Tuesday, September 22, 2020

Get to know about Clinical Evaluation Report


 A Clinical Evaluation Report (CER) records the determinations of a clinical evaluation of your medical device. A CER comprises of examined clinical data that was gathered either from a clinical investigation of your device, or the aftereffects of different investigations on significantly equivalent devices. The CER shows that your device accomplishes its expected reason without uncovering clients and patients to additionally chance.

Clinical Evaluation Report is required for all medical devices in Europe. You should present your CER to your Notified Body as a connection to your European CE Technical File. The Technical File is a basic advance to acquiring CE Marking for your device, which is needed to sell or disperse medical devices in Europe.

 

Medical device manufacturers need to evaluate clinical data from their own medical device or an equivalent device, whose security and clinical execution is the same. Under the MDR, the medical device manufacturer needs to consider three elements to demonstrate an item is identical: biological, technical and clinical. 
The MDR places great accentuation on Clinical Evaluation Reports or CERs. The Clinical Evaluation Report shapes part of the Technical File, which is the primary documentation which exhibits regulatory compliance and gives all the information about the device. Medical device organizations need to take a few measures to ensure that their CER is solid and steady and very much kept up. Clinical Evaluation Report documentation ordinarily includes 4 phases:

  • Defining the extent of the device, its intended usage and therapeutic / diagnostic claims.
  • Identifying and validating clinical data.
  • Analyzing the data and interpreting it to check whether it meets all the necessities.
  • Identifying risks and uncertainties, this might be replied during post-market surveillance (PMS).

Clinical Evaluation Report

Clinical Evaluation Report for Medical Device

A Clinical Evaluation Report (CER) for Medical Device is a document that contains the finishes of the clinical evaluation performed on the medical device dependent on all important clinical data accessible.

The CER and the clinical data are utilized together to demonstrate the similarity of the medical device to the general safety and execution necessities. The CER incorporates the details of the clinical foundation, current information, and best in class which can be utilized to assess the security and execution of the device for comparing to its expected reason. 

If a settled CE marked device which is like the device under evaluation, at that point the reports of that device can be utilized to demonstrate the security and execution of the device under evaluation by asserting equivalency, given an agreement is set up between the two manufacturers. Details of the post-market activities directed are additionally given in the CER, which is utilized to address any unanswered inquiries or residual risks that are not secured by the accessible clinical data.

Also, the aftereffects of the various tests directed are listed to demonstrate the wellbeing and execution of the gadget. During the investigation of the appraised information, the prerequisites on security, execution, agreeableness of advantage/hazard profile, and symptoms are surveyed to set up adjustment to GSPR.

The conclusion of CER includes the acceptability of the risk-benefit profile according to current knowledge/ the state of the art in the medical fields concerned and according to available medical alternatives.
It also includes the adequacy of the information materials supplied, whether the intended purpose and risk reduction measures are adequate and any discrepancies.

Summary of the suitability of the device, including its IFU, for the intended users and usability aspects, any discrepancies are also included along with the adequacy of claims and its discrepancies. If there is consistency between the clinical data, the information materials, the risk management documentation for the device under evaluation; discrepancies should be summarized. The CER is used to ultimately evaluate and prove the device is safe for use on humans and that it performs as expected when used according to the manufacturer’s instructions.

Also, the CER shows that the presence of the device on the market is justified because of side-effects and risks, if any, are outweighed by the benefits of the device.

Device under Clinical Evaluation

The device under evaluation section is intended to describe the device, yet additionally depict the techniques utilized for the CER and the data investigation. It ought to incorporate a few segments, including a reason for the clinical evaluation, a showing for equality (if pertinent), and the clinical informational indexes utilized. This segment must address whether the clinical evaluation depends on logical writing and legitimize proportionality if clinical information isn’t proper for the device.


Type of evaluation
Demonstration of equivalence
Data generated and held by the manufacturer

– Post-market surveillance
– Post-market clinical follow up
– Relevant Pre-clinical studies
– Biocompatibility testing (biological and clinical equivalence)
– Bench testing (technical and clinical equivalence)
– Electrical safety
– Software verification and validation

Data retrieved from literature
Summary and appraisal of clinical data
Analysis of the clinical data

 – Requirement on Safety
 – Requirement on acceptable benefit/risk profile
 – Requirement on Performance
 – Requirement on the acceptability of undesirable side-effects

Preparing a clinical evaluation report (CER) is time-consuming, but the report is also a living document. Therefore, you need to have a post-market surveillance plan for each medical device or device family that specifies the frequency of performing a review and update of your clinical evaluation report (CER). Depending upon the nature of your device and the amount of clinical history you have with that device, you may also need to conduct a post-market clinical follow-up study (PMCF). Any post-market surveillance that you conduct should be included as an input to the clinical evaluation report.

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Wednesday, September 16, 2020

Difference between FDA cleared vs FDA approved


 FDA cleared vs FDA approved is a significant capability between a drug and medical device. Given that undeniably more tech things are being checked by FDA, it’s basic to fathom the qualification.

Generally, “FDA approved” applies to drugs, however “FDA cleared” applies to “devices” and instruments. As a condition of clearness, things like number crunchers and plans that are used to make clinical decisions are considered “devices” in this particular situation, so even a mimeographed sheet used to work up a differential assurance with some check boxes on it is a “medical devices” that ought to be cleared by the FDA cleared vs approved (the standard is whatever replaces or instructs a point of view with respect to the demonstration with respect to drug).

  • We provide regulatory consulting of US FDA 510k for medical devices manufacturing.
  • We also assist with the establishment registration and device listings to make suitable the supply of medical devices in the US.

All manufacturers who try to showcase medical devices in the United States should initially pass an extremely exhaustive cycle with the FDA through one of two pathways—the section 510(k) measure, where a device is “cleared” for conveyance, or the Premarket Approval (PMA) measure, where a device is “approved” by the FDA.

Medical device organizations can utilize this pathway of FDA cleared vs FDA approved in the event that they can demonstrate considerable equality with a current item. The FDA analyst is assesses the data you give to “clear” your devices as like the predicate.

FDA cleared .vs. approved

The PMA cycle, which ordinarily includes Class III devices, is considerably more thorough than the 510(k) measure. The devices need to demonstrate security and viability through clinical proof. This permits the FDA to put their stamp of “endorsement” on the devices.

It’s an obvious fact that Class II and Class III items are dependent upon different kinds of FDA investigations. FDA auditors can be probably the most conscientious individuals you will actually meet. They will look at your documentation intently, so you need to ensure you get the straightforward things, for example, phrasing, right.

What does FDA cleared vs FDA approved mean?

Clearance demands are for medical devices that are actually similar to those as of now available. Affirmed demands are for things that are totally new and should be investigated for security in the event of new perils. The two angles should be demonstrated or given by the submitter to guarantee legitimate methods are followed.

It implies that the office has established that the “advantages of the item exceed the known dangers for the planned use.” Manufacturers must present a premarket approval (PMA) application and the aftereffects of clinical testing so as to get approval.

When deciding to approve a product or drug, the FDA has to decide if the benefits outweigh the risks. The FDA is usually inclined to approve a product that has a higher risk if the potential benefit is significant — like an artificial heart valve that can save someone’s life.

FDA cleared or approved is usually mandatory to market or sell products in the US that might have a significant risk of injury or illness, but can also benefit your health — such as prescription medications, over-the-counter medications, vaccines and Class III medical devices.

The FDA categorizes medical devices into Class III, Class II and Class I. Complex medical devices that are implanted in your body, life-sustaining, or have the potential to cause significant injury or illness in the body are in Class III. Those include implanted pacemakers, replacement heart valves and even breast implants.

Lower-risk devices and products used outside of the body, like condoms, motorized wheelchairs and bandages, fall into Class II and Class I. For reference, Apple’s ECG app for the Apple Watch is in Class II.

This distinction is usually applied to medical devices. Medical devices are classified into 3 categories based on ease of use and risk in case of failure:

Class I: Low risk devices (e.g., bed pans, bandages, etc.)

Class II: Medium risk devices (e.g., pregnancy kits, glucose monitors, etc.)

Class III: High risk devices (e.g., pacemakers)

Accordingly, the stringency of regulations applied to get these devices to market varies from most relaxed to strictest. For a device to be FDA cleared or approved it only needs to show that it is comparable in performance to other similar devices already on the market. This is usually applied to Class II devices. However, for an “FDA approved” label, more extensive safety and effectiveness testing is performed before the device can be sold or marketed.

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    2.     CDSCO Registration
    3.     FDA 510 k clearance
    5.     Design Control Requirements
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Wednesday, September 2, 2020

Medical Devices: LIFE After The Emergency Use Authorization (EUA)

  


In almost five decades of FDA experience, this is the first time I have ever seen a Emergency Use Authorization (EUA) put into practice — but, in real terms, what is a “EUA,” and why it is used so infrequently? The Emergency Use Authorization (EUA) authority permits FDA to help fortify the country’s public health protections against CBRN dangers by encouraging the accessibility and utilization of MCMs required during public health crises.

Under segment 564 of the Federal Food, Drug, and Cosmetic Act he FDA Commissioner may permit unapproved medical products or unapproved employments of endorsed medical products to be utilized in a crisis to analyze, treat, or forestall genuine or hazardous sicknesses or conditions brought about by CBRN (concoction, natural, radio logical, and atomic) danger operators when there are no satisfactory, affirmed, and accessible other options.

Operon Strategist is FDA 510 k process consultant helps the clients to register SBU (Small Business Unit), if applicable.

We also assist with the establishment registration and device listings to make suitable the supply of medical devices in the US

The U.S. EUA, Emergency Use Authorization Act, will be lifted, the medical device industry returns to the real world, and the FDA recovers control of the clinical endorsement measure with a genuine device audit set up.

The FDA’s position underpins the crisis readiness and reaction and cultivates the turn of events and accessibility of clinical items for use in the crises. These medical products, additionally alluded to as clinical countermeasures or MCMs, incorporate medications (e.g., antiviral and counteract ants), organic items (e.g., immunizations, blood items, and natural therapeutics), and gadgets (e.g., in vitro diagnostics and PPE).

Before the FDA may issue a EUA, the HHS Secretary must declare circumstances that exist to justify the authorization of the EUA and include the following actions:

  1. A determination by the Secretary of Homeland Security that there is a domestic emergency, or a significant potential for a domestic emergency, involving a heightened risk of attack with a CBRN agent(s);
  2. A determination by the Secretary of HHS that there is a public health emergency, or a significant potential for a public health emergency, that affects, or has a significant potential to affect the national security or the health and security of United States citizens living abroad, and that involves a CBRN agent or agents, or a disease or condition that may be attributable to such agent(s).

Importance of ppe in healthcare

After the Secretary of HHS gives an EUA statement, in view of one of these two judgments, and in the wake of counseling (to the degree attainable and proper given the pertinent conditions) with the Assistant Secretary for Preparedness and Response (ASPR), the Director of the National Institutes of Health (NIH), and the Director of CDC, the Commissioner may approve the crisis utilization of an unapproved item or an unapproved utilization of an endorsed item, given that other legal standards are met.

EUA applicant products incorporate medical products and utilizations that are not endorsed, cleared, or authorized under areas 505, 510(k), and 515 of the FD&C Act or segment 351 of the PHS Act. After the requisite determination and declaration have been issued subsequent to feasible and appropriate consultations, FDA may issue a EUA only if the FDA concludes that the following four statutory criteria for issuance have been met.

If the product does not meet the statutory criteria for issuance or is not otherwise an appropriate candidate, an alternative regulatory mechanism (i.e., access under an IND or IDE, which can include expanded access protocols) may be an appropriate means to provide patients access to an unapproved use of a product in a CBRN emergency.

  • Serious or Life-Threatening Disease or Condition
  • Evidence of Effectiveness
  • Risk-Benefit Analysis
  • No Alternatives
  • Serious or Life-Threatening Disease or Condition:

For the FDA to issue a EUA, the CBRN agent(s) referred to in the HHS Secretary’s EUA declaration must be capable of causing a serious or life-threatening disease or condition.

  • Evidence of Effectiveness:

The “may be effective” standard for EUAs provides for a lower level of evidence than the “effectiveness” standard that the FDA uses for product approvals. The FDA intends to assess the potential effectiveness of a possible EUA product on a case-by-case basis using a risk-benefit analysis, as explained below.

  • Risk-Benefit Analysis

In determining whether the known and potential benefits of the product outweigh the known and potential risks, the FDA intends to look at the totality of the scientific evidence to make an overall risk-benefit determination. Such evidence, which could arise from a variety of sources, may include (but is not limited to): results of domestic and foreign clinical trials, in vivo efficacy data from animal models, and in vitro data, available for FDA consideration.

  • No Alternatives

For the FDA to issue a EUA there must be no adequate, approved, and available alternative to the candidate product for diagnosing, preventing, or treating the disease or condition. A potential alternative product may be considered “unavailable” if there are insufficient supplies of the approved alternative to fully meet the emergency need. 

Be assured that the EUA conclusion will come as a big surprise for many of the companies that have been exporting under this temporary status. The bigger surprise may come if the FDA conducts its own testing and, as a result, requests that non compliant products to be recalled. Getting things back to normal for the FDA premarket review is a necessity. The public needs the assurance that the devices and drugs they are using are safe and effective. But, how does the FDA ever balance the increasing supply demands with the required device and drug quality

–  By Alan Shwartz (MDI Consultant, USA)

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CDSCO Import License for Medical Devices In India

  Central Drugs Standard Control Organisation is, known as CDSCO, is a regulatory body for the Indian medical devices industry, under the vi...