Posts Tagged ‘2007/47/EC’

The MHRA has recently issued updated guidance on clinical investigations to be carried out in the UK. It’s an update on previously available guidance that takes into account the impact of 2007/47/EC, the revision to the directives which takes effect in March 2010. One of the major updates in this document is the confirmation that it will be much more difficult to obtain regulatory approval using only clinical literature and that more products will require a clinical investigation.

In addition the guidance talks the reader through making an application, outlines how it will be processed and what documentation will be required.Download here mhra-guidance-re-clinical-investigations-july-2009

For guidance as to whether your product will require a clinical investigation please contact Danielle.avadis@mediqol.com

Now that’s an obvious statement to anyone who is familiar with the amending directives but I’ve read a couple of articles lately which reinforce the point and suggest that the alternative “literature route” is going to be even more difficult to justify than perhaps originally envisaged.

A recent article published in Clinica and written by NSAI (National Standards Authority of Ireland) outlined what they expect manufacturers to be able to demonstrate if they want to obtain a CE mark for high risk products via the literature route. NSAI have specifically said that:

1. they expect the products technical characteristics to be very similar to the product referenced;
2. that biologically they expect the products of a manufacturers products to be the same as the product referenced; and
3. that the product should be clinically equivalent in that it is to be used on the same type of end user and have the same access point or application.

Given Notified Bodies will be expected to interpret and apply the amending directives in a similar fashion I think we should assume that all Notified Bodies will be taking this approach.

So what are the implications for manufacturers of Class III devices? Well time to market is obviously going to be longer and more expensive if manufacturers are forced down the investigation route. I think we’ll also see an improvement in the quality and depth of clinical evaluations produced by manufacturers seeking approval by this route. Well they’ll have to if they are going to have a chance of being accepted!

For advice and guidance on how this might affect any of your products please email jane.arnold-round@mediqol.com or Kevin.webb@mediqol.com

MEDDEV 2. 1/3 concerning borderline products, drug-delivery products and medical devices incorporating, as an integral part, an ancillary medicinal substance or an ancillary human blood derivative has been updated to take account of the changes introduced by the 2007/47/EC amendments and is available to download here.

This guidance document is essential reading for manufacturers of medical devices intending to CE mark combination products that incorporate a medicinal substance or a human blood derivative.

I recently gave a presentation on the impact of 2007/47/EC to about 30 medical device manufacturers. I think it went ok, no one seemed to be asleep at the end!

There are now only eight months to go until compliance with the new MDD is mandatory and we are starting to see more and more companies asking for help with clinical evaluations; the requirement for which are significantly increased by the directive. There are 15-20 other significant amendments which you can find summarised in the presentation here.