Module 18 2021

Borderlines with PPE

A single product could be either a Device or a PPE product. The determining factor will be the intended purpose for the product.

To protect the user = PPE To protect the patient = Medical Device e.g.: Face masks (surgical / non-surgical) Mouth guards (dental / sport)

It is possible for some to be both (e.g. examination gloves): provisions introduced by the revised PPE directive allow for this. 35

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What is a biocidal product?

- any substance or mixture, in the form in which it is supplied to the user, consisting of, containing or generating one or more active substances, with the intention of destroying, deterring, rendering harmless, preventing the action of, or otherwise exerting a controlling effect on, any harmful organism by any means other than mere physical or mechanical action, - any substance or mixture, generated from substances or mixtures which do not themselves fall under the first indent, to be used with the intention of destroying, deterring, rendering harmless, preventing the action of, or otherwise exerting a controlling effect on, any harmful organism by any means other than mere physical or mechanical action. A treated article that has a primary biocidal function shall be considered a biocidal product. - Regulation (EU) No 528/2012

In short , a biocide has an antimicrobial effect which is not purely physical or mechanical.

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