Essentials of European Medical Device Regulatory Affairs - June 2020
Vigilance Periodic Summary Reporting (article 87) • Alternative to individual reports • Similar serious events on the same device /device type – Root cause identified or – FSCA implemented – Common and well documented • CAs agree with format, content and frequency Trend Reporting (article 88) • Incidents that are not serious incidents or Expected undesirable side effects – Significant impact on benefit – risk and – Have led or may lead to risks to health and safety which are unacceptable when compared to the benefits • Methodology is included in the PMS Plan • CAs can require measures
TheOrganisation for Professionals in Regulatory Affairs
Vigilance Electronic Reporting
Where does the information go? Automatic transfer of report Report CA Serious incident
MS where the incident occurred NB MS(s) where the incident(s) occurred NB MS(s) where the FSCA takes place MS of the manufacturer/AR NB MS (s) in coordination procedure MS of the manufacturer/AR NB
Trend reports
FSCA
Periodic Summary Reports
TheOrganisation for Professionals in Regulatory Affairs
Vigilance After the initial report…. Investigations by the manufacturer – Risk assessment – FSCA – Cooperation with CAs and NB Upload Full report with conclusions and corrective actions Send FSN to users – Devices (UDI) and Manufacturer (SRN)
– Reasons for the FSCA – Risks and level of risk – All actions to be taken by users – Translations(s)
Upload FSN
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