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Responsibilities for IVD Manufacturers

An IVD manufacturer’s challenges are unique because in vitro devices do not generally come into contact with patients or users and incidents caused by in vitro device involvement can be difficult to prove. However, the MEDDEV-5 guidelines help to preclude any non-disposition to report by stating explicitly that there should “be a predisposition to report.”In addition to reporting possible IVD incidents, IVD manufacturers also have the responsibility to review user instructions and labels.

Responsibilities for Notified Bodies

Notified bodies act as assessors of conformance and are thus an essential part of compliance and finalized assessment results. According to the MEDDEV-5, “Notified Bodies do not play a key operational role in the Medical Device Vigilance System” but the “overall performance of the Medical Device Vigilance System is supported by the notified body activity in the following areas like Assessment of vigilance procedures ,Audit of the implementation of the vigilance procedures, and link with other systems e.g. Corrective and Preventive Action (CAPA), FSCA , Assessment of the impact of vigilance issues on the certification granted and Liaise with the National Competent Authority if required, e.g. specific investigations/audits based on a request of the National Competent Authority.”

Users’ Responsibilities

Since the users of medical devices are often the first to observe incidents related to device error or the first to observe inappropriate usage methods, users are absolutely indelible to the healthy ebb and flow of the European Medical Device Vigilance System. For this reason, the MEDDEV-5 has specified the following responsibilities for users:

  • Report medical device related incidents to the appropriate manufacturer, or

  • Report medical device related incidents to the appropriate NCA (National Competent Authority);

  • Participate in the appropriate procedures that are specified by corrective action assignments.

The Responsibilities of National Competent Authorities

The responsibilities of National Competent Authorities written within the MEDDEV-5 extend past administration and into the realms and roles of liaison work and expert communication. These responsibilities include the following:

  • Send report receipts to manufacturers;

  • Evaluate (with the help of the manufacturer if possible and/or practicable) reports;

  • Provide advice when necessary;

  • Provide intervention when necessary;

  • Monitor the investigations of incidents;

  • Supplement, if necessary, an incident investigation;

  • Help prevent additional similar incidents by providing preventative information;

  • Help educate the purchasers of medical devices in regards to the MEDDEV-5 guidelines;

  • Help educate users of medical devices in regards to the MEDDEV-5 guidelines;

  • Encourage incident reporting.

Regardless of whether or not a company plans on entering the European medical device industry or is already a participant, the recent MEDDEV-5 guidelines are valuable information for best-practice success.

( http://www.mastercontrol.com/newsletter/medical_device/
european_medical_device_vigilance_system_guidelines_0308.html ).

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