharmacist or someone with appropriate credentials would be required to operate, monitor, and check the output prior to providing to customer. 

    What regulations would apply to this type of robot/machine and/or what other information would I need to determine an appropriate regulatory strategy?

    Any insight welcome. Thank you!



  • 2.  RE: What regulations in EU apply to pharmacy vial filling robot?

    Posted 14-Mar-2024 19:28

    There are many EU directives which applies such as:
    WEE

    ROHS

    General Safety

    Machinery directive

    Electrical safety, and perhaps more 



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    Armin Beck
    CEO
    SunTrixConsulting LLC
    El Dorado Hills, CA
    1-925-212-7683
    armin.beck@suntrixmedical.com
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  • 3.  RE: What regulations in EU apply to pharmacy vial filling robot?

    Posted 15-Mar-2024 04:43

    In addition to what Armin mentioned: probably also batteries regulation if it has a battery for uninterrupted power supply (many of these robots do). RED if the robot has a wireless interfacing capability. EMC (since MDR is not applicable EMC needs to happen separately). EUP (Energy using products) may apply. GDPR will necessitate some software design requirements if the robot processes personal data (e.g. if it combines patient data with a barcode on the vial). And don't forget the almost adopted AI Regulation in case the robot qualifies as an AI system.



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    Erik Vollebregt
    Partner
    Amsterdam
    Netherlands
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  • 4.  RE: What regulations in EU apply to pharmacy vial filling robot?

    Posted 15-Mar-2024 10:45

    Hello Anon

    A few other thoughts, assuming this is something like a tablet counter, and not meant for compounding, non-sterile, no liquids, so just basic sanitation requirements...

    There may be local pharmacy rules you should be aware of. See section 3.6 of this WHO report for some overview of equipment rules, record-keeping, etc.

    https://www.pgeu.eu/wp-content/uploads/2019/10/WHO-Europe-Report-Regulatory-framework-for-community-pharmacies-October-2019.pdf

    And just possibly relevant, this EDQM guide on automated dose dispensing.

    https://www.edqm.eu/en/-/new-automated-dose-dispensing-add-guidelines



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    Anne LeBlanc
    United States
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