Regulatory Affairs Flashcards

1
Q

Why do medical devices require strict regulations?

A

To protect the safety and wellbeing of patients and end-users

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2
Q

Regulatory bodies have implemented regulations to ensure that MDs released on the market are:

A
  • Safe for intended use
  • Have medical benefit that exceeds risk
  • Fulfil requirements for intended use
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3
Q

What is a MD?

A

Any instrument, apparatus, appliance (used alone or in combination) to be used by human beings for the purpose of:
- Diagnosis, prevention, monitoring, tx
- investigation, replacement or modification of anatomy
- Control of conception
(NOT BY PHARMACOLOGICAL MEANS, although may be assisted by them)

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4
Q

What is an active MD?

A

MD relying for its function on a source of energy other than energy of the body or gravity

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5
Q

What is an active implantable MD?

A

An active MD intended to be introduced into the human body or a natural orifice

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6
Q

What is an in vitro diagnostic MD?

A

MD intended to be used in vitro for examination of. specimens

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7
Q

What is an intended use?

A

An intended use is how your medical device addresses (treats/alleviates) the medical condition you with to address

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8
Q

What is an indication for use?

A

An indication for use is the actual situational use of the device (specific medical need the device is used for)

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9
Q

How are medical device companies structured to navigate regulatory needs?

A

They have different departments

  • Regulatory
  • Quality
  • R&D
  • Production, manufacturing
  • Legal
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10
Q

What is the regulatory department responsible for?

A

For advising through the design and development process
For submission to regulatory bodies for approval
It has pre-market, post-market and interfacing roles.

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11
Q

How does the quality department work?

A

They are obligated to operate a QMS (Quality Management System)
They control quality internally

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12
Q

How does R&D work?

A

They lead the process to product realisation through design and development

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13
Q

What do R&D look at?

A

User needs
User input
User output
Verification, validation

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14
Q

What is the purpose of the clinical department?

A

Demonstrate that clinical data supports MD’s performance, and that clinically known benefits outweigh risks

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15
Q

Does proving clinical benefit always require a trial?

A

No, you may be able to use the equivalency argument
If an existing product is similar enough, you can prove it through the literature
- Can be sufficiently demonstrated by literature route or a combination of both
– Works well for well established. technologies
– Requires predicates that are biologically, technically and clinically equivalent

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16
Q

What does Competent Authority do in EU market?

A

It controls the process and implementation of a directive

It is involved in Class I devices and clinical trial applications

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17
Q

What does the Notified body do?

A

It enforces approvals and conducts surveillance audits

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18
Q

Where must the legal manufacturer be, for a MD sold on EU market?

A

Must be within the EU

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19
Q

What happens if if there is no literature/predicates that are equivalent, and you need to prove clinical benefit?

A

You need to prove both performance and safety through 2 phase clinical trial

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20
Q

What is the classification for medical devices in the EU defined by?

A

Invasiveness and exposure time

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21
Q

What are the classes for MD in EU?

A

Class I
IIa
IIb
III

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22
Q

What annex are these classes defined in?

A

Annex 8

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23
Q

What else will these classes require?

A

A declaration of conformity

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24
Q

What annexes are used to demonstrate conformity?

A

9,10,11

25
Q

What is the purpose of annex 2?

A

It defines requirements for technical documentation content

26
Q

What is the purpose for annex 3?

A

It sets out requirements for post-market surveillance

27
Q

Where is the General Safety and Performance Requirement contained?

A

Contained in Annex I

28
Q

General Safety and Performance Requirement function

A

Requires that all devices must be safe for end use

29
Q

What is Eudamed

A

European database on medical devices

It should store all information on medical devices

30
Q

What is the unique divide identifier (UDI)?

A

Allows you to identify where device was made, the n it was made etc.
Made up of 2 parts (UDI-DI and UDI-PI)

31
Q

What is Common Specifications (CS)?

A

group-specific specifications that create a benchmark

32
Q

What will occur in a no deal Brexit?

A

CE marked products will be recognised in the UK

UK companies will likely need new validations to sell their products in EU

33
Q

What will occur if Brexit deal is finalised?

A

Mutual recognition
UK will have its own mark
UK - EU marks will be cross recognised

34
Q

Do EU territories all have the same requirements?

A

No, they each have their own individual requirements

35
Q

What pathways is the US FDA split into?

A

4 main ones
Exempted product (self-certification, well known devices)
510K (submission and approval with a predicate)
De novo (for novel devices at low risk)
PMA (pre-market approval)

36
Q

What branches is FDA approval split into

A

Devices
Biologics
Drugs

37
Q

In the US, what do you need to identify to classify your device? What happens once you have ascertained these?

A

-Review panel
- Product code
- Regulation number
You will now be able to identify device class and submission route

38
Q

What happens if you cannot identify a regulation number in the US?

A

You will need to apply as de novo /PMA

39
Q

What is equivalence based on?

A

Key items and justification / evidence to back it

It does not mean identical

40
Q

What is the 510k regulatory paradigm

A

it is based upon substantial equivalence

41
Q

What can you use to show equivalence for 510k

A

Multiple predicates

Reference devices

42
Q

What is a special 510k?

A

Essentially device modification
Focuses on changes ot
f product that is already marketed via 510k

43
Q

What is an abbreviated 510k?

A

Submission available to devices with lots of guidance documentation and established special controls

44
Q

What is de novo route?

A

Recent alternative route to PMA, if your device has no predicate
You are essentially petitioning the FDA to introduce a new classification code and regulation number that will cover your device.

45
Q

When is de novo applicable instead of PMA?

A

If you have low/moderate risk

46
Q

When is PMA used?

A

For riskiest devices

47
Q

How long is PMA process?

A

lengthy (6 months)

48
Q

How much is PMA process?

A

Over 250k

49
Q

What is Investigation Device Exemption?

A

It is the process to obtain approval to conduct safety and performance clinical trials within the US

50
Q

What is Humanitarian Device Exemption for?

A

A device developed to benefit patients with a diagnosis of rare conditions / ailments

51
Q

What does HDE do?

A

It means you are not required to demonstrate same effectiveness requirements as the others

52
Q

What is a big benefit of applying with the FDA?

A

You get a PRE SUBMISSION DISCUSSION

This means you can ask questions to the FDA and gain insight

53
Q

How is china as a secondary market?

A

It has its own regulatory process, it does not accept approval from other territories

54
Q

Which market is generally the last one to get access into?

A

China

55
Q

How are Canada and Australia as regular markets?

A

have mutual recognition with other approval territories

56
Q

What happens as the market becomes more third world?

A

Barriers to entry become lower

Requirements become fewer

57
Q

What is the Medical Device Single Audit Programme?

A

Combines the regulatory burden of surveillance audits worldwide into just one audit
Results in certificate allowing recognition

58
Q

What is a Declaration of Conformity?

A

Declaration of Conformity is the document officially certifying that your product fulfils the essential requirements in the applicable CE directives.