Specimen collection device
Specimen receptacles are class A under the IVDR, self-declared, but sterile ones bring a notified body in for the sterility aspects; the collection swab may be a medical device instead.
Regimes engaged, per market
Standing when pasted with its name: mapped
What the file has to hold
- Technical file (5 of the 5 regimes, including IVDR, ISO 13485, UK MDR)
The technical documentation: design, drawings, bill of materials, the standards applied, the conformity assessment route, and the evidence that the requirements are met. Kept for the retention period the regime sets, typically ten years from the last unit placed on the market. - Declaration of conformity (IVDR, UK MDR, UKCA)
The EU or UK declaration of conformity (or the food-contact declaration of compliance), signed by the manufacturer, naming the product, the legislation and the standards, and the notified or approved body where one was involved. - Risk assessment (IVDR, ISO 13485, UK MDR, FDA IVD)
The documented hazard identification and risk assessment for the product across its lifecycle, updated when the design, the use or the field data changes. - Test reports (IVDR, UK MDR, FDA IVD)
Test reports from an accredited or accepted laboratory against the standards the technical file names, tied to the exact model and revision tested. - Labelling and instructions (IVDR, UK MDR, UKCA, FDA IVD)
Markings on the product and packaging (conformity mark, identification, warnings, manufacturer and importer details) and the instructions and safety information in the language of the market. - Traceability records (IVDR, ISO 13485, UK MDR, FDA IVD)
Batch, lot or serial identification on the product, the records that tie a unit to its production and supply chain, and UDI where the device rules require it. - Third-party certificate (IVDR, ISO 13485, UK MDR, FDA IVD)
A type-examination certificate, notified or approved body certificate, or listing from a recognised laboratory, with the scope and the expiry. - Post-market surveillance plan (IVDR, ISO 13485, UK MDR, FDA IVD)
The plan and the periodic reports for collecting and acting on field experience, complaints and incidents, in the form the device rules set. - Registrations (IVDR, UK MDR, FDA IVD)
Producer, establishment, device or product registrations in the databases the regime names (EUDAMED, EPREL, CPNP, the WEEE and battery registers, FDA registration and listing).
Duties that continue after sale
- Market surveillance cooperation (IVDR, UK MDR, FDA IVD)
Answer an authority's request for the technical file, the declaration and the supply chain within the time it sets, in a language it accepts, and cooperate with any corrective measure it requires.
Licensed controls: IVDR Art.92, 93, 94, 95 - Incident reporting (IVDR, ISO 13485, UK MDR, FDA IVD)
Notify the authority when a product has caused, or could cause, an accident, injury or serious incident, through the channel the regime names (the Safety Business Gateway, the MHRA, the FDA, SaferProducts.gov) and within its clock.
Licensed controls: IVDR Art.82, 83, 84, 85, 86 · ISO 13485 8.2.3 - Recall readiness (IVDR, ISO 13485, UK MDR, FDA IVD)
Be able to identify affected units, reach the customers who hold them, issue a notice in the required form, offer the remedy the rules require, and show the authority the effectiveness of the action.
Licensed controls: IVDR Art.82, 83, 84, 85, 86 · ISO 13485 8.3.3 · ISO 13485 8.5.2 - Traceability records (IVDR, ISO 13485, UK MDR, FDA IVD)
Keep the records that identify which batch went to which customer, and the identification on the product that lets a unit be traced back, for the retention period the regime sets.
Licensed controls: IVDR Art.22, 23, 24, 25 · ISO 13485 7.5.8 · ISO 13485 7.5.9.1 - Post-market surveillance and periodic reporting (IVDR, ISO 13485, UK MDR, FDA IVD)
Run the surveillance plan, analyse complaints, trends and field data, and produce the periodic safety update report the device rules require.
Licensed controls: IVDR Art.78 · IVDR Art.80, 81 · ISO 13485 8.2.1 · ISO 13485 8.2.2 · ISO 13485 8.4
This week
Check whether the swab is registered as an IVD accessory or a medical device, because the two regulations split here.
What holding one is evidence for
Requirement text and evidence artefacts from a human-verified corpus. Data licensed to Conformity Sheet by The Art of Service Pty Ltd, revocable, non-transferable.
IVDR: EU In Vitro Diagnostic Medical Devices Regulation (IVDR)
IVDR Art.10 General obligations of manufacturers (Article 10)Article 10 imposes the central manufacturer obligations: (1) demonstrate compliance with general safety and performance requirements (Annex I); (2) establish + document + implement + maintain a Quality Management System (QMS, Article 10(8)); (3) carry out clinical/performance evaluation (Article 56) + post-market perfo...
Common gap: Manufacturer without an ISO 13485 / equivalent QMS
EU In Vitro Diagnostic Medical Devices Regulation (IVDR) on compliance.theartofservice.com
IVDR Art.47 Classification of devices (Article 47 and Annex VIII)Article 47 + Annex VIII set the risk-based classification system for IVDs into Class A (low risk; e.g. specimen receptacles, buffers), Class B (moderate risk; e.g. pregnancy tests, cholesterol), Class C (high individual + moderate public-health risk; e.g. companion diagnostics, blood gas), Class D (high individual + hi...
Common gap: Class C / D device classified as B or below
EU In Vitro Diagnostic Medical Devices Regulation (IVDR) on compliance.theartofservice.com
IVDR Art.48, 49, 50 Conformity assessment procedures + NB involvement + Class D scrutiny (Articles 48-50)Article 48 sets the conformity-assessment routes by class. Class A devices (other than self-tests/sterile/measuring): manufacturer self-declaration (Annex II + III technical documentation; no NB). Class A sterile, Class B, Class C, Class D: NB involvement required, with specific Annex IX (full QMS + tech doc assessment...
Common gap: Class B/C/D device self-declared without NB involvement
EU In Vitro Diagnostic Medical Devices Regulation (IVDR) on compliance.theartofservice.com
IVDR Art.17, 18 EU declaration of conformity and CE marking (Articles 17-18)Article 17 requires the manufacturer to draw up the EU declaration of conformity (DoC) before placing the IVD on the market or putting it into service. The DoC contains the Article 17(1) information set out in Annex IV. By drawing up the DoC the manufacturer assumes responsibility for compliance. The DoC is kept availa...
Common gap: IVD placed without EU DoC
EU In Vitro Diagnostic Medical Devices Regulation (IVDR) on compliance.theartofservice.com
IVDR Art.15 Person Responsible for Regulatory Compliance (Article 15)Article 15 requires manufacturers to have permanently available within their organisation at least one Person Responsible for Regulatory Compliance (PRRC) with the requisite expertise in the field of in vitro diagnostic medical devices. The PRRC has the formal responsibility to ensure: (a) the conformity of devices bef...
Common gap: Manufacturer without a documented PRRC
EU In Vitro Diagnostic Medical Devices Regulation (IVDR) on compliance.theartofservice.com
ISO 13485: ISO 13485:2016 medical device quality management systems
ISO 13485 4.1 General requirementsThe organization documents a quality management system and maintains its effectiveness in line with the standard and applicable regulatory requirements, documenting the regulatory role or roles it undertakes (for example manufacturer, authorized representative, importer, distributor). It determines the processes the sy...
Common gap: Regulatory role never stated, so applicable requirements are inferred rather than identified
ISO 13485:2016 on compliance.theartofservice.com
ISO 13485 4.2.3 Medical device fileFor each medical device type or family the organization establishes and maintains one or more files that contain or reference the documents generated to demonstrate conformity to the standard and compliance with applicable regulatory requirements. The file content includes at least a general description of the device, ...
Common gap: No file exists per device family; documents are scattered across engineering and production systems with no index
ISO 13485:2016 on compliance.theartofservice.com
ISO 13485 7.3.1 GeneralThe organization documents procedures for design and development. The procedures carry the requirements of 7.3.2 to 7.3.10: how design is planned, how inputs are set and approved, what outputs contain and how they are approved, how reviews, verification, validation and transfer are conducted and recorded, how changes a...
Common gap: Design work done to a project management method with no quality management system procedure
ISO 13485:2016 on compliance.theartofservice.com
ISO 13485 8.2.2 Complaint handlingThe organization documents procedures for timely complaint handling in accordance with applicable regulatory requirements, covering at least the requirements and responsibilities for receiving and recording information, evaluating whether feedback constitutes a complaint, investigating complaints, determining the need ...
Common gap: Feedback evaluated for complaint status by sales or service staff with no defined criteria
ISO 13485:2016 on compliance.theartofservice.com
ISO 13485 8.2.3 Reporting to regulatory authoritiesWhere applicable regulatory requirements require notification of complaints that meet specified reporting criteria for adverse events, or issuance of advisory notices, the organization documents procedures for notifying the appropriate regulatory authorities and maintains records of that reporting.
Common gap: Reporting criteria and timelines for every market the device is sold in not identified
ISO 13485:2016 on compliance.theartofservice.com
Do this for every product you sell
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