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QUALITY STANDARDS FOR MEDICAL DEVICES

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Abstract

Formerly with more augmented disabilities, Medical devices have become decisive device in many circumstances. As these are more perilous, the manufacturer should endow with an ideal medical device in aspects of safety & quality. To produce a homogeneous device globally, there should be some standards to be followed within an explicit country and standard throughout the globe, complying with the quality. In milieu of this resemblance of device globally, International Organization for Standard (ISO) has issued a standard, ISO 13485. This article is made to furnish the details about ISO 13485 and the Quality management system followed by United States manufacturer’s to market their devices within the country, i.e., 21 CFR Part 820.
Achin et al. International Journal of Drug Regulatory Affairs; 2014, 2(4), 19-24 ISSN: 2321 - 6794
© 2014 IJDRA Publishing Group, All rights reserved Page 19
QUALITY STANDARDS FOR MEDICAL DEVICES
Available online at www.ijdra.com
REVIEW ARTICLE
Achin Jain*, Neenu Ganesh, Venkatesh M.P.
JSS College of Pharmacy, JSS University, S.S. Nagar, Mysore, Karnataka, India
*Corresponding Author’s E-mail: achinjain16@yahoo.co.in
INTRODUCTION
Definition
A medical device is "an instrument, apparatus,
implement, machine, contrivance, implant, in
vitro reagent, or other similar or related article,
including a component part, or accessory which
is
recognized in the official National
Formulary, or the United States
Pharmacopoeia, or any supplement to
them,
intended for use in the diagnosis of
disease or other conditions, or in the cure,
mitigation, treatment, or prevention of
disease, in man or other animals, or
intended to affect the structure or any
function of the body of man or other
animals, and which does not achieve any
of its primary intended purposes through
chemical action within or on the body of
man or other animals and which is not
dependent upon being metabolized for the
achievement of any of its primary
intended purposes.(1)
Classification of medical devices
The medical devices in US are classified into
three regulatory classes based on the level of
control necessary to assure the safety and
effectiveness of the device. The classification of
medical devices also depends on the intended
use, indications for use and the risk that a device
imposes on the patient and/or on the user. (2)
The three classes and the requirements which
apply to them are (device class and regulatory
controls)
1. Class I (low to moderate risk): General
controls. E.g.: Tongue depressors, arm
slings, and stethoscopes
2. Class II (moderate to high risk): General
controls and Special Controls E.g.:
Physiologic monitors, x-ray systems, gas
analyzers, pumps, and surgical drapes.
3. Class III (high risk): General controls
and Premarket Approval (PMA) E.g.:
Pacemakers, replacement heart valves
and total joint replacements. (3)
The General Controls are the baseline
requirements of the Food, Drug and Cosmetic
(FD&C) Act that apply to all medical devices,
Class I, II, and III.
The Special Controls are regulatory
requirements for class II devices. The general
controls alone are insufficient for providing
reasonable assurance of safety and effectiveness
ABSTRACT
Formerly with more augmented disabilities, Medical devices have become decisive device in many circumstances. As
these are more perilous, the manufacturer should endow with an ideal medical device in aspects of safety & quality.
To produce a homogeneous device globally, there should be some standards to be followed within an explicit country
and standard throughout the globe, complying with the quality. In milieu of this resemblance of device globally,
International Organization for Standard (ISO) has issued a standard, ISO 13485. This article is made to furnish the
details about ISO 13485 and the Quality management system followed by United States manufacturer’s to market
their devices within the country, i.e., 21 CFR Part 820.
Keywords: Medical devices, ISO 13485, 21 CFR-Part 820.
Achin et al. International Journal of Drug Regulatory Affairs; 2014, 2(4), 19-24 ISSN: 2321 - 6794
© 2014 IJDRA Publishing Group, All rights reserved Page 20
of the device and these special controls provide
such assurance.
Class III devices, supporting or sustaining
human life, highly risked, for which general
controls and special controls are insufficient to
provide reasonable assurance of the safety and
effectiveness of a device. For marketing of these
devices a premarket approval application (PMA)
is required. (4)
The marketing of Class I or II devices is done
through the path of 510K, if it is not an exempt.
The devices classified as exempt, are subject to
the limitations on exemptions. (2)
Quality Standards for Medical Devices
A standard is a document that provides
requirements, specifications, guidelines or
characteristics that can be used consistently to
ensure that materials, products, processes and
services are fit for their purpose. As the medical
devices are more allied with risk factor, there
should be no negotiation on their quality. To
ensure the quality of medical devices, some
standards are customized globally and within
each specific country. Every manufacturer
should meet these precised standards before
marketing the medical devices. (5)
ISO 13485
ISO International Standards ensure that products
and services are safe, reliable and of good
quality, it is published by ISO, the International
Organization for Standardization, and is
available through National Standard Bodies.
Some medical devices such as pacemakers and
diabetic pumps can hoard countless lives, but
they also pose a huge threat to human life if
proper safety and quality procedures are not
followed. To ensure the quality of devices, a
standard ISO 13485 is established relating to
quality management systems in the field of
Medical Devices, including IVD (In Vitro
Diagnostics). ISO 13485 have become global
standard for those who manufacture medical
devices, as they endow with a proven guideline
for maintaining assurance and managing risk.
(6)
ISO 13485 “specifies requirements for a quality
management system where an organization
needs to demonstrate its ability to provide
medical devices and related services that
consistently meet customer requirements and
regulatory requirements applicable to medical
devices and related services”. ISO 13485 solves
two concerns for medical device manufacturers:
Supplying customers and end-users with safe
medical products and superior patient outcomes.
The standard is used by an organization for the
design, development, production, and
installation and servicing of medical devices.
ISO 13485 is also used by internal and external
parties, including certification bodies, to assess
the organization’s ability for meeting the
customer and regulatory requirements. Its
primary objective is to facilitate harmonized
medical device regulatory requirements. The
standard is based on eight quality management
principles: customer focus, leadership,
involvement of people, process approach, and
system approach to management, continual
improvement, fact-based decision-making and
mutually beneficial supplier relationships. (7)
21 CFR Part 820 (8)
The manufacturers of devices should establish
and follow quality systems to ensure that their
products consistently meet the applicable
requirements and specifications. The current
Good manufacturing practices (cGMP’s) are
strictly followed in US for the manufacture of
FDA regulated products, these requirements
were stated in part 820 (21 CFR part 820) which
was first authorized by section 520(f) of the
Federal Food, Drug, and Cosmetic Act (the act),
which became effective on December 18, 1978,
and was codified under part 820. (5)
In 1990, FDA revised the cGMP regulation to
add the design controls authorized by the Safe
Medical Devices Act. It was revised, to benefit
the public and the medical device industry.
Further, the revision made for cGMP regulation
to be consistent, for the extent possible, with the
requirements for quality systems contained in
applicable international standards. After an
extensive effort, the part 820 revision was
published on October 7, 1996 and was effective
from June 1, 1997. The regulation does not
prescribe in detail how a manufacturer must
produce a specific device. Rather, it provides the
framework that all manufacturers should follow
by requiring that manufacturers develop and
Achin et al. International Journal of Drug Regulatory Affairs; 2014, 2(4), 19-24 ISSN: 2321 - 6794
© 2014 IJDRA Publishing Group, All rights reserved Page 21
follow procedures, fill in the details that are
appropriate to a given device according to the
current state-of-the-art manufacturing for that
specific device. (5)
Salient Features of quality standards
ISO 13485(6)
Implementation of a Quality Management
System helps to motivate staff and provide a
better definition of roles and key
responsibilities.
Implementing a Quality Management
System specifically tailored for the medical
devices industry helps the organization to
demonstrate its ability to systematically
provide medical devices and services that
consistently meet customer requirements,
meet applicable regulatory requirements
(compliance) and safety standards.
Cost savings can be made through improved
efficiency and productivity, as product or
service deficiencies will be highlighted and
corrected.
Improvements can be made on a systematic
and monitored base, resulting in less waste,
less inappropriate or rejected work, and
fewer complaints.
Provides a systematic approach to risk
management.
Systematic, smoother, transparent and
documented handling of activities required
by regulation such as post-marketing follow-
up and surveillance, complaints handling,
CAPA implementation, field actions or
product recall handling, vigilance and
competent authorities reporting, and clinical
experience enrichment.
Systematic incorporation, at an early stage
and within the design and development
process, of the regulatory requirements
impacting on the product itself and its
technical features
Help creating a systematic vision embracing
the medical device lifecycle, medical device
packaging, its labelling, its installation, its
servicing, and its usability. This includes the
information provided together with the
medical devices, the commercial claims, the
unspoken user expectations, the feedback
from users or patients, the risks associated
with use, the benefits brought to the single
patient and to the Community, the costs and
the disposal of the medical device.
21 CFR Part 820 (9-11)
21 CFR Part 820 provides standards for a
company to set policies, operating
procedures, guidelines and objectives that
will promote product quality.
Developing the Quality System Structures
Keeping management informed
Improving Customer Service
Responsibility and ownership sharing
Improving timeliness trends
Strategies for enlisting support
The Design Review
Sustaining Systems
Comparison of ISO 13485 with 21 CFR Part
820 (12, 13)
21 CFR 820 is applicable to the manufacturers
of finished medical devices sold in the United
States, including foreign manufacturers who
import devices. Some manufacturers might be
subject only to certain requirements, depending
on the operations they are engaged in. (6)
Medical device manufacturers that sell their
products in the global market find it
advantageous to get ISO 13485 certification
because ISO standards are recognized
worldwide. Certain countries require such
certification and many customers also prefer
medical devices that are ISO certified. Table 1
gives a detail comparison between the both.
Table 1: Comparison of 21 CFR 820 and ISO 13485 regulations for medical devices
Sr.no.
21 CFR 820
ISO 13485
1.
Quality system refers to a medical device
manufacturer’s responsibilities, procedures,
processes, and resources for implementing
quality management. (Subpart B)
Quality management system requirements
were developed to satisfy international
medical device regulations.
(Clause 4)
Achin et al. International Journal of Drug Regulatory Affairs; 2014, 2(4), 19-24 ISSN: 2321 - 6794
© 2014 IJDRA Publishing Group, All rights reserved Page 22
2.
Require controls in design, document,
purchase, and production process. This entails
establishment of processes to ensure that a
medical device conforms to specifications.
(Subpart C,D,E,G)
Requires establishment of a quality
management system for medical devices.
A manufacturer must have quality
procedures that are documented,
controlled, and effectively implemented
and maintained. (Clause 4)
3.
Each manufacturer must have sufficient
personnel with the necessary background,
training, and experience. It must have
established procedures for identifying training
needs and ensuring that employees are
adequately trained to perform their jobs.
Training should be documented.(Subpart B,
Sec. 820.25)
A manufacturer must ensure that its
personnel have the right experience,
education, training, and skills. Acceptable
levels of competence must be defined.
Training needs must be established and
assessed. A record of competence must be
maintained.(Clause 6)
4.
Require establishment and maintenance of
non-conformance and corrective and
preventive action (CAPA) procedures.
Non-conformances relating to product,
processes, and quality system should be
investigated and actions needed to correct and
prevent recurrence must be identified.
Corrective action has to be validated to ensure
effectiveness and all activities pertaining to
Non-conformance and CAPA must be
documented.(Subparts I,J)
Remedial processes are required. Quality
should be monitored and measured by
gathering customer feedback, setting up
internal audits, establishing a non-
conformance procedure, and analyzing
quality information. Non-conformances
must be corrected, recorded, and
prevented.(Clause 8)
5.
Requires procedures for identifying
products.(Subpart F)
Requires development of procedures to
identify and track products.(Clause 7)
6.
When computers or automated data processing
systems are used as part of production or the
quality system, the manufacturer should
validate computer software for its intended use
according to an established protocol.
Validation activities and results should be
documented.(Subpart G, Sec. 820.70)
Requires validation of monitoring and
measuring software before use.
Revalidation should be conducted when
necessary.(Clause 7)
7.
Complaint means any written, electronic, or
oral communication that alleges deficiencies
related to the identity, quality, durability,
reliability, safety, effectiveness, or
performance of a device after it is released for
distribution. (Sec 820.3)
Customer complaint: written, electronic or
oral communication that alleges
deficiencies related to the identity, quality,
durability, reliability, safety or
performance of a medical device that has
been placed on the market (Clause 3)
8.
The term “labelling” means all labels and
other written, printed, or graphic matter upon
any article or any of its containers or wrappers
or accompanying such article. The “label”
means a display of written, printed, or graphic
matter upon the immediate container of any
article; and a requirement made by or under
authority of this Act that any word, statement,
or other information appear on the label.
(Sec. 210)
Labelling:
Written, printed or graphic matter affixed
to a medical device or any of its
containers or wrappers, or accompanying
a medical device, related to identification,
technical description, and use of the
medical device, but excluding shipping
documents (Clause 3)
9.
Inputs relating to product requirements
Design input means the physical and
Achin et al. International Journal of Drug Regulatory Affairs; 2014, 2(4), 19-24 ISSN: 2321 - 6794
© 2014 IJDRA Publishing Group, All rights reserved Page 23
shall be determined and records maintained.
These inputs shall include:
a) functional, performance and safety
requirements, according to the intended use
b) applicable statutory and regulatory
requirements
c) where applicable, information derived from
previous similar designs,
d) other requirements essential for design and
development (Sec 210)
performance requirements of a device that
are used as a basis for device
design.(Clause 7)
10.
Quality policy:
Management with executive responsibility
shall establish its policy and objectives for,
and commitment to, quality. Management
with executive responsibility shall ensure that
the quality policy is understood, implemented,
and maintained at all levels of the
organization. (Sec 820.20)
Quality objectives:
Top management shall ensure that quality
objectives, including those needed to meet
requirements for product, are established
at relevant functions and levels within the
organization. The quality objectives shall
be measurable and consistent with the
quality policy. (Clause 5)
CONCLUSION
ISO 13485 is a tool which reassures that the
medical devices are being manufactured through
a systematic approach to make them safer for
use. Device manufacturers need to follow ISO
13485 for marketing their device globally, and
also need to comply with regulations in
individual countries. US follow 21 CFR 820 for
medical devices and ISO 13485 certification is
not acknowledged in FD & C act. Unlike US
and European Union, other countries do not
have the resources to conduct inspections
outside their own borders. Thus, they must rely
upon a regulatory standard to assure the
organization for quality system compliance. If a
manufacturer meets the requirements of ISO
13485, the device can easily meet the quality
requirements in many regulated countries
including the US.
ACKNOWLEDGEMENTS
I would like to express my sincere gratitude to
my guide Dr. M.P Venkatesh & my M.Pharm
friends, who gave me the appropriate guidance
and has shown interest and encouraged me to
carry out work on this review article.
CONFLICT OF INTEREST
Author declares that there are no conflicts of
interest.
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... In addition, the most important thing in the competitiveness of this medical device is the fulfillment of ISO 13485 which is certified by LSSMA. ISO 13485 certification is very important to ensure that the medical device industry management system meets the standards [24] . In Indonesia currently there are only two institutions LSSMA and involve auditors from abroad. ...
Article
Full-text available
Purpose: Health care equipment international trade could serve a new strategic revenue for Indonesia. Since its implementation in 2015, AFTA has been a very strategic issue in creating export opportunities for its member countries. One of the sectors that becomes a priority for ASEAN integration is in the field of medical devices which is regulated in the ASEAN Medical Device Directive (AMDD) policy. Indonesia itself has officially ratified AMDD policy since 2018, but Indonesia will have been facing the problem of quality, innovation and diversification of medical devices. This study examines the competitiveness opportunities for domestic medical devices in ASEAN Free Trade Area. Method: This study used a qualitative method where information was obtained from in-depth interviews and document review. The informants came from policy makers, implementing officers, and stakeholders. Results: Indonesia has harmonized 26 out of 31 standards mandated by AMDD. Conformity assessment bodies in Indonesia that have been certified by the National Accreditation Committee have received international recognition. Indonesia has many potential exporting innovative medical devices to ASEAN countries. Fulfillment of medical devices is carried out through compulsory licensing and parallel import mechanism.
Chapter
Translating a laboratory-developed prototype into a commercialized medical device requires a brief understanding of biomedical engineering, design process, business, law, market analysis, risk assessment, and regulatory principles. This chapter brings to light the challenges faced by medical device industry—such as technology, demand, reliability, sensitivity, cost, quality management, reusability, short lifecycles, eco-friendliness, safety and regulatory hurdles. The first half of this chapter elucidates a concise review of technological advancements for medical biosensors. Additionally, special emphasis has been laid to build the business upfront for a device. The second half of the chapter elucidates the method of designing affordable devices and challenges faced to validate whether the product meets the healthcare standards and end-user requirements. This discussion is further guided by an overview of pathways toward a financially sustainable business prototype, obtaining intellectual property, and reviewing device regulations. Finally, the chapter concludes with a productive discussion on the challenges for emerging diagnostic tools in an increasingly competitive scenario.
  • Poccent
PocCENT, point of care Center for Emerging Neurotechnologies [Internet]. USFDA; 2014[cited 2014 Feb 24].
International Organization for Standardization
ISO, International Organization for Standardization [Internet]. Geneva; 2014 [cited 2014 Feb 24]. Available at: http://www.standards.org/standards/listing/iso_13 485.
Quality Management: The Need for ISO 13485
  • N Willett
  • Quality Magazine
Willett N. Quality Magazine. Quality Management: The Need for ISO 13485 [Internet].
Medical Device Solutions
  • Incra Med
Incra Med, Medical Device Solutions [Internet].
Compliance Accelerated
  • Ireland
Ireland; 2010 [cited 2014 Feb 26]. Available from: http://incramed.com/main/page_training_solution s_capa.html 12. Master Control, Compliance Accelerated
Master Control, Compliance Accelerated
  • Ireland
Ireland; 2010 [cited 2014 Feb 26]. Available from: http://incramed.com/main/page_training_solution s_capa.html 12. Master Control, Compliance Accelerated [Internet]. Utah; 2014 [cited 2014 Feb 26]. Available from: http://www.mastercontrol.com/iso13485/ISO_134 85_Certification.html 13. 13485 Store [Internet]. US; 2003 Aug 5 [cited 2014 Feb 26]. Available from: http://13485store.com/downloads/compare-iso-9001-and-iso-13485-to-fda-qsr.pdf.