Thursday, July 26, 2018

CE-Marking and China; Design Inputs / Requirements


Answers to some questions from my recent 3 hour DHF, DMR, DHR ... TD webinar:

CE Mark and China?

The European Union comprises 28 countries that require CE-Marking. Three additional countries (Norway, Iceland, Liechtenstein), although not officially part of the European Union, are signatories to the European Economic Area (EEA). Switzerland is not an EU member nor a signatory to the EEA, but they have transposed the Medical Devices Directives into their national law and these countries require CE Marking. -- https://www.emergobyul.com/resources/europe/where-ce-mark-is-required

 As I mentioned, the China Food and Drug Administration (CFDA) is the administrative body responsible for the regulation of medical devices and pharmaceuticals on the Chinese mainland. The US FDA resident posts in China assisted them in setting up their CFDA.  I personally know that many Chinese companies that manufacture finished devices and components for sale in the EU are certified to ISO 13485 and the CE-Marking of those products.  And those that do so for US destined products are also registered with the US FDA and subject to US FDA periodic inspections.

Writing good design inputs / requirements [for devices, processes, equipment (manufacturing, test)]?
  • List requirements needed / the reason why acquiring the equipment, RM, components in the "requirements"; expectations for it, (see below "functional, performance, interface" also),  Marketing, company manufacturing / engineering inputs; documentation and calibratable instrumentation requirements; spare parts; etc;
  • Also address the following as applicable (from one of my webinar slides): 
           "Virtually every product will have requirements of the following three types:
1.Functional requirements:  what the device does, focusing on the operational capabilities of the device and processing of inputs and the resultant outputs;
2.Performance requirements:  how much or how well the device must perform:  e.g., speed, strength, response times, accuracy, limits of operation, etc. This includes a quantitative characterization of the use environment, including, temperature, humidity, shock, vibration, and electromagnetic compatibility.  Device reliability and safety (see ISO 14971, Device Risk Management)  fit into this category;
3.Interface requirements:   characteristics of the device critical to compatibility with external systems;  characteristics mandated by external systems and outside the control of the developers.  One such important interface is the user and/or patient interface (see Use / Human Factors Engineering IEC 62366-1)."
  • Add required ISO + standards;
  • Add applicable US FDA guidance document requirements or their equivalent;
  • Convert to quantifiable / measurable terms where necessary;
Remember the requirements become the basis for V&V -- Instalation (IQ) and Operational  (OQ, all the remainining requirements) / Performance (PQs;  those requirements that need additional challenging due to allowable "worst case" inputs, e.g., different operator shifts, large volume RM, power fluctuations, other highly variable inputs.

As I mentioned, DIs and DO's during the R&D process is an iterative process, recognized as such by the FDA in it's Design Control Guidance Document.  A DI becomes a DO which in turn becomes a DI at the next level of development, which becomes a DO, until the product reaches the final stage of development.  Generally I recommend that the interim "DO's" be retained under Design Input in the DHF, and only the final DO that outputs to Design Transfer to Manufacturing, be retained under Design Output.  But the company would develop a system that works best for their culture / system, and then specify this in their Design Control SOP and then follow their SOP. 

jel@jelincoln.com