Procedure: New Market Authorization Class II
Country: Global Procedure
Version #: 01/08/2024
Author: Daria Kostiuchenko
Editor: Daria Kostiuchenko
ID: GP-MD-VII-SR
Category: Medical Devices
Validity: For five years
Certified by: Vlad Reznikov
Copyright: Pattern of USA Inc.
SUMMARY
Class II medical devices are fall under the moderate risks category. Manufacturers must follow a set of regulatory requirements to bring a class II medical device to market. In the USA they must submit a premarket notification, or 510(k), to the FDA demonstrating that the device is substantially equivalent to a device that is already on the market. However, if the FDA determines that a device is not substantially equivalent or if it raises concerns about the device’s safety or effectiveness, it may require additional clinical testing or other data before it can be cleared for sale. In addition to the premarket review process, class II medical devices are also subject to Post-Market Surveillance (PMS). This means that manufacturers must continue to monitor their devices and maintain records after they are on the market and report any adverse events or problems to the FDA. In Europe, there are Class lla and Class IIb-type medical devices classified as low-moderate risk and high-moderate risk devices. Under the MDR, manufacturers of class II medical devices must obtain a CE mark to sell their products in the EU. Manufacturers must complete a conformity assessment procedure to obtain a CE mark and submit a technical file to a Notified Body (NB) to review the technical file and determine whether the device meets the relevant requirements. Market authorization (MA) requirements vary by country, and compliance with local regulations is crucial. It typically involves demonstrating that the device meets safety and performance standards set by the respective health authorities.
Must-Have Requirements, Recognized Standards, and Certifications:
- Device description, including variants
- Technical documentation (MDR/IVDR)
- Instructions for use (IFU)
- Quality Management System (QMS/QSR)
- Good Manufacturing Practice (GMP)
- Declaration of Conformity (DoC)
- Risk Management
- Clinical Evidence
- POA
- Substantially equivalent to the predicate device
- MAs in other countries
- CE mark and ISO 13485 in many countries
Nice-to-have:
- IEC 60601
- ISO 14971
- ISO 10993
- Labeling
- Regulatory Compliance and Gap Analysis see GP-PhR-GAP-SR card
- Regulatory Intelligence and Strategic Consulting see GP-PhR-RI-SR card
- Q-Sub Activities see GP-MD-QSA-SR card
Typical Gaps and Deficiencies: Understanding of the regulatory pathway and requirements applicable to the device. Incorrect predicate device selection. Inadequate documentation. Rush in submitting the application without being prepared
Implementation Period: Immediately upon approval
Deliverables: Market Authorization (Clearance or Registration), NRA Listing and Establishment registration
PHASE | TASK | TASK | START | DURATION | Fee | KPI | ||
NUMBER | TITLE | OWNER | W/M/Q/Y | in weeks | 3rd Party | Service | State | |
0 | In-house Pre-Submission Activity | |||||||
0.1 | NDA signing or validation | Executor | week 1 | 1 | ||||
0.2 | Contract Closing | MAH | week 1 | 1 | ||||
0.3 | SOW is approved by MAH | MAH | week 1 | 1 | SOW | |||
0.4 | POA issuance and shipping | MAH | week 2 | 1 | ||||
0.5 | Invoice is sent to MAH and paid | MAH | week 3 | 1 | POP | |||
I | Prep and Submission | |||||||
I.1 | Predicate device equivalence, admin. & info set review | Executor | week 4 | 1 | ||||
I.2 | Classify the device (exemption review) | Executor | week 5 | 1 | ||||
I.3 | Technical Documentation review vs. NRA requirements | Executor | week 6 | 2 | ||||
I.4 | Application and supplement documents development | Executor | week 8 | 2 | ||||
I.5 | Approval of the Application | MAH | week 10 | 1 | ||||
I.6 | NRA payment | MAH | week 10 | 1 | ||||
I.7 | Submission of the Application | Executor | week 11 | 1 | Submission | |||
II | Studies | |||||||
II.1 | Сonducting technical, toxicology, electrical, and software tests, as well clinical and suitability studies, if required | Executor | week 12 | 4 | Reports | |||
III | Review and Evaluation | |||||||
III.1 | NRA Application review | NRA | week 16 | 2 | ||||
III.2 | NRA Technical file review | NRA | week 18 | 2 | ||||
III.3 | NRA Lab tests and clinical evaluation review | NRA | week 20 | 2 | ||||
III.4 | NRA Addressing clarifications or queries if so | NRA | week 22 | 1 | ||||
III.5 | Answering with relevant documents from MAH | Executor | week 23 | 1 | ||||
III.6 | Facility Inspection if required | NRA | week 24 | 4 | ||||
III.7 | NRA Official Response | NRA | week 28 | 1 | ||||
III.8 | NRA Approval (GoTo Ph. IV) or Query (Rpt. Ph. III.5) | NRA | week 29 | 1 | Approval | |||
IV | Approval | |||||||
IV.1 | NRA/NB Conclusion draft verification | Executor | week 30 | 1 | ||||
IV.2 | NRA Conclusion publication | NRA | week 31 | 1 | ||||
IV.3 | State Listing update | Executor | week 32 | 1 | ||||
IV.4 | Reporting to MAH | Executor | week 33 | 1 | Report | |||
F | Final Phase In-house Post-Authorization Activity | |||||||
F.1 | Service Acceptance Certificate signing | MAH | week 34 | 1 | ||||
F.2 | Final Invoice | Executor | week 34 | 1 | ||||
F.3 | Final Payment | MAH | week 35 | 1 | ||||
F.4 | Contract Termination | Executor | week 35 | 1 | ||||
F.5 | Archiving and limiting access | Executor | week 36 | 1 | Archiving |
Feel free to submit a Request for Proposal (RFP) for a specific country or territory to info@patternofusa.com