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Medical Device Vigilance

Definitions and legal basis 1.1. Organigramme 1.2. Legal basis 1.3. Definitions 1.3.1. Materiovigilance 1.3.2. Medical Device 1.3.3. Corrective Action 1.3.4. Field Safety Corrective Action (FSCA) 1.3.5. Field Safety Notice (FSN) 2. What shall be notify?

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Medical Device Vigilance

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  2. Definitions and legal basis 1.1. Organigramme 1.2. Legal basis 1.3. Definitions 1.3.1. Materiovigilance 1.3.2. Medical Device 1.3.3. Corrective Action 1.3.4. Field Safety Corrective Action (FSCA) 1.3.5. Field Safety Notice (FSN) 2. What shall be notify? 3. Who should be notify? 4. When must incidents be notified? 5. How should incidents be notified? 5.1. Users 5.2. Manufacturers, distributors, authorised representatives Medical Device Vigilance 2

  3. 1. Definitions and legal basis Medical Device Vigilance 3

  4. 1.1 Organigramme SOE-USE Special Investigation Unit d’enquête R&D Division (human) Marketing Authorisation Division Variations & Renewals Control Policy Division Marketing Authorisation Division(human) Vigilance Division (pharmaco, materio, haemo, bio) “Industry” Division Medicines for Veterinary use Division “Dispensing” Division Health Products Division Assessors Division Proper Use Division 1. Definitions and legal basis DG PRE authorisation DG POST authorisation DG INSPECTION 4

  5. 1.2 Legal basis Royal decrees: Royal decree 18/03/1999 (art. 11): Medical Device (MD) Royal decree 15/07/1997 (art. 12): Active Implantable Medical Device (AIMD) European Directives: Directive 93/42/EEC (MD) Directive 90/385/EEC (AIMD) Other: Guideline: MEDDEV 2.12-1 rev 6: not legally binding 1. Definitions and legal basis 5

  6. 1. Definitions and legal basis • 1.3 Definitions • 1.3.1 Materiovigilance • The purpose of materiovigilance is to study and follow incidents that might result from using medical devices. It enables dangerous devices to be withdrawn from the market and to eliminate faults in medical devices with the intention of constantly improving the quality of devices and providing patients and users with increased safety. • Materiovigilance only refers to medical devices whereas pharmacovigilance refers to medicines. 6

  7. 1.3.2 Medical Device Medical device is defined as any instrument, equipment, material or other article used on its own or jointly, including software required for it to function correctly, which is intended by the manufacturer to be used on humans for the following purposes : for diagnostic, prevention, control, treating or  diminishing an illness for diagnostic, control, treating, for diminishing or compensating an injury or handicap,  for studying, replacing or modifying part of the anatomy or a physiological process for mastering conception and whose principal intended action in or on the human body is not obtained by pharmacological or immunological means or by metabolism but whose function can be assisted in such a way. More definition in the art. 1 of the law : accessory, active medical device, active implantable medical device, custommade device. 1. Definitions and legal basis 7

  8. 1.3.3: Corrective Action: Action to eliminate the cause of a potential non-conformity or other undesirable situation. NOTE1: There can be more than one cause for non-conformity. NOTE 2: Corrective action is taken to prevent recurrence whereas preventive action is taken to prevent occurrence. 1. Definitions and legal basis 8

  9. 1.3.4.: Field Safety Corrective Action (FSCA): A FIELD SAFETY CORRECTIVE ACTION is an action taken by a MANUFACTURER to reduce a risk of death or serious deterioration in the state of health associated with the use of a MEDICAL DEVICE that is already placed on the market. Such actions should be notified via a FIELD SAFETY NOTICE. The FSCA may include - the return of a MEDICAL DEVICE to the supplier; - device modification; - device exchange; - device destruction; - retrofit by purchaser of MANUFACTURER's modification or design change; - advice given by MANUFACTURER regarding the use of the device (e.g. where the device is no longer on the market or has been withdrawn but could still possibly be in use) A device modification can include: - permanent or temporary changes to the labelling or instructions for use; - software upgrades including those carried out by remote access; - For implantable devices it is often clinically unjustifiable to explant the device. Corrective action taking the form of special patient follow-up, irrespective of whether any affected un-implanted devices remain available for return, constitutes FSCA. 1. Definitions and legal basis 9

  10. 1.3.5. Field Safety Notice (FSN) A communication to customers and/or USERs sent out by a MANUFACTURER or its representative in relation to a Field Safety Corrective Action. 1. Definitions and legal basis 10

  11. 2. What shall be notify? Medical Device Vigilance 11

  12. - any dysfunction or any change of the characteristics and/or performance of a device, and any inadequacy in the labelling or instructions, which might lead to or have led to death or serious relapse in the state of health of a patient, a user or a third party. - any technical or medical reason related to the characteristics or performance of a device for reasons shown in the previous paragraph and having led to the systematic withdrawal from the market by a manufacturer of devices of the same type. 2.What shall be notify? 12

  13. Not only must one notify serious incidents which have actually taken place but also the cases where there was a risk of a serious incident but that incident was avoided thanks to the attention and action of the relevant people. 2.What shall be notify? 13

  14. Definition of an serious incident: An incident is considered serious if it has one of the following consequences or could have had such a consequence: -         death, an illness or a handicap -         a permanent lesion of a function or structure -         the need for a medical or surgical operation -         for a prolongation of a surgical operation -         incorrect results of examinations leading to an incorrect diagnostic or treatment 2.What shall be notify? 14

  15. Examples: 1. An infusion pump stops, due to a malfunction, but gives an appropriate alarm (e.g. in compliance with relevant standards) and there was no injury to the patient.  do not need to be reported. 2. An infusion pump stops, due to a malfunction of the pump, but fails to give an appropriate alarm; there is no patient injury. This should be reported as in a different situation it could have caused a serious deterioration in state of health. 2.What shall be notify? 15

  16. 3. An aortic balloon catheter leaked because of inappropriate handling of the device in use, causing a situation which was potentially dangerous to the patient. It is believed that the inappropriate handling was due to inadequacies in the labelling. This incident should be reported. 4. A defect is discovered in one (hitherto unopened) sample of a batch (lot) of a contact lens disinfecting agent that could lead to incidence of microbial keratitis in some patients. The MANUFACTURER institutes a FSCA of this batch. The FSCA should be reported. 2.What shall be notify? 16

  17. 5. Loss of sensing after a pacemaker has reached end of life. Elective replacement indicator did not show up in due time, although it should have according to device specification. This INCIDENT should be reported. 6. The premature revision of an orthopedic implant is required due to loosening. Although no cause is yet determined, this INCIDENT should be reported. 2.What shall be notify? 17

  18. 3. Who should be notify? Medical Device Vigilance 18

  19. Not only the manufacturers or their representatives but also persons distributing devices, notified bodies, practitioners and people responsible for receiving and/or delivering devices should all signal incidents to : Federal Agency for Medicines and Health Products – Vigilance Division. Email address : meddev@fagg-afmps.be 3. Who should notify? 19

  20. 4. When must incidents be notified? Medical Device Vigilance 20

  21. Incidents must be notified as quickly as possible using the quickest means possible. Incidents that have led to death or serious injury must be notified immediately. 4. When must incidents be notified? 21

  22. 5. How should incidents be notified? Medical Device Vigilance 22

  23. 5. How should incidents be notified? 5.1 User (pharmacist, doctors) • www.fagg-afmps.be • Human use • Medical devices and their accessories • How should incidents be notified 23

  24. http://ec.europa.eu/enterprise/sectors/medical-devices/index_en.htmhttp://ec.europa.eu/enterprise/sectors/medical-devices/index_en.htm Market surveillance and vigilance Reference documents Guidance 2.12 Market surveillance (Manufacturer Incident Report and Field safety Corrective Action) 5. How should incidents be notified? 5.2. Manufacturers, distributors, authorised representatives,… 24

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  28. 5. How should incidents be notified? 28

  29. Documents to provide (FSCA): - The traceability data for Belgium (list of Belgian Customers, with quantities provided per lot number). - The model letter in our national languages (FSN) - Once available evidence that the users have received the letter and reconciliation data. 5. How should incidents be notified? 29

  30. Links : • Federal Agency for Medecines and Health Products : • http://www.fagg-afmps.be/en/human_use/health_products/medical_devices_accessories/materiovigilance/index.jsp • Belgian legislation: • http://www.fagg-afmps.be/fr/humain/produits_de_sante/dispositifs_medicaux/legislation/index.jsp • Market Surveillance and Vigilance on European Commission Web Site: • http://ec.europa.eu/enterprise/sectors/medical-devices/market-surveillance-vigilance/index_en.htm • Forms: • Distributor / Manufacturer /Authorized representative / …: • FSCA:http://ec.europa.eu/enterprise/sectors/medical-devices/files/meddev/report_form_field_safety_corrective_action_en.doc • Incident: http://ec.europa.eu/enterprise/sectors/medical-devices/files/meddev/report_form_manufacturers_incident_report_en.doc • - User: • http://www.fagg-afmps.be/fr/binaries/Copie%20de%20vigilance%20report%20%20FR%20vers.041104_tcm291-27060_tcm291-27060.xls • Email address of Health Product Division and Medical Device Vigilance Unit: • meddev@fagg-afmps.be 30

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