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Download our Free Combination Products Poster

This “Lessons Learned from Combination Products” poster was presented at the Parenteral Drug Association’s (PDA) Annual Meeting. Learn about the what, when, and how in accelerating new combination product development and regulatory pathways—in light of the recently finalized guidance: Good Manufacturing Practices for Combination Products.

This document is to provide a high-level overview of RCA’s MDR consultant solutions and the EU MDR requirements for manufacturers. Included is an outline of RCA’s EU MDR consultant Compliance and Implementation services based on these requirements. Both existing and new clients may be targeted as part of the marketing campaign for these new services. Download the full document below.

The regulatory process surrounding the medical device industry involves a strict adherence to pre/post market compliance throughout a device’s life-cycle. Even a single compliance issue you have can turn into a significant effect on your business. RCA’s MDR consultant team can help guide you through any stage of this strategic process, with capabilities during product development through the regulatory clearance/approval of your product.

Our team of over 500 industry experts — including many expert MDR consultant, FDA officials and other leaders in the field of medical device regulation — will work with your company to create a quality assurance and regulatory compliance approach tailored to your products and regulatory needs. RCA works with both international Fortune 100 companies and small local start-ups, as well as law firms requesting remediation for warning letters, 483’s, import bans or consent decrees. We offer expertise in a variety of medical fields, such

 

 

Learn About our Pharmaceutical Consultants Expertise in the Pharmaceutical Industry

Whether you need support with New Product Development, Compliance Assurance, or help navigating a 483, Warning Letter, or Consent Decree, the pharmaceutical consultants at Regulatory Compliance Associates®  can help. Our industry Expert pharmaceutical consultant services have a proven track record of success and can negotiate the potential minefield of pharmaceuticals with insight, hindsight, and the clear advantage of our breadth and depth of knowledge and experience.

Our pharmaceutical consultant services highlighted in this handout include:

  • Regulatory Support for New Product Development
  • Life Cycle Management
  • Compliance Assurance
  • Quality Systems
  • Remediation Strategy & Support
  • Additional Regulatory Services

Learn About our Expertise in the Biosimilar Industry

Whether you need support with Product Development, Formulation Development, Compliance Assurance, Clinical and Manufacturing Development, Guidance and Pathways for Biologic/Biosimilar Approval, FDA Briefing, or Application Submission, Regulatory Compliance Associates® can help.

We have a proven track record of success and can navigate the Biosimilar process with insight, hindsight, and the clear advantage of our breadth and depth of knowledge and experience. Our services highlighted in this handout include:

  • Regulatory Affairs
  • Product Development
  • Formulation Development
  • Quality Systems and Compliance
  • Clinical and Manufacturing Development

Regulatory Compliance Associates® Inc. can assist you in ensuring the quality of your biologics or biosimilar product during its entire lifecycle. From pre-market to post-market reviews, inspection, and compliance, our Biotech consulting experts can shepherd your biologics through design, labeling, promotion, production, and testing.

 

To begin the Regulatory Compliance Associates® scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. 

 

MDSAP is a standardized global auditing program which allows for a single regulatory audit of a medical device manufacturer’s quality management system (QMS) to be conducted to satisfy the requirements of several global regulatory agencies and/or regulatory bodies. 

MDSAP was conceived in 2012 (launched in 2014) by the International Medical Device Regulators Forum (IMDRF).  The program officially completed the pilot phase in December of 2016 and manufacturers are now able to begin the process for certification.  Currently 5 countries are participating in the program and they include: USA, Canada, Australia, Brazil and Japan.  The World Health Organization (WHO) and the European Union (EU) are Official Observers.  One special area of consideration is that manufacturers selling products in Canada have a deadline of January 1, 2019 to become certified in order to continue to sell their products on the Canadian Market. MDSAP will replace the current Canadian Medical Devices Conformity Assessment System (CMDCAS) in Canada. The two (2) year transition period in Canada started on January 1, 2017 and continues through January 1, 2019. At the end of this transition period, only MDSAP certificates will be accepted. 

 

Global Regulatory Authorities Designated Use of the MDSAP Audit Reports
US – FDA The FDA will accept the MDSAP Audit Report in lieu of FDA routine inspections.However, MDSAP does NOT apply for certain types of regulatory inspections including:·         “for cause” inspections·         “compliance follow-up” inspections; or·         pre-or post-approval inspections for PMA (Premarket Authorization)
Canada – HC MDSAP will replace the Canadian Medical Device Conformity Assessment System (CMDCAS) by the end of the (2) two year transition period in Canada [January 1, 2017 to January 1, 2019]. After the transition period ends in Canada, only  MDSAP certificates will be accepted.
Australia – TGA MDSAP Audit Reports may be used to support compliance with the medical device authorization requirements (unless the particular medical device is excluded or exempt from the requirements)
Brazil – ANVISA MDSAP Audit Reports may be used to support the technical evaluation of the premarket and post-marketing requirements.
Japan – MHLW and PMDA MDSAP Audit Reports may be used to support the premarket and postmarket requirements.

 

MDSAP audits must be conducted by recognized Auditing Organizations (AO) authorized by the participating global regulatory agencies and/or regulatory bodies pursuant to the MDSAP requirements.  These will be conducted on an annual basis based on a (3) three year certification cycle.

 

What to expect in the MDSAP audit:

During your MDSAP audit, you should expect the Auditing Organization to cover all elements of ISO 13485 (Management, Device Marketing Authorization, Measurement and Analysis, Medical Device Adverse Events Reporting, Design and Development, Production and Service Controls, and Purchasing) with a heavy emphasis on:

  • Incorporation of risk within all processes to manage your product lifecycle
  • More scrutiny on your outsourcing practices
  • Both design and process validation
  • Design change management and risks associated with these changes

 

Value Proposition

Traditionally, manufacturers selling their products globally were faced with the challenge of being audited by multiple regulatory authorities causing disruption to manufacturers.  MDSAP evolved because it was recognized that a single audit would be more efficient while ensuring the Quality Management System was thoroughly covered during an audit.  It also provides consistency in the audit process and minimizes the burden on resources.  All important factors when you consider efficiency goals within an organization.

 

What’s in it for the Regulatory Authorities?

  • Creates a coalition of countries utilizing shared technology, resources, and services to improve the oversight of medical devices more efficiently.
  • Better utilizes the widely accepted international standards and best practices to achieve alignment of regulatory approaches of multiple regulatory bodies.

 

What’s in it for the manufacturer?

  • One audit overall instead of one per Regulatory Authority means less burden on manufacturer resources to deal with multiple audits.
  • Use of standardized non-conformity grading system will make the outcomes more predictable.
  • Utilization of a consistent audit criteria compliant to the requirements of all participating regulatory authorities will be used by the Auditing Organizations.
  • Saves you time and money by participating in 1 audit versus multiple audits.

 

Country specific Adverse Event Reporting

  • In 2012 Australia made access available to the Database of Adverse Event Notifications (DAEN). The database is searchable by report number, date, manufacture, sponsor, etc. 
  • The Manufacturer and User Facility Device Experience (MAUDE) has been available since 1996 and is also searchable by report number, date, manufacturer, etc. The product problems are categorized into more than 1,000 device and patient problems as defined by Code 3500A
  • Canada utilizes what is referred to as the Adverse Reaction Database. The search criteria is more limited however, reports date back to 1965.
  • Japan and Brazil also have information available publicly however, the incidents are only available in the local languages.
  • European Database on Medical Devices (EUDAMED)*
    • EUDAMED will be an information system for exchanging legal information related to the application of European Union Directives on medical devices between the European Commission’s Enterprise and Industry Directorate General and the Competent Authorities in the European Union Member States. Its legal basis is laid down in Directives 90/385/EEC, 93/42/EEC, 98/79/EC and 2000/70/EC.
    • EUDAMED will also develop a vigilance module. This vigilance module will inform Member States on incidents or near-incidents in relation to certain devices on the market.
    • EUDAMED will also develop a vigilance module. This vigilance module will inform Member States on incidents or near-incidents in relation to certain devices on the market.

*Note, EUDAMED is expected to be operational in March of 2019.  Note this date is subject to change.