Online Test 2 Flashcards
Post Market surveillance relation to QMS
Post Market Surveillance is a subset of quality management system
Post Market Period
User starts using to end-of-life disposal
After-sales obligations
- Record keeping of supply
- Monitoring device’s clinical performance
- Identifying and correction action of any problems
Effective post market surveillance
monitors performance of device under actual usage conditions to ensure public and patient safety
Why is post market control important
ongoing safety and performance monitoring is important to ensure patient and public safety after device is released on the market
- inherent risk throughout the medical device life cycle, even for low risks ones,
- limitation of pre-market registration controls, and to
- enable timely intervention to safeguard public health.
Responsibility of product risk management
lies in management
What is post market surveillance
system providing continuous feedback about a device on the market to maintain high standard of product safety and quality
feedback is gathered via collection of processes and activities used to monitor the performance of a medical device after being released on the market
regulatory requirement in EU and ASEAN
Proactive activities
- Customer surveys
- Post approval clinical studies
- Expert user focus groups
- Implant registries
Reactive activities
- Customer complains
- Maintenance service reports
- Detection of manufacturing issues
- Vigilance (EA & FSCA)
Post-market alert system requirements
- Distribution records
- Complaint records
- Adverse events (AE) reporting criteria and reporting format
- Field safety corrective action (FSCA) reporting format
Definition of adverse events
By GHTF: malfunction or deterioration in characteristics or performance of a supplied medical device or use error, which has, or could have caused/ contributed to death/ injury of the patient or others
objective of AE reporting and subsequent evaluations
improve protection of the health and safety of patients, users and others by disseminating information to reduce the likelihood of/ prevent repetition of AEs, or alleviate consequences of such repetition
AE of IVD
consequence of a medical decision/ action taken/ not taken, on the basis of result(s) provided by the IVD medical device
FSCA includes
- return of a medical device to the product owner or its representative which is recall
- Modification – which will be elaborated in the next slide
- Device exchange
- Destruct – it could be disposed at user’s end, product owner not collecting it back
- Advice given by product owner regarding the use of the device
FSCA device modification may include
- Retrofit in accordance with the product owner’s modification or design change
- Permanent or temporary changes to the labelling or instructions for use
- Software upgrades including those carried out by remote access
- Modification to the clinical management of patients to address a risk of serious injury ordeath related specifically to the characteristics of the device
Why is FSCA important
required when manufacturer of the medical device has to take action (including recall of the device) to eliminate/ reduce the risk of identified hazards
Product recall
action taken by product owner to remove / retrieve the health product from the market
Product may be:
- hazardous to health
- unable to conform to any claim made by its product owner relating to its quality, safety or efficacy
Who can initiate FSCA
- Product Owner
- Regulatory Agency
HSA regulation
Health Product Act (HPA): regulate manufacture, import, supply, presentation and advertisement of all health products
Health Products (Medical Devices) Regulations 2010: covers control of medical devices only
Medical Device Regulatory Framework
Legal Framework:
- Premarket registration
- Post-market
- Medical device establishment
Pre-market registration
- Medical device definition
- Medical device classification
- Medical device registration Z(Class A exempted)
Post-market
- Adverse events (AE) report criteria
- Field safety corrective action (FSCA) monitoring
Medical device establishments
- Establishment license (for manufacturer, importer & wholesaler)
- QMS certification
Regulatory control points to regulate medical devices
- Licensing of manufacture, import & supply
- Product registration (on Singapore Medical Devices Register SMDR, Class A exempted)
- Post-market records of recalls, distribution & advertisements
Types of registration in conformity assessment
- Registration of devices
- Registration of persons
Mandatory requirements in Health Products Act
- Control supply chain via dealers & establishments
Dealer Licensing - Legislation identify and define the joint responsibility of importers, authorised representatives and distributors
- All of them are governed by the legislation and must comply
- Responsibility period is for the entire lifetime of the device