Clinical Evaluation of Orphan Devices: Navigating MDCG 2024-10

The Medical Device Coordination Group (MDCG) recently released guidance MDCG 2024-10, focusing on the clinical evaluation of orphan medical devices. This comprehensive guidance aims to address the unique challenges and regulatory requirements for orphan devices under the Medical Device Regulation (MDR) 2017/745. Orphan medical devices are intended for rare diseases or conditions, affecting a small patient population. This article delves into the key aspects of the new guidance, emphasizing the clinical evaluation processes and the implications for manufacturers.

Introduction to Orphan Devices

Orphan medical devices play a crucial role in providing diagnostic or therapeutic solutions for rare diseases or conditions, which often lack adequate medical alternatives. The MDR has stringent requirements for clinical evidence, which pose significant challenges for orphan devices due to their limited patient population and the ethical concerns surrounding clinical investigations in vulnerable groups, such as children.

Defining Orphan Devices

Orphan devices (OD) are defined as medical devices or accessories intended for the treatment, diagnosis, or prevention of diseases or conditions that affect no more than 12,000 individuals annually in the European Union. To qualify as an orphan device, the device must meet one of the following criteria:

  • There is an insufficiency of available alternative options for the treatment, diagnosis, or prevention of the disease or condition.
  • The device provides an expected clinical benefit compared to available alternatives or the current state of the art, taking into account both device-specific and patient population-specific factors.

Scope of Applicability for MDCG 2024-10

The MDCG 2024-10 guidance does not apply to the following types of devices:

  • Custom-made devices: According to EU MDR Article 2(3).
  • In-house devices: According to EU IVDR Article 5(5).
  • Products without an intended medical purpose: According to EU MDR Annex XVI.
  • In vitro diagnostic medical devices: Devices covered under the In Vitro Diagnostic Medical Devices Regulation (IVDR) 2017/746.

Evaluating Clinical Data Limitations

For orphan devices, it is acknowledged that the scarcity of available patients and the nature of the conditions often limit the amount of comprehensive clinical data that can be gathered pre-market. Therefore, the MDCG allows for certain limitations in pre-market clinical data under specific conditions:

  • There must be enough existing non-clinical and clinical data to suggest that the device can perform its intended purpose with an acceptable level of safety.
  • Any limitations in the clinical data must be transparently communicated to healthcare professionals and users.
  • The manufacturer must implement an effective post-market surveillance (PMS) strategy and post-market clinical follow-up (PMCF) plan to gather further data and validate the clinical performance and safety of the device post-launch.

Importance of Non-clinical Data for OD

Non-clinical data play a pivotal role in supporting the safety and efficacy of orphan devices, especially when clinical data are limited. This data can include:

  • Laboratory and animal studies that provide preliminary safety and performance insights.
  • Engineering and bench tests that demonstrate the device’s mechanical and functional integrity.
  • Computational modeling that predicts device behavior in various scenarios.

Manufacturers are encouraged to utilize robust non-clinical data to justify the safe use of their devices, reducing the reliance on extensive pre-market clinical trials which may not be feasible for orphan devices.

Expert Panel Consultation: Enhancing the Orphan Device Certification Process

Section 11 of the MDCG 2024-10 guidance outlines the role of expert panels in the evaluation process of orphan medical devices. This section emphasizes the importance of obtaining external expert advice to ensure that orphan devices meet stringent safety and efficacy standards before they reach the market. The involvement of expert panels is particularly crucial given the unique challenges associated with the development and evaluation of devices intended for rare diseases.

Purpose of Expert Panel Consultation

The consultation with expert panels serves multiple purposes:

  • Verification of Orphan Device Status: Expert panels assist in verifying the orphan status of a device, ensuring that the manufacturer’s justification aligns with the regulatory definitions and requirements.
  • Assessment of Clinical Evidence: Panels review the sufficiency and appropriateness of both clinical and non-clinical data to support the intended use of the device. This is especially critical when traditional clinical trial routes are impractical due to the rarity of the condition the device is designed to treat.
  • Guidance on Regulatory Compliance: Expert panels provide guidance on whether the device meets the overall regulatory requirements, including safety and performance standards outlined in the MDR.

Process of Expert Panel Involvement

  1. Early Engagement: It is recommended that notified bodies engage with expert panels as early as possible, ideally during the pre-assessment phase of the device certification process. This early engagement allows for a structured dialogue between the manufacturer, the notified body, and the expert panel, facilitating a thorough and informed evaluation.
  2. Review of Manufacturer’s Submission: The expert panel reviews the documentation provided by the manufacturer, focusing on the justification for the orphan device classification and the adequacy of the clinical and non-clinical evidence.
  3. Issuance of Recommendations: Based on their review, the expert panel issues recommendations that can significantly impact the certification process. These recommendations might pertain to additional data requirements, modifications to the device or its intended use, or specific post-market surveillance strategies.
  4. Influence on Notified Body Decisions: The advice provided by the expert panel is taken into consideration by the notified body in their final decision-making process. While the notified body is not bound to follow the panel’s recommendations, any deviations must be well justified in the assessment report.

Benefits of Expert Panel Consultation

The involvement of expert panels in the certification process of orphan devices brings several benefits:

  • Enhanced Device Safety and Efficacy: Expert panels contribute to a higher level of scrutiny, potentially increasing the safety and efficacy of devices approved for rare conditions.
  • Reduced Risk of Post-Market Issues: By addressing potential issues during the pre-market phase, expert panels help reduce the risk of significant complications once the device is in clinical use.
  • Increased Confidence Among Stakeholders: The input from expert panels can increase confidence among healthcare providers, patients, and regulatory bodies regarding the reliability and effectiveness of orphan devices.

Notified Bodies

Notified bodies play an essential role in determining whether a device qualifies as an orphan device before its certification. This critical initial assessment should be conducted as early as possible to ensure compliance and readiness for market entry:

  • Verification of Orphan Device Status:

The orphan status of the device should be verified at the earliest opportunity, ideally during a structured dialogue before or during the initial conformity assessment activities. This verification involves a thorough assessment of the evidence provided by the manufacturer, which must justify the classification of the device as an orphan, as detailed in section 4.2 of the guidance.

  • Assessment of Clinical and Non-clinical Data:

Notified bodies are tasked with evaluating the sufficiency and quality of both clinical and non-clinical data submitted by the manufacturer. This evaluation is crucial to ensure that, despite the acknowledged limitations typically associated with clinical data for orphan devices, there is robust evidence to demonstrate that the device can perform safely and effectively.

  • Compliance with Regulatory Requirements:

The review process must confirm that the device complies with all relevant regulatory requirements, with a focus on safety and performance standards as specified in the Medical Device Regulation (MDR).

Additionally, if applicable, notified bodies may take into consideration advice provided by an expert panel. This advice can significantly influence the assessment, particularly regarding the device’s status as an orphan and the adequacy of the clinical evidence. This expert input ensures a comprehensive review process, aligning the device assessment with the highest standards of regulatory compliance and patient safety.

Conclusion for the Clinical Evaluation of Orphan Devices

The MDCG 2024-10 guidance provides a structured approach for the clinical evaluation of orphan medical devices, balancing the need for clinical evidence with the practical challenges of studying rare conditions. By allowing for limitations in pre-market clinical data and emphasizing robust non-clinical evidence and post-market follow-up, the guidance aims to facilitate the market access of orphan devices, ultimately improving patient care for rare diseases. Manufacturers must navigate these requirements carefully, leveraging robust non-clinical data and detailed documentation, to ensure that orphan devices meet regulatory standards while addressing the unique needs of patients with rare conditions.

Industry Insights & Regulatory Updates

MDR Investigator´s Brochure: Consolidating MDCG 2024-5 and ISO 14155 for Medical Devices

The Investigator´s Brochure (IB) is a critical document in the realm of clinical research for medical devices. As mandated by the European Union Medical Device Regulation (EU MDR) 2017/745, the creation of an Investigator´s brochure is a fundamental requirement for conducting clinical investigations. This document must encapsulate all relevant clinical and non-clinical information concerning the investigational device, thus serving as the principal source of information for investigators overseeing clinical investigations with medical devices.

Under the stringent provisions of the EU MDR, the IB is designed to ensure that medical devices undergoing clinical investigations are evaluated thoroughly and scientifically. This evaluation helps ascertain that the devices are used safely and with optimal performance, protecting the health of the patients involved. The MDR Investigator´s Brochure must align with the standards set by ISO 14155, which outlines the requirements for good clinical practice in the design, conduct, recording, and reporting of clinical investigations carried out on human subjects. Furthermore, the Medical Device Coordination Group’s (MDCG) guidance, specifically MDCG 2024-5, provides additional clarity and specifics on structuring the Investigator´s Brochure. This guidance emphasizes the necessity for the IB to be clear, comprehensive, and meticulously detailed, enabling it to support the clinical investigation effectively by providing investigators with the knowledge needed to assess the investigational device critically.

The IB communicates essential information about the investigational device’s safety, design, and manufacturing and also synthesizes data from previous studies to establish a robust framework for clinical investigations. This synthesis is crucial for understanding the potential risks and benefits of the device, guiding ethical and regulatory decision-making processes throughout the clinical investigation phases.

Investigator´s Brochure for the MDR: Regulatory Context and Importance

Regulated by EU MDR 2017/745

The European Union Medical Device Regulation (EU MDR) critically outlines the requirements for clinical investigations within the EU. Specifically mentioned twice, Article 71.4 of the EU MDR states that the Investigator´s Brochure must provide comprehensive information on the investigational device, ensuring it corresponds to the state of scientific knowledge and is suitable for proving safety, performance, and benefits during clinical investigations. This article explicitly mandates that the IB should contain detailed descriptions of the device, its intended use, risk classification, design, manufacturing details, and all necessary clinical and non-clinical information at the time of application. This thorough documentation supports the assertion that the device is appropriately evaluated before and during clinical investigations.

Standardized by ISO 14155

ISO 14155, which mentions the IB four times, sets the standards for good clinical practice in the design, conduct, recording, and reporting of clinical investigations involving human subjects. In Section 6.5 and Annex B of ISO 14155, the standard details the requirements for the IB, emphasizing that it must provide principal investigators with sufficient safety and performance data from pre-clinical and other clinical investigations. It highlights the need for the IB to be updated continually throughout the clinical investigation as significant new information becomes available, ensuring that the documentation is current and comprehensive.

Detailed in MDCG 2024-5

The Medical Device Coordination Group’s guidance, MDCG 2024-5, provides specific details on what should be included in the IB to support a clinical investigation application. This guidance aims to clarify how to comprehensively compile the IB to meet regulatory expectations and facilitate the review process by competent authorities. It emphasizes the necessity for clear, non-promotional, and balanced content that enables potential investigators to make informed decisions regarding the clinical investigation.

Structuring the MDR Investigator´s Brochure: A Detailed Approach

The detailed description of the investigational device forms a crucial part of the Investigator´s Brochure (IB). This section must provide a thorough overview of the device, including its design, operational mechanics, and the scientific rationale behind its development. The aim is to furnish investigators with the necessary information to understand the device’s functionality, potential clinical applications, and safety features.

General Information

  • Device Identification: This includes the official name, model number, and any other identifiers unique to the device. It’s essential to maintain consistency in terminology throughout the IB to avoid confusion.
  • Regulatory Status: Details about the device’s approval status, including whether it is under investigation or already approved for use in other contexts or regions. This should align with the regulatory requirements of the EU MDR and include any CE marking statuses.

Technical Details

  • Design Overview: A comprehensive description of the device’s design, highlighting any innovative features. This should cover the underlying technology, operational principles, and any software components integral to the device’s function.
  • Materials and Components: Detailed information about the materials used in the device’s construction, especially those in contact with patients. Information on biocompatibility must be included as per ISO 10993-1 standards, ensuring that all materials are safe for intended use scenarios.
  • Manufacturing Process: Insight into the manufacturing processes, including quality control measures and compliance with current good manufacturing practices (cGMP). This transparency helps assure investigators of the device’s reliability and consistency in production.

Operational Mechanics

  • Mechanism of Action: Explanation of how the device achieves its intended medical purpose. This includes a description of any mechanical, electronic, or biological actions that are central to the device’s operation.
  • Instructions for Use: Clear, step-by-step instructions on how the device should be operated during the clinical investigations, including setup, usage, and shutdown procedures, if applicable. This section should also address any training requirements for investigators or clinical staff.

Safety Features

  • Safety Mechanisms: Details of built-in safety features designed to protect the patient and user, such as automatic shut-offs, error alerts, and fail-safes.
  • Known Risks and Mitigation Strategies: An overview of identified risks associated with the device, along with strategies implemented to mitigate these risks. This should be directly linked to the risk management processes detailed in a later section of the IB.

This section of the IB serves not only to inform but also to build confidence among clinical investigators and regulatory bodies regarding the investigational device’s suitability for clinical investigations. By providing a clear and detailed description of the device, the IB helps ensure that all stakeholders have a deep understanding of the device’s capabilities, safety, and potential impact on patient health.

This section of the IB comprehensively details the investigational device’s performance in both pre-clinical and clinical settings. It should offer a thorough summary of all relevant studies, ensuring that investigators have access to comprehensive data that supports the safety and performance of the device.

Pre-Clinical Studies

  • Overview of Studies: A summary of all pre-clinical studies conducted, including laboratory, in vitro, in vivo (animal studies), and any biomechanical or biochemical research relevant to the device’s intended use. This should include detailed results and interpretations.
  • Safety and Performance Data: Detailed findings from pre-clinical tests that assess the safety and performance of the device. This includes any biocompatibility testing done in accordance with ISO 10993, mechanical and durability testing, and any other relevant safety evaluations.
  • Regulatory Compliance: Explanation of how pre-clinical testing complies with relevant regulations and standards, including any deviations from standard protocols and justifications for such deviations.

Clinical Data

  • Summary of Clinical Investigations: A detailed account of previous and ongoing clinical investigations involving the device, including study design, methodology, sample size, duration, endpoints, and primary outcomes. This should include both published and unpublished data.
  • Safety and Performance Outcomes: Analysis of data related to the device’s safety and performance from clinical investigations, highlighting any significant adverse events, device deficiencies, and corrective actions taken.
  • Comparative Analysis: If applicable, comparative data from similar devices or previous versions of the same device, providing a contextual understanding of the investigational device’s performance.

Integration of Data

  • Data Correlation: Correlate pre-clinical findings with clinical outcomes to illustrate how earlier studies have informed clinical investigation designs and expectations.
  • Rationale for Clinical Investigation: Based on the integrated data, provide a comprehensive rationale for proceeding with further clinical investigations, outlining expected benefits, potential risks, and overall clinical value of the device.

Justification of Clinical Relevance

  • Scientific Literature: Review and summarize relevant scientific literature that supports the use, safety, and performance of the device. This should include any meta-analyses, systematic reviews, and key opinion papers.
  • Regulatory Considerations: Discuss any regulatory feedback or advisories that have impacted the clinical development of the device, including any special designations or regulatory pathways that are being utilized.

This section of the IB is critical for establishing the scientific and clinical foundation upon which the clinical investigation is based. It must convincingly demonstrate that the investigational device has been thoroughly evaluated in non-clinical settings and that the data derived from these evaluations justify its examination in human subjects. By providing clear, comprehensive, and scientifically sound data, this section helps ensure that the clinical investigation proceeds with a well-defined understanding of the device’s potential impacts on patient safety and performance.

Overview of Risk Assessment

  • Risk Identification: Detail all potential risks associated with the use of the device, derived from pre-clinical studies, historical data from similar devices, and initial clinical investigations. This should include both device-specific and procedure-related risks.
  • Risk Analysis: Evaluate the likelihood and potential impact of identified risks. Use qualitative and quantitative methods to assess how these risks could affect patient safety and the reliability of study results.

Risk Control Strategies

  • Risk Mitigation Measures: Outline specific strategies and actions taken to minimize identified risks. This includes design modifications, safety features integrated into the device, and specific procedural steps taken during clinical investigations to mitigate risks.
  • Monitoring and Reporting: Procedures for ongoing monitoring of risks throughout the clinical investigation. Detail how adverse events and device deficiencies will be recorded, analyzed, and reported. Include information on the data monitoring committee’s role and any interim analyses planned.

Documentation and Communication of Risks

  • Risk Communication Plan: Describe how information about risks is communicated to all stakeholders, including clinical investigation sites, investigators, and participants. Ensure that all parties are aware of potential risks and the measures in place to protect participants.
  • Training Programs: Detail training provided to clinical staff and investigators to recognize, manage, and report risks effectively. Training should cover the proper use of the device, recognition of adverse events, and emergency procedures.

Benefit-Risk Analysis

  • Overall Benefit-Risk Profile: Synthesize the benefits and risks of the device to demonstrate that the anticipated benefits outweigh the risks. This analysis should be based on data from pre-clinical and clinical studies and should be updated with new information obtained during the investigation.
  • Regulatory Compliance: Ensure that the risk management approach complies with ISO 14971, the international standard for the application of risk management to medical devices, and any specific regulatory requirements pertinent to the device.

Continuous Risk Management

  • Review and Update: Mechanisms for regularly reviewing and updating the risk management plan as new data become available or as circumstances change during the investigation. This includes planned revisions following interim analyses or in response to external factors such as newly published research or changes in clinical practice.

Risk Management Documentation

  • Documentation Standards: Maintain comprehensive documentation of all risk management activities, including assessments, decisions made, actions taken, and the rationale behind each decision. Documentation should be readily accessible and auditable.

This section of the MDR Investigator´s Brochure is essential for ensuring that all potential and actual risks are adequately managed throughout the clinical investigation. The risk management  protects participants and also ensures the integrity of the clinical data and supports the ultimate goal of demonstrating the device’s safety and performance.

Compliance with General Safety and Performance Requirements (GSPRs)

  • GSPR Alignment: List and describe how the investigational device complies with each of the applicable General Safety and Performance Requirements as outlined in Annex I of the EU MDR. This includes detailing the device’s design, manufacturing processes, and performance characteristics that ensure compliance.
  • Standards and Specifications: Identify all standards and Common Specifications (CS) applied during the device’s development and testing phases, such as ISO standards for medical devices, IEC standards for electrical devices, etc. Provide a justification for each standard’s application and describe how it contributes to the device’s compliance with the GSPRs.

Documentation of Compliance

  • Evidence of Compliance: Provide documentation or summaries of test results and analyses that demonstrate the device’s compliance with the aforementioned standards and requirements. This should include both pre-clinical and clinical data, as well as any data related to device modifications.
  • Notified Body Interaction: Detail interactions with Notified Bodies, including any conformity assessments or certifications obtained. This section should also cover the scope of the assessments, highlighting critical areas reviewed and any recommendations made by the Notified Body.

Regulatory Submissions and Approvals

  • Regulatory Filings: List all regulatory filings made for the device, including submissions to national and international regulatory agencies. Detail the status of these filings, any approvals received, and pending decisions.
  • Labeling and Instructions for Use: Ensure that the device’s labeling and instructions for use comply with regulatory requirements. Include information on language requirements, symbols used, and any specific labeling considerations for investigational use.

Compliance with International Guidelines

  • ISO 14155 Compliance for Clinical Investigations: Demonstrate how the clinical investigations comply with ISO 14155, which outlines good clinical practice for the design, conduct, recording, and reporting of clinical investigations performed on human subjects. Discuss any deviations from these guidelines and provide justifications.
  • Ethical Considerations: Address ethical considerations in compliance with the Declaration of Helsinki and local regulations where the clinical investigations are being conducted. Include information on ethical review board approvals, informed consent processes, and any other ethical safeguards in place.

Continuous Regulatory Monitoring

  • Monitoring Changes in Regulations: Establish a process for monitoring and responding to changes in regulatory requirements that could affect the ongoing clinical investigations. This includes updates to laws, guidelines, or standards relevant to the device or its clinical investigation.
  • Adaptation to Regulatory Changes: Describe the strategies for adapting the clinical investigation and documentation practices in response to regulatory changes, ensuring ongoing compliance throughout the investigation’s duration.

This section of the MDR IB serves to assure all stakeholders, including regulatory authorities, ethics committees, and clinical investigators, that the device meets all necessary safety, performance, and regulatory requirements for clinical investigation. It underscores the sponsor’s commitment to adhering to the highest standards of regulatory compliance and patient safety.

Update Procedures

  • Scheduled Updates: Define a schedule for regular reviews and updates of the IB. These should be strategically timed to follow major study milestones, such as the completion of certain phases or after significant data analysis points.
  • Trigger Events for Ad-Hoc Updates: Specify conditions or “trigger events” that necessitate immediate updates outside of the regular schedule. These may include significant adverse events, changes in regulatory requirements, or substantial amendments to the clinical investigation protocol.

Document Control and Version Management

  • Version Tracking: Implement a version control system to track all changes made to the IB. Each version should be clearly numbered and dated, with a summary of changes provided in each new version.
  • Archiving Procedures: Establish procedures for archiving superseded versions of the IB. This ensures that previous versions are accessible for reference or regulatory review, maintaining a complete history of document changes.

Communication of Updates

  • Notification System: Develop a systematic approach for notifying all stakeholders, including clinical investigation sites, ethics committees, and regulatory authorities, of updates to the IB. Notifications should detail the nature of the updates and their implications for ongoing clinical activities.
  • Training on Updates: Coordinate training sessions for all relevant clinical investigation personnel whenever significant updates are made to the IB. This ensures that all team members are informed about the latest device information, safety protocols, and compliance requirements.

Regulatory Compliance of Updates

  • Regulatory Submission of Updated IB: Outline the procedures for submitting updated versions of the IB to regulatory authorities as required by local regulations or international guidelines. Include timelines for submissions following significant changes or discoveries during the investigation.
  • Compliance Audits: Regularly audit the update and revision processes to ensure they comply with both internal quality standards and external regulatory requirements. Audits help identify and rectify any discrepancies or inefficiencies in the documentation process.

Feedback Mechanism

  • Stakeholder Feedback: Establish a feedback mechanism allowing investigators and other stakeholders to provide input on the IB’s content and layout. This feedback can be instrumental in improving the clarity and utility of the document.
  • Continuous Improvement: Use stakeholder feedback and audit outcomes to continually refine the update and revision processes. This ensures that the procedures remain effective and responsive to the needs of the clinical investigation and regulatory landscape.

This section ensures that the MDR IB remains a living document, reflective of the latest scientific knowledge and regulatory standards. By meticulously managing updates and ensuring comprehensive communication and training regarding these changes, sponsors can maintain the document’s relevance and utility throughout the clinical investigation process.

In summary, the MDR Investigator´s Brochure must be actively managed to remain a current and compliant resource throughout the study. The processes outlined in this section provide a framework for achieving this, ensuring that the MDR IB continuously supports the safe and performance evaluation of the investigational device.

Conclusion: The Role of the MDR Investigator´s Brochure for Medical Devices

The MDR Investigator´s Brochure is a cornerstone document in the clinical investigation of medical devices. Its purpose extends beyond mere regulatory compliance; it is an essential tool for ensuring that all parties involved in the clinical investigation—from investigators and ethics committees to regulatory bodies—are well-informed about the investigational device. This comprehensive knowledge base supports informed decision-making, which is crucial for safeguarding participant safety and ensuring the validity and reliability of clinical investigation data.

Emphasis on Dynamic Documentation

The IB is not a static document but a dynamic one that evolves as the clinical investigation progresses. Regular updates and meticulous documentation are crucial to reflect new knowledge and experiences gained from ongoing research and development. This adaptability is vital not only for compliance with regulatory requirements but also for maintaining the trust and confidence of all stakeholders involved in the clinical process.

Integration of Multidisciplinary Insights

Constructing a solid MDR IB requires the integration of a wide range of data, from detailed device descriptions and pre-clinical findings to comprehensive risk management strategies and regulatory compliance details. It necessitates a collaborative effort among multiple disciplines, including engineering, clinical science, regulatory affairs, and quality assurance. This multidisciplinary approach ensures that the IB is thorough, scientifically sound, and reflective of the latest advancements in medical technology and clinical practice.

Commitment to Transparency and Education

The MDR Investigator´s Brochure serves as a critical educational tool, providing investigators and medical personnel with the necessary information to conduct the clinical investigation safely. It promotes transparency by detailing the device’s development history, its operational mechanics, and the scientific rationale behind its intended use. This transparency is crucial for building and maintaining the trust of clinical investigation participants and the general public.

Future Considerations

As medical device regulations and standards continue to evolve, the processes and content of the IB must adapt to meet these changes. Future considerations include enhancing the accessibility of the IB through digital formats and interactive tools that make complex information more understandable and actionable. Furthermore, as global regulatory landscapes shift, the IB will need to address these changes proactively to facilitate international clinical studies and device approvals.

In conclusion, the MDR IB is more than just a regulatory requirement; it is a key component of clinical research that plays a pivotal role in advancing medical technology. By ensuring that the Investigator´s Brochure is comprehensive, current, and compliant, sponsors can facilitate a smoother investigational process and contribute significantly to the enhancement of healthcare outcomes through safe and performaning medical devices.

This article has provided a structured approach to crafting an Investigator´s Brochure for medical devices that meets regulatory expectations and supports the ethical and scientific objectives of clinical investigations. By adhering to these guidelines, sponsors can ensure that their clinical investigations are conducted with the highest standards of safety, performance, and data integrity.

Written by:
David Tomé

David Tomé

President

Clinical research leader and MedTech entrepreneur with deep expertise in medical devices, IVDs & precision medicine, with global study experience.
Industry Insights & Regulatory Updates

Medical Device CRO: How to Qualify Your Clinical Partner

Introduction

In the highly regulated and competitive world of medical device development, the choice of a Clinical Research Organization (CRO) is more than a business decision—it’s a strategic partnership crucial to success. A qualified Medical Device CRO brings invaluable expertise in clinical investigations, regulatory navigation, and market entry strategies, acting as a linchpin for the development and approval processes. As the medical device industry grapples with stringent regulations, such as the EU MDR 2017/745, and evolving technological advancements, the stakes for choosing the right Medical Device CRO have never been higher. This article delves into how medical device companies can qualify their CRO partners, ensuring they align with their benchmark of excellence and are fully equipped to navigate the complexities of bringing innovative medical solutions to market.

Qualifying Your Medical Device CRO Partner: A Strategic Evaluation Framework

Choosing the right Clinical Research Organization (CRO) is pivotal for medical device manufacturers seeking to navigate the intricacies of clinical investigations, regulatory compliance, and market success. The process of qualifying a Medical Device CRO goes beyond simple service comparisons; it requires a strategic evaluation framework that ensures the selected partner is not only capable but also highly aligned with the company’s specific needs and goals. This framework should consider a variety of critical factors, including expertise in clinical operations, regulatory acumen, quality assurance capabilities, and a proven track record of success in the medical device field. By adopting a holistic and rigorous approach to evaluating potential CRO partners, companies can foster successful collaborations that are essential for achieving their project milestones and long-term objectives.

Criteria for Excellence: What to Look for in a Medical Device CRO

When selecting a Medical Device Clinical Research Organization (CRO) for medical device development, it’s essential to employ a strategic evaluation framework that encompasses various critical criteria. This rigorous approach ensures that the CRO is not only competent but also perfectly aligned with the specific needs and goals of your project. Here are the key criteria to consider:

1. Expertise in Clinical Operations

Look for a Medical Device CRO with a proven track record in managing and executing clinical investigations specific to medical devices. This includes experience with ISO 14155 and adherence to Good Clinical Practice (GCP), indicating their capability to handle the nuances of medical device clinical investigations.

2. Regulatory Strategy and Compliance

The ideal Medical Device CRO should demonstrate in-depth knowledge of global regulatory requirements, including the EU MDR 2017/745, and FDA regulations. Their expertise should cover strategic planning, submission processes, and the ability to navigate regulatory pathways efficiently.

3. Quality Assurance and Management Systems

Quality assurance is critical in medical device development. The CRO should have robust Quality Management Systems (QMS) in place, compliant with ISO 13485 and capable of ensuring the highest standards are met throughout the project lifecycle.

4. Medical Writing and Documentation

Exceptional medical writing capabilities are essential for clear, compliant, and persuasive documentation. This includes clinical evaluation reports, regulatory submissions, and technical documentation necessary for approval processes.

5. Data Management and Biostatistics

Competence in data management and statistical analysis is vital for interpreting clinical investigation data accurately. The Medical Device CRO should offer sophisticated methods for data collection, management, and analysis, supporting regulatory submissions and market claims.

6. Project Management

Effective project management ensures that clinical investigations are completed on time, within budget, and to the required quality standards. Look for a CRO with a strong project management framework, emphasizing communication, transparency, and stakeholder engagement.

7. Adaptability and Customized Solutions

Each medical device project is unique, requiring tailored approaches. A qualified Medical Device CRO should demonstrate flexibility and the ability to provide customized solutions that align with the specific challenges and goals of your project.

8. Reputation and Track Record

Finally, consider the CRO’s reputation within the industry and its track record of success. Testimonials, case studies, and references from past clients can provide valuable insights into their capabilities and reliability.

By meticulously evaluating potential CRO partners against these criteria, medical device companies can ensure they select a partner that will contribute significantly to the success of their projects.

The right CRO is a crucial ally in the complex journey from concept to market, providing expertise, support, and guidance every step of the way

The Benefits of Partnering with an Excellent Medical Device CRO

Choosing a Clinical Research Organization (CRO) that aligns with the strategic evaluation framework and exemplifies the criteria for excellence, such as MDx, brings manifold benefits to medical device companies. These advantages not only streamline the pathway from development to market but also ensure compliance, enhance quality, and optimize outcomes. Here are the key benefits of such a partnership:

Enhanced Efficiency and Time-to-Market

A CRO that excels in project management, clinical operations, and regulatory strategy can significantly expedite the development process. By effectively navigating clinical investigations and regulatory approvals, an excellent CRO reduces time-to-market, enabling quicker patient access and competitive advantage.

Rigorous Regulatory Compliance and Approval Success

Expertise in global regulatory landscapes is crucial for navigating the complex approval processes. A top-tier CRO ensures that all aspects of the development process, from clinical evaluations to technical documentation, meet the stringent standards set by regulatory bodies. This comprehensive understanding of regulatory requirements minimizes the risk of delays and rejections, facilitating smoother market entry.

Quality Assurance Across the Development Lifecycle

Quality assurance is embedded in the DNA of an excellent Medical Device CRO. Through robust Quality Management Systems (QMS) and adherence to international standards such as ISO 13485, a CRO ensures that every stage of development meets the highest quality standards. This commitment to quality not only supports regulatory compliance but also enhances the safety, efficacy, and reliability of the medical device.

Data Integrity and Scientific Rigor

The management and analysis of clinical investigation data are critical for substantiating claims and supporting regulatory submissions. Partnering with a CRO skilled in data management and biostatistics ensures the integrity and scientific rigor of investigation data, bolstering the case for approval and market acceptance.

Tailored Solutions and Flexibility

Each medical device project comes with its unique challenges and requirements. An excellent Medical Device CRO offers the adaptability and customized solutions necessary to address specific project needs effectively. This flexibility ensures that innovative approaches are applied to overcome obstacles and achieve project goals.

Access to Expertise and Global Networks

A CRO with a wealth of expertise and a global network can provide invaluable resources and insights throughout the development process. From subject matter experts to connections with regulatory bodies and clinical sites, this access facilitates smoother project execution and opens doors to opportunities and collaborations.

Conclusion

In the competitive and highly regulated world of medical device development, partnering with the right Medical Device CRO is not just a choice—it is a strategic imperative. By adhering to a strategic evaluation framework and selecting a CRO that embodies the criteria for excellence, medical device companies can navigate the complexities of development, regulatory approval, and market entry with confidence and efficiency.

MDx serves as a prime example of what to look for in a clinical research partner. With its comprehensive services, unparalleled expertise, and commitment to quality and success, MDx stands ready to support medical device companies in bringing their innovations to market.

For those in the medical device industry seeking a partner that meets these high standards, we invite you to learn more about how MDx can contribute to the success of your projects. Reach out for a consultation or more information on our full-service offerings and take the first step towards realizing your development and market aspirations.

Written by:
David Tomé

David Tomé

President

Clinical research leader and MedTech entrepreneur with deep expertise in medical devices, IVDs & precision medicine, with global study experience.
Industry Insights & Regulatory Updates

Understanding MDCG 2021-6 Rev. 1: A Comprehensive Guide for Clinical Investigations under EU MDR

The Medical Device Regulation (MDR) 2017/745 has transformed the EU’s regulatory landscape for medical devices. It aims to boost patient safety and transparency. The regulation sets strict criteria for clinical investigations. In this context, MDCG 2021-6 Rev. 1 is key. Issued by the Medical Device Coordination Group (MDCG), it underwent a revision in December 2023.

This update offers valuable insights. It addresses common questions about clinical investigations under MDR. The impact is wide-reaching. Manufacturers, sponsors, competent authorities, research centers, ethics committees, legal representatives, and CROs are all affected. This guide explores MDCG 2021-6 Rev. 1’s vital aspects. Moreover, it highlights its implications for these stakeholders.

Introduction to MDCG 2021-6 Rev. 1

MDCG 2021-6 Rev.1 is a cornerstone document for those embarking on clinical investigations of devices within the scope of the Medical Device Regulation (EU) 2017/745 (MDR). Designed for sponsors, this evolving guide may expand with more questions and answers over time. It clarifies the use of the term ‘device’ in line with MDR. This includes medical devices, their accessories, and specific products listed in Annex XVI.

The guide also standardizes the definition of “clinical investigation.” It aligns with Article 2(45) of the MDR, focusing on investigations aimed at assessing a device’s safety or performance. Moreover, it introduces the broader concept of “clinical study.” This encompasses a range of research activities within medical science. It includes clinical trials of medicines, device investigations, and in vitro diagnostic studies. These elements are vital for understanding the full scope of clinical research.

This document touches on key topics crucial for navigating the regulatory landscape:

  • Proof of Concept Studies: Offering insights into the initial stages of device development.
  • Article 82 Clinical Studies: Clarifying the scope of broader research activities under MDR.
  • Pilot Stage Investigations: Defining early feasibility and its regulatory implications.
  • Regulatory Pathways: Shedding light on navigating clinical investigations amidst the interplay of MDR, the Clinical Trial Regulation (CTR), and local laws.
  • Combined Trials: Addressing the complexities of studies involving both medicinal products and medical devices.
  • Invasive or Burdensome Considerations: Guiding sponsors on ethical and participant safety considerations.
  • Usability Testing: Outlining when such tests are considered clinical investigations.
  • Retrospective Testing: Distinguishing between prospective data collection and the analysis of existing data.
  • Submissions and Modifications: Offering guidance on navigating regulatory submissions and changes during the clinical investigation process.
  • Legal Representation: Emphasizing the role of legal representatives in ensuring compliance.

Some of the Key Highlights of MDCG 2021-6 Rev. 1

MDCG 2021-6 Rev. 1 offers an in-depth exploration into the clinical investigations aspects under the Medical Device Regulation (EU) 2017/745 (MDR). This document is instrumental in bridging the regulatory gaps and ensuring a harmonized approach across the European Union. Here are the refined key highlights based on the updated request:

Regulatory Pathways and Documentation

The document elaborates on navigating the regulatory landscape for conducting clinical investigations. It includes guidance on choosing the correct regulatory pathway, be it for a novel device entering early-stage clinical investigation or for further assessment of a CE-marked device. Detailed documentation requirements facilitate sponsors in preparing comprehensive applications, streamlining the approval process.

Legal Representative’s Role and Responsibilities

The document provides clarity on the responsibilities of the sponsor’s legal representative, which is pivotal for non-EU manufacturers. It underlines the need for a legal representative within the EU to ensure compliance with MDR requirements. This representative acts as a point of contact between the non-EU sponsor and the EU regulatory authorities, facilitating the submission and communication processes.

Substantial Modifications

Understanding what constitutes a substantial modification is crucial for the continuity and compliance of clinical investigations. MDCG 2021-6 Rev. 1 details the criteria for identifying substantial modifications that could impact the safety, health, or rights of subjects, or the reliability and robustness of the clinical data.

This guidance aids sponsors in navigating the process for notifying competent authorities about such modifications, ensuring that the integrity and validity of the investigation are maintained.

Relationship with the CTR, Combined Trials, and Combination Products

The document delves into the interplay between medical device regulations and the Clinical Trials Regulation (CTR), particularly in the context of combined trials and combination products. It highlights the importance of navigating both regulatory frameworks when a study involves medical devices and medicinal products. This includes guidance on conducting clinical studies that collect data for both devices and associated medicinal products, ensuring compliance with the MDR and CTR. The document’s insights into handling combination products—where devices and medicinal substances are integrated—are crucial for sponsors planning such studies.

Clarifications on Specific Aspects of Clinical Investigations

MDCG 2021-6 Rev. 1 sheds light on several nuanced areas of clinical investigations:

  • Usability Testing: It clarifies when usability tests are considered clinical investigations.
  • Invasiveness Considerations: The document defines what constitutes invasive procedures and the implications for clinical investigations, emphasizing the importance of assessing the invasiveness level when planning studies.
  • Retrospective Studies: Insights are provided on the role of retrospective studies within clinical investigations, delineating when such studies fall under the scope of clinical investigation definitions and how they contribute to clinical evaluations.
  • Proof of Concept Studies: Guidance on conducting proof of concept studies is highlighted, including their significance in the early stages of device development and their regulatory considerations under the MDR.

In-Depth Highlights of MDCG 2021-6 Rev. 1 for Specialized Clinical Investigations

Proof of Concept Studies according MDCG 2021-6 Rev. 1

Proof of Concept (PoC) studies are instrumental in the nascent phases of medical device development. These studies aim to demonstrate the feasibility and potential clinical benefits of a device, laying the groundwork for subsequent development stages. MDCG 2021-6 Rev. 1 provides comprehensive guidance on PoC studies, emphasizing their critical role in validating device concepts and navigating the regulatory framework of the MDR.

PoC studies serve as a foundational element in device development, enabling sponsors to assess a device’s early clinical viability and address potential design modifications before advancing to more comprehensive clinical trials. The guidance from MDCG 2021-6 Rev. 1 ensures that these studies are conducted within a framework that prioritizes patient safety, scientific validity, and regulatory compliance.

By focusing on detailed planning, ethical conduct, and adherence to specified regulatory pathways, PoC studies under the guidance of MDCG 2021-6 Rev. 1 facilitate a smoother transition through the early stages of device development.

MDCG 2021-6 Rev. 1 delineates the regulatory pathways essential for conducting PoC studies that support the conformity assessment of the device under investigation. It specifies the need for a meticulously detailed Clinical Investigation Plan (CIP), ensuring that PoC studies are grounded in solid scientific rationale and ethical considerations. This guidance is particularly highlighted in:

  • Question 7, which discusses the regulatory pathways for clinical investigations aimed at supporting device conformity assessments.
  • Question 11, focusing on the investigational use of CE-marked devices for new potential applications or further PoC studies.
  • Question 8, which identifies clinical investigations considered at the pilot stage, setting the stage for PoC studies.
  • Question 9, providing a roadmap for conducting early feasibility and first-in-human studies under the MDR, underscoring the importance of thorough risk assessment and ethical considerations.

Combined Trials

Combined Trials represent a pivotal area of focus within the regulatory landscape of clinical investigations, particularly when these involve both medical devices and medicinal products.

The MDCG 2021-6 Rev. 1 and MDCG 2022-10 documents offer a comprehensive overview of the complexities and regulatory pathways for conducting such trials, highlighting the necessity for compliance with the Medical Device Regulation (EU 2017/745, MDR) and the Clinical Trials Regulation (EU 536/2014, CTR), as well as with the In Vitro Diagnostic Regulation (EU 2017/746, IVDR).

  • Questions 15 and 16 in MDCG 2021-6 Rev. 1 and the detailed guidance in MDCG 2022-10 illuminate the pathway for combined trials involving medical devices and medicinal products. This guidance is crucial for sponsors planning studies that bridge the gap between medical devices and pharmaceuticals, offering clear directives on navigating combined trials.
  • The concept of “combined trial” is further elaborated to include simultaneous investigation of a medicinal product (clinical trial authorized under the CTR) and an IVD (clinical performance study), subject to the requirements of both the CTR and IVDR.
  • Sponsors are encouraged to thoroughly understand and comply with both MDR/IVDR and CTR requirements, ensuring that all aspects of the combined trials are adequately addressed.

Usability Studies

Usability studies are paramount in ensuring that medical devices meet the highest standards of safety and performance through effective user interface design. The MDCG 2021-6 Rev. 1 document, alongside the EN 62366-1:2015 standard, provides comprehensive guidance on when and how usability studies are considered within the scope of clinical investigations under the MDR.

It emphasizes the crucial role of usability studies in integrating user feedback into the device design and development processes. This aligns with the focus of EN 62366-1:2015 on user interface characteristics that foster both safety and user satisfaction, highlighting the importance of these studies in enhancing device usability and overall patient care.

Usability testing evaluates how well users can interact with a device within specified environments, aiming to enhance the user interface to promote performance, safe, and satisfying use.

  • Question 17 of MDCG 2021-6 Rev. 1 clarifies when usability studies are regarded as clinical investigations under the MDR. The classification hinges on the study’s scope, purpose, and the extent to which users are exposed to the device.
  • Usability testing that exposes users to device-related risks or where poor usability could impact patient or user safety is more likely to fall under the definition of a clinical investigation. Manufacturers must document their rationale for classifying a usability test as outside the scope of a clinical investigation when human subjects are involved.
  • Manufacturers should strategically design usability tests to limit human exposure to risks before investigating device performance and safety in clinical investigations.
  • Documentation of usability considerations, as part of the technical documentation, is critical. This includes justifying why certain usability tests do not constitute clinical investigations, ensuring compliance with both MDCG 2021-6 Rev. 1 guidance and EN 62366-1:2015 requirements.

Invasive or Burdensome Considerations in MDCG 2021-6 Rev. 1

  • Question 13 is particularly relevant for ensuring the ethical conduct and safety of participants in clinical investigations. It delves into what is considered burdensome or invasive, guiding sponsors in designing studies that minimize discomfort or risk to participants. This question is vital for maintaining ethical standards and participant welfare in both medical device and in vitro diagnostic studies under IVDR.

Impact on Medical Device Stakeholders

The MDCG 2021-6 Rev. 1 document significantly influences the medical device sector. It offers pivotal guidance that extends well beyond the regulatory framework to affect various stakeholders involved in the lifecycle of a medical device within the European Union.

Manufacturers and Sponsors

Manufacturers and sponsors find in MDCG 2021-6 Rev. 1 an essential roadmap. This guidance provides clarity on regulatory requirements, helping to streamline clinical investigations, mitigate risks, and shorten the time-to-market for innovative solutions.

  • Strategic Planning and Execution: The document outlines regulatory pathways for different types of clinical investigations, facilitating better planning and execution.
  • Risk Management: Emphasizes the importance of safety reporting and ethical considerations, aiding in the development of comprehensive risk management strategies.

Competent Authorities and Ethics Committees

Competent authorities and ethics committees are crucial in the regulatory oversight of medical devices. MDCG 2021-6 Rev. 1 enhances their ability to assess and ensure compliance with the MDR, promoting a unified application across the EU.

  • Streamlined Review Processes: Provides clear guidelines that support more efficient review and approval processes, contributing to quicker decision-making.
  • Enhanced Transparency and Consistency: Promotes transparency and consistency in the review of clinical investigations, bolstering the collaborative effort across Member States.

Research Centers and CROs

Research centers and Contract Research Organizations (CROs) play a vital role in conducting clinical investigations. The document offers them detailed guidance on designing and implementing studies that align with regulatory expectations and scientific rigor.

  • Design and Conduct of Studies: Facilitates the incorporation of ethical considerations and safety reporting in study designs, ensuring the generation of reliable and meaningful data.
  • Collaboration Enhancement: Aids in fostering collaborations between industry and research entities, ensuring that studies are conducted efficiently and effectively.

Legal Representatives

Legal representatives are instrumental in ensuring that the sponsor’s obligations under the MDR are met, particularly for non-EU sponsors. MDCG 2021-6 Rev. 1 clarifies their roles and responsibilities, ensuring compliance across the board.

  • Regulatory Compliance: Guides legal representatives in navigating the MDR requirements, ensuring sponsors fulfill their regulatory duties.

Patients and the General Public

The ultimate beneficiaries of the MDCG 2021-6 Rev. 1 are patients, who gain access to safer and more performance-oriented medical devices.

  • Access to Innovative Treatments: Enhances patient access to new and innovative medical devices, improving treatment options and patient care.
  • Enhanced Patient Safety: Prioritizes patient safety through rigorous clinical investigation standards.

Conclusion

The  MDCG 2021-6 Rev. 1 marks a significant stride in the EU’s approach to medical device regulation. This document is vital for navigating the complexities of the Medical Device Regulation (EU 2017/745, MDR). It offers a roadmap that impacts a wide range of stakeholders, from manufacturers to regulators and researchers.

  • Guidance and Collaboration MDCG 2021-6 Rev. 1 details the path for clinical investigations under MDR. It covers regulatory pathways, changes in trials, and usability considerations. This guidance is crucial. It ensures that devices entering the market are both innovative and safe. The document encourages collaboration across the sector, highlighting the shared goal of enhancing patient care.
  • Impact Across the Board Manufacturers, competent authorities, ethics committees, and others find value in this guidance. It clarifies MDR compliance, aiding in the efficient development and evaluation of medical devices. The emphasis is on using feedback, ensuring ethical conduct, and strategic planning. This collaborative effort advances medical device safety and innovation.
  • Benefiting Patients and the Public Ultimately, patients and the public stand to gain the most. They benefit from safer, more performance-oriented medical devices. The document fosters an environment where patient care is at the forefront. Innovations in device technology directly enhance patient outcomes and treatment options.
  • Moving Forward As the regulatory landscape evolves, staying informed and adaptable is key. Stakeholders must use MDCG 2021-6 Rev. 1 insights to meet the MDR’s demands. This commitment to high standards in device development and evaluation will continue to benefit European healthcare.
Written by:
David Tomé

David Tomé

President

Clinical research leader and MedTech entrepreneur with deep expertise in medical devices, IVDs & precision medicine, with global study experience.
Industry Insights & Regulatory Updates

Why Choose an ISO 14155-Compliant MedTech CRO under MDR?

In the challenging field of medical device development, particularly under the EU Medical Device Regulation (MDR), selecting the right Contract Research Organization (CRO) is pivotal. A crucial aspect often overlooked is the CRO’s adherence to ISO 14155, the international standard for good clinical practice in clinical trials, which becomes even more significant in light of the MDR’s stringent requirements.

Selecting an ISO 14155-compliant MedTech CRO under EU MDR ensures enhanced data reliability and patient safety. This compliance is key to successful clinical trials, aligning with MDR standards for quality and regulatory adherence, aiding manufacturers in the competitive MedTech field.

Why ISO 14155 Matters in the Context of MDR

ISO 14155, established by the International Organization for Standardization, provides a comprehensive framework for conducting clinical investigations with high ethical and scientific standards, aligning closely with the principles of the MDR. Adherence to ISO 14155 helps compliance with MDR, especially for clinical investigations, by emphasizing the protection of subjects, ensuring data integrity, and maintaining the quality and validity of research findings.

Benefits of Choosing an ISO 14155 CRO for MDR Clinical Investigations

  • Enhanced Quality and Reliability of Clinical Data: Adhering to ISO 14155 ensures that CROs implement quality control measures and data management practices that align with MDR requirements, leading to more reliable and trustworthy research findings.
  • Reduced Regulatory Risks and Delays: A CRO with ISO 14155 certification is well-equipped to navigate the MDR landscape, minimizing the risk of non-compliance, which is critical for timely and successful clinical investigations.
  • Improved Patient Safety: In line with MDR’s focus on patient safety, ISO 14155-compliant CROs prioritize participant well-being, implementing robust risk management and ethical guidelines.
  • Global Recognition in the MDR Era: ISO 14155 certification holds significant weight under the MDR, enhancing a CRO’s reputation for commitment to quality and compliance.
  • MDR-Specific Expertise and Experience: CROs compliant with ISO 14155 bring valuable insights and experience in conducting clinical trials that meet both ISO and MDR standards, offering expert guidance throughout the development process.

Conclusion

In the medical device sector, especially under the EU Medical Device Regulation, partnering with a CRO that is compliant with ISO 14155 is a strategic decision for success. MDx, as a CRO adept in both ISO 14155 and MDR requirements, offers a comprehensive approach to ensure patient safety, data integrity, and regulatory compliance. This makes MDx an excellent choice for manufacturers aiming to meet the high standards of the MDR and succeed in the competitive medical device market.

Why Choose MDx as Your Medical Device CRO Partner for ISO 14155 Compliance

MDx stands out as a preferred partner for manufacturers and sponsors in the MDR-regulated environment. Our compliance with ISO 14155 ensures that we are not only aligned with international standards but also adept at navigating the specific requirements of the MDR for clinical investigations. Our team offers:

  • MDR and ISO 14155 Expertise: Ensuring that your clinical trials meet all regulatory requirements for safety and efficacy.
  • Commitment to Quality and Integrity: Prioritizing the quality of clinical data, which is essential under the MDR.
  • Efficient and Cost-Effective Solutions: Streamlining the development process to comply with MDR, reducing delays and costs.
  • Global Recognition and Network: Enhancing the credibility of your product in the global market, a key aspect in the MDR era.
Written by:
David Tomé

David Tomé

President

Clinical research leader and MedTech entrepreneur with deep expertise in medical devices, IVDs & precision medicine, with global study experience.
Industry Insights & Regulatory Updates

Importing Investigational Devices for Clinical Investigation in Europe | EU MDR Guide

Importing investigational devices into Europe under the EU MDR is a complex process that requires strict compliance with regulatory provisions before a clinical investigation can begin. The Medical Device Regulation (MDR) establishes rigorous rules for the entry of investigational devices into the European Union, detailing specific obligations for manufacturers and sponsors. Partnering with a specialized Medical Device Contract Research Organization (CRO) ensures a seamless pathway to compliance and successful device importation.

Essential MDR Provisions for Investigational Device Importation

The MDR delineates vital requirements for the importation of investigational devices:

  • Designation of an EU Legal Representative: Non-EU entities must appoint a representative within the EU to ensure adherence to MDR regulations. (See MDR Article 62)
  • Conformity with Labeling Standards: Labels on investigational devices must comply with MDR stipulations, encompassing usage instructions, risk information, and device safety and performance details. Compliance with specific language and symbol requirements is essential. (See MDR Annex I Chapter III)
  • Demonstration of compliance with the applicable GSPR: This encompasses, when applicable, conducting technical and biological safety assessments, along with pre-clinical evaluations. It also involves implementing measures in occupational safety and accident prevention, all while considering the current state of the art. (See MDR Article 62.4.l)
  • Adverse Event Surveillance: Manufacturers and sponsors are obligated to implement a system for tracking and reporting adverse events associated with the investigational device over its entire usage period, adhering to defined adverse event criteria and reporting timelines. (See MDR Article 80)
  • Compliance with MDR Article 21: Importation must adhere to MDR Article 21, ensuring the free movement of investigational devices within the EU for clinical investigation.

Role of a Medical Device CRO in Investigational Device Importation

A Medical Device CRO offers comprehensive support:

  • Regulatory Guidance: CROs provide deep insights into MDR complexities and keep abreast of regulatory updates.
  • Labeling Assistance: They ensure investigational device labeling is in full compliance with MDR.
  • Adverse Event Reporting System Establishment: CROs facilitate setting up compliant adverse event reporting systems.
  • EU Regulatory Communication: CROs act as liaisons with EU regulatory bodies, managing necessary communications on behalf of manufacturers.
  • Documentation and Submission Management: From preparing technical documents to managing submissions and responses to EU authorities, CROs play a pivotal role.

Benefits of Collaborating with a Medical Device CRO

Partnering with a CRO offers numerous advantages:

  • Simplified Regulatory Compliance: CROs handle regulatory complexities, freeing manufacturers to concentrate on development.
  • Reduced Compliance Risks: Expert advice from CROs minimizes the risks of non-compliance.
  • Efficient Market Entry: CROs expedite the process of bringing investigational devices to the EU market.
  • Cost Efficiency: By streamlining the importation process, CROs help in curtailing unnecessary costs.
  • Expertise Access: CROs offer specialized knowledge in medical device regulation and market entry strategies.

Conclusion

Navigating the MDR for the importation of investigational devices for clinical investigation demands diligent regulatory adherence and strategic planning. Engaging an experienced Medical Device CRO is key to ensuring a compliant and efficient pathway for bringing innovative investigational devices to the EU market.

MDx CRO: Your Strategic Partner for Investigational Device Importation

MDx CRO, a leader in Medical Device CRO services, excels in assisting sponsors and manufacturers through the MDR’s complexities. Our team, proficient in the nuances of the MDR, provides end-to-end support, ensuring your investigational devices are compliantly and effectively introduced into the European market.

With MDx CRO, you gain a partner committed to a compliant, streamlined, and successful introduction of your investigational devices in the EU. Contact us to discover how our expertise can enhance your clinical investigation endeavors.

*MDx offers assistance with the importation of investigational devices. MDx’s range of services does not include acting as an economic operator importer as defined under Article 13 of the EU MDR.

Written by:
David Tomé

David Tomé

President

Clinical research leader and MedTech entrepreneur with deep expertise in medical devices, IVDs & precision medicine, with global study experience.
Industry Insights & Regulatory Updates