Medical Device Guidelines and Regulations Handbook

Prakash Srinivasan Timiri Shanmugam
Pugazhenthan Thangaraju
Nandakumar Palani
Thamizharasan Sampath Editors
Medical Device
Guidelines and
Regulations
Handbook
Medical Device Guidelines and Regulations
Handbook
Prakash Srinivasan Timiri Shanmugam
Pugazhenthan Thangaraju
Nandakumar Palani • Thamizharasan Sampath
Editors
Medical Device Guidelines

and Regulations Handbook
Editors
Prakash Srinivasan Timiri Shanmugam Pugazhenthan Thangaraju
Global Product Safety & Toxicology Department of Pharmacology
Avanos Medical, Inc. All India Institute of Medical
Alpharetta, GA, USA Sciences (AIIMS)
Raipur, Chhattisgarh, India
Nandakumar Palani
R&D Engineer, Medical Devices Thamizharasan Sampath
Milpitas, USA Department of Pharmacology
Maitri College of Dentistry
M.Sc., Electronics & Research Centre
Chennai, India Anjora, Durg, Chhattisgarh, India
ISBN 978-3-030-91854-5 ISBN 978-3-030-91855-2 (eBook)

https://doi.org/10.1007/978-3-030-91855-2
© The Editor(s) (if applicable) and The Author(s), under exclusive license to Springer Nature
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Contents

ISO 14155: Clinical Investigation of Medical Devices
for Human Subjects �� 1
Karnika Singh

ISO 13485: Medical Devices – Quality Management Systems,
Requirements for Regulatory Purposes �� 19
B. Karthika and A. R. Vijayakumar

ISO 14971 and ISO 24971: Medical Device Risk Management�� 31
Thamizharasan Sampath, Sandhiya Thamizharasan,
K. Vijay Kumar Shetty, and Prakash Srinivasan Timiri Shanmugam

ISO 19227: Implants for Surgery – Cleanliness
of Orthopedic Implants �� 57
Nandakumar Palani

ISO 21534: Non-active Surgical Implants – Joint
Replacement Implants �� 75
and Prakash Srinivasan Timiri Shanmugam

ISO 16061: Instrumentation for Use in Association
with Non-active Surgical Implants—General Requirements�� 83
Karnika Singh

ISO 22442: Medical Devices Utilizing Animal Tissues
and Their Derivatives�� 91
Thamizharasan Sampath, Sandhiya Thamizharasan, Krithaksha V.,

ISO 11137: An Overview on Radiation for Sterilization
of Medical Devices and Healthcare Products�� 121
Balu Venugopal, Sunitha Chandran, and Amita Ajit
v
vi Contents

ISO 11135: Sterilization of Health-Care Products—Ethylene
Oxide, Requirements for Development, Validation and Routine
Control of a Sterilization Process for Medical Devices�� 145
Indumathy Jagadeeswaran and Sunitha Chandran
An Overview on Sterilization of Health
Care Products using Moist Heat: ISO
17665�� 155
Renjith P. Nair and Sunitha Chandran

ISO 10993: Biological Evaluation of Medical Devices�� 163
Pugazhenthan Thangaraju and Shoban Babu Varthya

FDA-CFR Title 21-Food and Drugs: Parts 800 to 1299�� 189
Indumathy Jagadeeswaran, Nandhini Palani, and Ganesh Lakshmanan
1907/2006 – Registration, Evaluation, Authorisation
EU
and Restriction of Chemicals�� 237
Indumathy Jagadeeswaran and Harini Sriram
1272/2008 – Classification, Labelling and Packaging
EU
of Substances and Mixtures�� 261
2015/863: Restriction of Hazardous Substances (RoHS) -3�� 297
EU
Harini Sriram and Indumathy Jagadeeswaran
722/2012 – Animal Tissue Regulations in Effect for
EU
Some Medical Devices�� 309
2017/746 – In Vitro Diagnostic Medical Devices�� 321
EU

Device Regulations of Other Countries�� 347
Karnika Singh
Index�� 377
ISO 14155: Clinical Investigation
of Medical Devices for Human Subjects
Karnika Singh
1 Introduction
The international standard ISO 14155 was formulated by Technical Committee

ISO/TC 194, Biological evaluation of medical devices, to define good clinical prac-
tice during clinical investigation of medical devices in human subjects. This includes
the design, conduct, recording, and reporting of clinical investigations as well as the
safety or performance of medical devices for regulatory purposes. It consists of two
parts, ISO 14155-1, which specifies procedures for the “conduct and performance,”
and ISO 14155-2 that contains prerequisites for the “preparation of Clinical
Investigation Plans (CIPs)” for the clinical investigation of medical devices. First
version of ISO 14155 was released in 2003 (ISO 14155:2003); since then it has been
modified several times, and the latest version came out in 2011 and is the standing
version till date known as the ISO 14155:2011. It should be noted that ISO 14155 is
not applicable to in vitro diagnostic medical devices. In this chapter, we will be
discussing both parts of this ISO.
2 Structure of ISO 14155:2011
The ISO 14155:2011 is divided into several sections, namely:

1. Scope
2. Normative references (ISO 14971:2007)
3. Terms and definitions
4. Ethical considerations
K. Singh (*)
The Ohio State University Comprehensive Cancer Center, Columbus, OH, USA
© The Author(s), under exclusive license to Springer Nature Switzerland AG 2022 1

P. S. Timiri Shanmugam et al. (eds.), Medical Device Guidelines and Regulations
Handbook, https://doi.org/10.1007/978-3-030-91855-2_1
2 K. Singh
5. Clinical investigation planning

6. Clinical investigation conduct
7. Suspension, termination, and closeout of the clinical investigation
8. Responsibilities of the sponsor
9. Responsibilities of the principal investigator
The original document also has several annexes associated with clinical investiga-
tion plan (CIP), investigator’s brochure (IB), case report form (CRF), clinical inves-
tigation report, essential clinical investigation documents, and adverse event
categorization.
In this chapter each part of ISO 14155:2011 will be discussed in the light of
above sections.
3 ISO 14155-1
3.1 Scope
As mentioned above, this part of ISO 14155 defines the “general requirements for
biological tests” aimed at protecting human subjects, assuring that clinical investi-
gation is carried out with optimal scientific conduct and helps the sponsors, moni-
tors, investigators, ethics committees, and regulatory authorities and bodies involved
in the conformity assessment of medical devices to oversee the compliance of the
standard. It specifies the requirements to plan a clinical investigation with regards to
the concerned medical device’s performance in terms of mimicking clinical use,
adverse events that might occur during normal conditions of usage, evaluation of
acceptable risks associated with the assigned performance of the medical device
and organization, conduct, monitoring, data collection, and documentation of the
clinical investigation of a medical device. All these requirements are applicable to
clinical investigations pertaining to human subjects.
3.2 Terms and Definitions
Adverse device effect: As the name suggests, it means any unexpected response to a
medical device. This could be any event as a consequence of defects or faults in
the “instructions for use” and/or arrangement of the device or simply user error.
Adverse event: This refers to the development of any unfortunate medical condition
in a subject. However it should be kept in mind that there may not be a direct
association between the adverse event and the medical device.
Case report form: Form designed to catalog all the information notified to the spon-
sor about each human subject as needed by the clinical investigation plan.
ISO 14155: Clinical Investigation of Medical Devices for Human Subjects 3
Clinical investigation: A study intended for analyzing the safety and performance of
a particular device in humans.
Clinical investigation plan: Often referred to as protocol, this document describes
all the information regarding the “rationale, objectives, design and proposed
analysis, methodology, monitoring, conduct, and record keeping of the clinical
investigation.”
Clinical investigator: Person or institution that is conducting the clinical investiga-
tion and would be liable for the good health of the human subjects that are part
of the clinical study.
Clinical investigator’s brochure: A collection of clinical and nonclinical informa-
tion about the device under investigation relevant to the human subjects of
the study.
Clinical performance: Performance or action of a medical device when used with
correct intent on suitable human subjects.
Coordinating clinical investigator: It is the person (usually appointed by the spon-
sor) who coordinates the work of a multicenter investigation.
Ethics committee: An independent panel created for ensuring the safety, well-being,
and human rights of the subjects participating in the clinical study.
Final report: Document containing the details, results, and interpretation of the con-
ducted clinical investigation.
Informed consent: A legal document confirming a subject’s voluntary participation
in a clinical study after he/she has been informed about all aspects of the clinical
investigation pertaining to their decision to participate.
Investigation center/investigation site: Site or institution of clinical investigation.
Medical device: A contraption along with the software required for its operation
used for various diagnostic purposes like prevention, monitoring, treatment, or
alleviation of disease; rectification of an injury or handicap; alteration of anat-
omy or physiology of a biological process; conception control; etc. Such a device
is not supposed to function in the human body by any pharmacological, immu-
nological, or metabolic ways. However, any such outside assistance can be taken
to improve its function.
Monitor: Person recruited by the sponsor for assessing the compliance of investiga-
tor with the clinical investigator plan, performance of source data verification,
and regular progress reporting to the sponsor.
Multicenter investigation: A clinical investigation that occurs at two or more sites
according to original clinical investigation plan.
Principal clinical investigator: A clinical investigator responsible for arranging
clinical investigation at a single site.
Serious adverse device effect: An adverse device effect resulting in a serious adverse
event or any series of events in which intervention was not possible due to vari-
ous reasons.
Serious adverse event: An adverse event leading to death or severe decline of health
of the human subject. This includes any life-threatening illness or injury, lasting
impairment of a body part, hospitalization, surgery, etc. Congenital anomalies
and fetal morbidity also fall under this category.
4 K. Singh
Source data: Original information in the records collected during the clinical inves-
tigation comprising clinical findings, observations, etc. that may be used to
reconstruct or evaluate the initial clinical investigation.
Source documents: Original data, documents, and records, for example, laboratory
notes, hospital records, pharmacy records, photographs, radiographs, etc.
Sponsor: Also known as promoter, it is the person responsible for proper institution
and/or implementation of a clinical investigation. The clinical investigator can
also carry out this role.
Subject: Human being who participates in a clinical investigation either as a receiver
of the test device or as a control.
3.3 Ethical Considerations
Declaration of Helsinki (DoH)
It was created by the World Medical Association (WMA) in 1964 as a policy state-
ment for ensuring the ethical treatment of human subjects in clinical investigation.
Since then this document has been amended seven times and the latest accepted
version was formulated in 2013. However it should be noted that this is not a legal
document, even though it is referred to at every step of a clinical investigation. The
DoH highlights the fundamentals like basic respect of the individual, their right to
informed decisions, their welfare, that the clinical investigation should be carried
out after detailed scientific investigation, and, above all, ethical considerations.
Improper Influence or Inducement
The participants of the study (subjects, officials, and other parties) should not to be
improperly influenced or induced by any means during the clinical investigation.
Compensation and Additional Health Care
This includes all the provisions decided for the compensation of subjects due to any
injury while participating in the clinical investigation. This also comprises addi-
tional healthcare provisions that would be employed during an adverse device
effect. All these occurrences if happen shall be documented.
Responsibilities
It is the responsibility of the participating parties to ensure that clinical investigation

is conducted ethically, especially as far as their role is concerned.
3.4 General Requirements
Formal Agreement
This is a written and signed agreement between the sponsor, the clinical
investigator(s), and other involved parties that describe their responsibilities.
Qualifications
This entails to the required educational qualification and experience of the person-
nel involved in the clinical investigation.
Clinical Investigation Plan
This is discussed more in part 2.
Design of the Clinical Investigation
The design of clinical investigation should center around testing the suitability of
the device for the intended medical purpose such that the results obtained shall be
authentic, supportive, and relevant to the investigation’s objective.
Confidentiality
This requires the safekeeping of patient data such as their name and identifying
information. For this, the case reports form should not use such information; the
patient data should be secured under unauthorized access and should be limited to
only reports and scientific publications.
Start of Clinical Investigation
The following things should be kept in mind before starting a clinical

investigation:
1. A written and signed clinical investigation plan
2. Approval of the ethics committee
3. Regulatory clearance
6 K. Singh
Informed Consent
It is mandatory to obtain and document the informed consent in writing from every
subject who decides to enroll in the clinical study. It is structured in two parts: study
information and signature area. They can be together in one document or two sepa-
rate documents.
ISO 14155-1 details the “process of obtaining informed consent.” It should not
involve any pressurizing or influencing of subjects to participate. Subject’s legal
rights should not be waived. Nontechnical language should be used in the consent
form such that the subject or his/her legal representative easily understands it. The
subject should be given ample time to consider their participation in the study. The
informed consent should be signed and dated by the subject or his/her legal repre-
sentative and the clinical investigator. It should be outlined how the informed con-
sent would be obtained for cases when the subject is unable to give it. Some
circumstances could be when the subject is a fetus, child, juvenile, seriously ill,
unconscious, or mentally incapable to do so. In such conditions, a legal guardian or
representative is authorized to give informed consent. All this has to be documented
in the clinical investigation plan.
Informed consent is a really important part of a clinical investigation; therefore
the subject needs to be properly informed of certain things before obtaining their
informed consent. First, is the description and purpose of the study detailing the
involvement of research, investigation’s objective, duration of the study, how the
subject would be involved in the study, specifics about the medical device that is
being investigated, and explanation of the procedure with an emphasis on the exper-
imental part. Second, is the mentioning of any foreseeable risks that accompany the
investigation along with any side effects. The consent should also describe the
potential benefits, the subject or others might have if the study is a success (have a
positive outcome). It should also include the alternative therapies that are available
to the current medical condition/device. The consent should clearly state that the
subject’s participation would be kept confidential; his/her medical details would
only be accessible to the regulatory authorities or sponsor’s delegates; and the
results of the study may be published but the subject’s identity would not be revealed.
The consent should also state that the subject is liable to get compensation if he/she
is injured during the study and additional healthcare needs to be administered
because of an adverse device effect. The compensation can be financial and the
details of that should be outlined. The contact person needs to be clearly defined in
the consent to which the subject can ask questions about the study in general, inform
about an injury, etc. The conditions of termination of participation by the investiga-
tor should also be included in the consent. Finally, it should state that any new find-
ings related to the subject’s participation would be made available to them.
The signing of informed consent agreement means that the participating indi-
vidual or his/her legal representative would participate and comply with the clinical
investigation; they would inform their personal physician of their participation in
the study or their disagreement for this information release and that they would
allow the use of any personal data relevant to the study in the clinical investigation.
In the event of an early termination of the study, it is the sponsor’s responsibility to

promptly inform the clinical investigators and investigation centers of the termina-
tion along with the reason of termination. The ethics committee should also be
informed of the termination and its reason either by the sponsor or the investigator
or the investigation center. In some instances the subjects’ physicians may also have
to be informed.
Document and data control are critical aspects of a clinical investigation. It is
important to safeguard subject’s privacy as much as possible. A case report form
should be maintained for each patient which would record their data as required by
the clinical investigation plan. Similarly, all subjects enrolled currently or previ-
ously in the study shall be accounted for and documented. All the data obtained in
the study has to be kept confidential and only the clinical investigator would have
access to it. Monitor would only have access to source documents and other infor-
mation necessary to ensure investigator compliance with the study plan, rules, and
regulations and judge the progress of clinical investigation. The clinical investigator
should allow auditing of their clinical investigator procedures.
Documentation
Clinical investigator’s brochure and other documents like clinical investigation

plan, case report forms, etc. should be prepared before the start of clinical study. The
clinical investigator brochure should contain a summary of literature, clinical inves-
tigation design, and rationale for the planned use of the medical device. The descrip-
tion of the device should be included according to ISO 14155-2. The mechanism of
action of the device should be described along with the supporting scientific litera-
ture. The manufacturer’s instructions for use and installation and possible side
effects and contraindications should also be included if required. The expected
clinical performance of the device and materials used to manufacture the device
should be outlined. The experimental results pertaining to the device including bio-
logical, clinical, and preclinical studies should be reported. Any previous reports
regarding the device or any similar device should also be mentioned. A compiled list
of international standards and results of the risk analysis should also be included.
The clinical investigator brochure should be regularly updated with any piece of
significant information along the course of clinical investigation and shall be con-
veyed to the clinical investigators.
Other documents that should be prepared in advance, include the clinical inves-
tigation plan; the curriculum vitae that is current, signed, and dated; the institution(s)
where the clinical study would happen; written approval of the ethics committee
and related documents; all communication with authorities as needed by national
legislation; agreement between the principal investigator and the sponsor; insurance
certificates; informed consent forms and other materials provided to the subjects;
case report forms; reporting forms for adverse events and adverse device effects;
and contact information of the monitor.
8 K. Singh
Sponsor
It is the responsibility of the sponsor to design and communicate all the duties and
functions relating to the clinical study. They will ensure documentation showing
that, investigator, sponsor, and monitor comply with ISO 14155, the clinical inves-
tigation plan and subsequent amendments, and applicable regulatory requirements
through a transparent system. The responsibilities of a sponsor have been listed in
detail in the ISO 14155 document.
• Selection of investigator and the investigation center for the study and coordina-
tion of the clinical investigator if required.
• Selection and appointment of monitor for the study or acting as monitor them-
selves. The sponsor is supposed to perform this duty along with the monitor and
clearly outline the guidelines for taking care of noncompliances and missing data.
• Assemble and update the clinical investigation brochure.
• Supply the clinical investigator with clinical investigation plan, approved amend-
ments, and the clinical investigator’s brochure.
• Sign the approved clinical investigation plan.
• Provide the devices that are to be studied in the clinical investigation.
• Make sure that the clinical investigator has the appropriate information and/or
training in the use of device as per the clinical investigation plan.
• Assure that all the deviations from the original clinical investigation plan have
been reviewed with the respective clinical investigator(s) and recorded in the
case report form and the final report of the clinical investigation.
• Report and review the adverse events and adverse device effects with the clinical
investigator to the ethics committee, safety monitoring committee, and any other
relevant authorities.
• Report in writing to all clinical investigators involved in the study, the serious
adverse effects reported to them during the investigation. The report shall be sent
based on the perceived risk.
• Immediately inform the clinical investigator if the study has been prematurely
terminated or suspended along with the concerned regulatory authorities. Also
explain the reason of premature termination or suspension.
• Tell the clinical investigator(s) about the developmental status of the device, and
state the requirements essential to verify the performance of the device.
• Review and approve any departure from the original study plan, and perform any
relevant corrective or preventive actions.
• Collect, secure, store, and ensure completion by involved authorities of the listed
documents:
–– All the documents listed in the “documents” section
–– Case report forms, signed and dated
–– Records of any adverse events and adverse device effects reported to the spon-
sor during the clinical investigation
–– Final report of the clinical investigation
• Make sure that device is accountable and traceable.
Monitor
The monitor is responsible for the following:

• Verifying compliance with the clinical investigation plan is maintained and any
departure from the clinical investigation plan is reviewed and documented with
the clinical investigator and at the same time reported to the sponsor.
• Verifying that the device is being used in accordance with the clinical investiga-
tion plan and reporting to the sponsor if any modifications are needed for the
device or its methodology.
• Monitor that the clinical investigator(s) currently have the staff and facilities to
conduct the clinical study safely and effectively.
• Verify that the clinical investigators have continued access to adequate number
of subjects and clinical devices.
• Check that all consent forms obtained from the subjects at the time of enrollment
are signed and dated before any study-related procedures are started.
• See if the case report forms are complete and timed, and match the source of
the data.
• Ensure that adverse events and adverse device effects are recorded and reported
to the sponsor, followed according to respective procedure.
• Device accountability and traceability procedures are in place and are maintained.
• The equipment under study is calibrated regularly and documented at the
same time.
• There is documentation of subject withdrawal and noncompliance, regular dis-
cussion with clinical investigator, and report to the sponsor.
• Review the noncompliant findings or required modifications with the clinical
investigator, and write a monitoring report to the sponsor disclosing the above
information.
Clinical Investigator
The clinical investigator is an appropriately qualified clinician with a license to

practice medicine. He should have enough experience in the field and also training
for the device usage under investigation. He should be thorough with the back-
ground and requirements of the methods to be followed in the clinical study. The
clinical investigator should be well versed in the art of obtaining informed consent.
Like the sponsor and the monitor, the clinical investigator also has several
responsibilities to ensure the smooth day-to-day conduct of the clinical study and
safety of the human subjects involved in the study.
• The clinical investigator should have all the resources to properly conduct the
clinical study.
10 K. Singh
• He/she should also make sure that there is no conflict of interest because of
the study.
• The clinical investigator should regularly obtain important information from the
sponsor concerning the device under investigation.
• He/she should also completely go through the clinical investigation plan before
signing it.
• He/she should help the monitor and the auditor to rectify case report forms for
any inconsistencies or missing information. Also this would give the investigator
a chance to verify compliance of the two officials with the clinical investigation
plan and perform source data verification as well.
• They should discuss the possibilities of modification to the clinical investigation
plan with the sponsor and the monitor and obtain sponsor’s written approval.
• They are also responsible for making sure that the clinical investigation plan is
followed by all those involved in the study and that any departure from the plan
is documented and reported to the sponsor.
• The clinical investigator has to make the necessary arrangements for the proper
conduct and completion of the clinical study.
• They also have to make sure that necessary measures are in place for emergency
treatment to protect the subjects in the study.
• Obtaining appropriate ethics committee approval is also the responsibility of the
sponsor in order to start the clinical study at the respective center.
• Give the results from the ethics committee to the sponsor.
• Communicate to the ethics committee about any significant changes that have
been made to the study plan as approved by the sponsor along with the appropri-
ate reasons.
• Notify the ethics committee of any adverse side effects.
• Also notify the sponsor of all adverse events and adverse device effects as
they happen.
• Make sure that the subjects are recruited in an adequate manner.
• To establish that the recruited subjects were given adequate information to pro-
vide informed consent.
• Assure that informed consent is obtained and recorded.
• Ensure that clinical records clearly indicate that enrollment of subjects in respec-
tive study; if needed, the subjects shall be provided with a means to prove their
association with the study along with identification and other compliance docu-
ments. The subject’s physician may also be involved if required.
• Like the sponsor the clinical investigator also has to ensure that the subjects are
briefed with procedures to follow during an emergency situation. Under such
conditions the prior approval of sponsor shall not be required, and this would not
be considered a breach of agreement. However, these deviations would be docu-
mented and reported to the sponsor.
• Any information that is made public as a part of the clinical investigation about
the subjects and is required for clinical study’s continuation shall be conveyed to
the sponsor and if appropriate to the subject’s physician as well.
• The clinical investigator is also responsible for informing the subjects and their
physician about any premature termination or suspension of the clinical study
along with the reason of termination.
• The clinical investigator is responsible for accuracy, legibility, and security of all
data collected during the study, documents, and patient records at the investiga-
tion site both during and after clinical investigation. The clinical investigator
should sign the case report forms. Data shall be altered, initiated, and dated only
by the authorized personnel, and original data has to be retained for comparison
purposes.
• Make sure that the basic data collected during the study are retained for the mini-
mum time specified in the plan.
• The clinical investigator shall also be responsible for the supervision and assign-
ment of duties to the responsible personnel at the clinical investigation center
involved.
• Account all the devices that are part of the investigation.
The quantity of the devices received for the study should be adjusted with the
number of devices used, discarded, or returned.
Final Report
A final report of the clinical study has to be completed even when the study is pre-
maturely terminated. It has to be in a written format and signed by the sponsor and
the coordinating investigator, principal clinical investigator(s) from each center.
This document would be made available upon request to all clinical investigators
and the ethics committee. The final report should comprise a detailed identification
of the device(s), description of the methodology and design of the study, any depar-
tures from the study plan, data analysis with the statistics, and a critical assessment
of the aims of the study. The final report will include data from all the centers and
enrolled subjects. The subjects shall not be identifiable from any part of the report
or the published data. All clinical investigators would review the report and com-
ment on it. The sponsor will keep the record that all clinical investigators have been
given the final report for review and comments. If any investigator disagrees with
any part of the final report, his/her comments shall be recorded and conveyed to
other investigators. If the coordinating investigator or other investigator is unable to
or refuses to sign the report, a justification shall be given for the not signing of the
final report.
12 K. Singh
4 ISO 14155-2
4.1 Scope
This part of ISO standard details the requirements for laying out the CIP for the
clinical investigation of medical devices. A CIP compiled in accordance with this
ISO helps in establishing the validity and reproducibility of the results of a clini-
cal study.
End point – primary: Principal indicator measured or set to evaluate the primary
objective of a clinical study
End point – secondary: Indicator measured or set in addition to the primary end
point to determine some other aim of the study
Point of enrollment: The time at which, after recruitment, the subject signs the
informed consent forms and officially becomes the part of the study population
Follow-up period: The period of the clinical study where the effects of the medical
device under investigation are observed in the enrolled subjects
Recruitment: The process of classifying subjects who may be appropriate for the
clinical study under consideration
4.3 Requirements
All requirements for this part of ISO are same as ISO 14155-1.
4.4 Clinical Investigation Plan (CIP)
The sponsor and the clinical investigator(s) would prepare this document such that
it would be used for optimizing the scientific validity and reproducibility of the
results. All this would be done in accordance with current clinical standards relevant
to completing the aims of the study. The CIP would have information in the orga-
nized clauses. The other documents like clinical investigator’s brochure, sponsors
standard operating procedures, etc. should be referenced in the CIP and provided on
request. The sponsor can decide that any of the following requirements is not appli-
cable in a particular situation; he/she would have to provide a clear statement
explaining the omission of information in each situation.
4.5 General Information
Identification of the Clinical Investigation Plan
The CIP and any of its amended versions would be identified by the title of the study
and its reference number. It will also include the version/issue number and the date
to trace it back to the signatories. Each page would contain the version number.
linical Investigators, Principal Clinical Investigator, Coordinating

C
Clinical Investigator, Investigation Center/Site(s)
The CIP would list the contact details (name, address, and professional position) of
the clinical investigator(s), principal investigator(s), and the coordinating clinical
investigator if applicable. Similarly, name and address would be provided for the
institutions at which the study would take place. The name and address of additional
centers or persons involved in the study in terms of patient management, testing, or
analysis would also be included.
Sponsor
The contact details of sponsor of the study would be included in the CIP whether
they are in state or a foreign country.
Monitoring Arrangements
The monitoring arrangements would be outlined in the CIP and the planned extent
of the source data verification.
Data and Quality Management
The CIP would define the protocol for database management, treatment of data,
source data verification, data archiving, retention period, and other quality control
processes.
An Overall Synopsis of the Clinical Investigation
The CIP would give a summary or outline of the clinical investigation. It can be
accompanied with graphics like flowcharts showing the key stages of the study or
other important information relevant to the study.
14 K. Singh
Approval and Agreement to the Clinical Investigation Plan
The sponsor, coordinating investigator, and the principal clinical investigator(s) in

each center shall comply with the CIP and its amendments and express their approval
and consensus by signing and dating an appropriate document.
4.6 I dentification and Description of the Medical Device

to Be Investigated
The CIP would include or reference to a brief description of the device under inves-
tigation and its designated purpose. The subsequent information shall be provided:
• The device manufacturer, its model, or type number along with software version
and accessories to allow full identification and traceability. If this information is
unknown at the time of CIP preparation, a method of traceability would be laid
down for before and after the study.
• The designated purpose of the device as declared by the manufacturer including
the contraindications and clinical implications in the study and the target
populations.
• Characterization of the device including any components that would come in
contact with tissues or body fluids. This would consist of the details of any
medicinal products, human and/or animal tissues or their derivatives, or other
biologically active substances.
• Instructions for installation and use of the device along with any necessary stor-
age and handling requirements, arrangement for use and reuse and any checking
before safety and performance, and any precautions required after use.
• A review of required training and experience needed for the use of device
under study.
• A statement of involved medical or surgical procedures in the use of the
said device.
4.7 Preliminary Investigations and Justification of the Study
Literature Review
The CIP shall contain relevant scientific literature and/or unpublished data and
reports along with a list of references that have been reviewed. The purpose of this
review is to justify the proposed study design. The review would pertain to the
intended purpose of device under investigation and prospective method of use.
Preclinical Testing
The review would recap the preclinical testing that has been done for the device
under investigation to support its use in human subjects, along with an analysis of
the results from such testing. This would include the results of the preclinical test-
ing, design calculations, in vitro tests, mechanical and electrical testing, reliability
checks, and software validation relating to the function of the device. Other results
from performance tests, ex vivo testing, biological testing and/or safety tests in ani-
mals, justification of tests done, and timeline of such results would also be included.
Previous Clinical Experience
The CIP would also include the results from the previous clinical investigations, if
any and clinical use that is pertinent to the current study. The CIP would also talk
about any previous data that is out there regarding device usage or similar devices
that are currently in use. All this comprises an evaluation of adverse device effects
and any past experiences of modification or recall.
Device Risk Analysis and Risk Assessment
The CIP shall provide results of a risk analysis and assessment. This would weigh
the balance between anticipated clinical benefit and the risks connected with the
device and its method of use as stated by the risk management. Probable interac-
tions with competent medical interventions shall be tabulated, along with a state-
ment of the expected clinical benefit. This would comprise an evaluation of adverse
device effects and any prior report of modification or recall in association with
safety and clinical performance of the device under study and similar devices.
Objectives of the Clinical Investigation
The CIP would clearly state the hypothesis and objectives, both primary and sec-
ondary, of the clinical study and populations on which the device would be tested.
These would specifically include:
• Predictions and suspected performance of the devices that are to be tested
• Risks and predictable adverse side effects that are to be evaluated
• Specific hypotheses to be tested by statistical data obtained from the study
16 K. Singh
Design of the Clinical Investigation
The scientific credibility of a clinical study lays on its design; therefore the CIP
shall supply the following information:
• Explanation of the type of investigation to be conducted (e.g., comparative
double-blind, parallel design, with or without a control group) with appropriate
rationale for the choice
• Review of the controls
• Methods employed to reduce bias
• Primary and secondary end points with reason for this choice
• The variables to be tested with relevant reason to achieve the end points
• The methods and timing for checking, documenting, and evaluating variables
• Assess the equipment to be used for analysis of study variables and the setup for
monitoring the sustenance and calibration
• Inclusion criteria for subject election
• Exclusion criteria for subject election
• Point of enrollment
• Detailed description of the protocol that the subjects would be subjected to dur-
ing the study along with a record of other devices or medication to be utilized
during the usage of the device under investigation or during the follow-up course
• Criteria and methods for withdrawal and discontinuation of subjects from the
study and their accountability, along with the follow-up procedures of these sub-
jects, if feasible
• Number of subjects needed for the study, time required to recruit this number,
total devices needed for the study, and explanation for all these numbers. For
multicenter studies, the minimum number of subjects to be involved from each
center has to be specified and justified. If there is a chance of the validity of the
study results to get affected, the number of subjects enrolled at each center would
be taken into consideration.
• Strategy for documenting and evaluating adverse events, adverse side effects,
and/or outcomes
• Time of use of the device or its control and its follow-up time in a specific subject
of the study along with the justification
• Any known or expected factors that may impact results or their interpretation, for
example, subject baseline characteristics, concomitant medication, use of other
devices or subject-related factors (age, gender or lifestyle), etc. The means (sub-
ject selection, study design-stratified randomization, statistical analysis) of
addressing these variables in the study have to be outlined.
Statistical Considerations
The CIP will contain a description and explanation of hypothesis and statistical
design, method, and the analytical procedures to be employed. This encompasses:
• Reasoning for the sample size, significance test to be used, power of the study,
and predicted dropout rates, along with the justification of all these choices
• Pass/fail criteria to be used on the results of the study
• Plan for an interim analysis, where required, and the criteria for the cessation of
the study on the statistical grounds
• Protocols for reporting any departure(s) from the original statistical plan. All this
would be recorded in the CIP or final report.
• Criteria for choosing the subjects to be included in the study with the explanation
• Protocols for accounting of data, handling of missing, unused, or false data,
drop-outs, and withdrawals along with the explanation of leaving out particular
information from hypothesis testing
Deviations from the Clinical Investigation Plan
All the deviations from the CIP would be recorded with a justification. These devia-
tions would be communicated to the sponsor, who will analyze and evaluate its
significance. The reasons for retraction and suspension of any subject from the
study would be documented. The ethics committee or other regulatory authorities
can be involved if needed. If the reasons involve safety and lack of effectiveness,
that subject would still be followed up in the study, if feasible.
Amendments to the Clinical Investigation Plan
Any modifications to CIP shall be done only after agreement between sponsor and
the clinical investigator(s). These modifications would be recorded with required
explanations. If the list of clinical investigators and centers is changed, the list will
not be formally updated, and only sponsor would maintain the updated list and
make it available on request. The final list of all centers and investigators shall be
included in the final report.
Adverse Events and Adverse Device Effects
The CIP would contain:

• Emergency contact information for reporting of serious adverse events and seri-
ous adverse device effects
• Specifics of predictable adverse events and adverse device effects (e.g., serious/
nonserious, device-related/non-device-related, their probable incidence, meth-
ods for their management)
• Detailed procedures for reporting all adverse events and adverse device effects to
the sponsor, ethics committee, and other regulatory authorities in agreement with
18 K. Singh
relevant regulations, specifications of those types of events, device-related and

non-device-related that would be documented along with its timing
Early Termination and Suspension of the Investigation
The CIP would lay down the criteria and provisions for early termination or suspen-
sion of the study. This can apply to the whole study or one or more centers. If the
study includes blinding techniques, the rules to access and break the code have to be
described. The CIP would define the subject follow-up requirements to be consid-
ered after an early termination or suspension of the study, wherever relevant.
Publication Policy
Although all the data collected in the study should be put up for publication, still the
CIP shall state whether the results from the study would be submitted for publica-
tion or not. It would also specify the extent and the conditions under which the
results obtained from the clinical study would be proposed for publication.
Case Report Forms (CRF)
In CRF, all the information is listed that needs to be recorded during a study. The
CRF shall mirror the contents of the CIP and clearly show its version number. Any
amendments to the CRF would also contain a version number, and each page would
be marked by the study number and identification of the subjects, whose data are
present in the CRF. If the necessity of amending the CRF arises, the sponsor shall
determine whether the amendment is necessary or not by reviewing the CIP.
References
1. ISO 14155:2011 Clinical investigation of medical devices for human subjects—Part 1: General
requirements
2. ISO 14155:2011 Clinical investigation of medical devices for human subjects—Part 2: Clinical
investigation plans
ISO 13485: Medical Devices – Quality
Management Systems, Requirements
for Regulatory Purposes
B. Karthika and A. R. Vijayakumar
Introduction
The International Organization for Standardization (ISO) develops standards for
use worldwide, and it is a national standards body for worldwide federation. The
effort of setting goals for international standards is carried out through ISO techni-
cal committees, and also international, governmental, and nongovernmental organi-
zations are in association with ISO to frame this. In electrotechnical standardization,
ISO collaborates with the International Electrotechnical Commission (IEC). ISO
13485 guides companies to do their share in protecting medical devices’ consumers
and users. ISO 13485 frames criteria for the best quality management system (QMS)
in international standard that specifies requirements for a QMS for organization
involved in all stages of the medical device, including design and development,
production, storage, distribution, installation, servicing, final decommissioning, dis-
posal of medical devices, and provision of associated activities (e.g., technical sup-
port). This international standard requirement can also be used by suppliers or other
external parties providing product (e.g., raw materials, components, subassemblies,
medical devices, sterilization services, calibration services, distribution services,
maintenance services) to conform with such organizations to maintain the standard.
International Standard Process Approach
This international standard process approach is for quality management. A process,
it could be of any activity that receives input and converts it to output. The output
from one process mostly directly forms the input to the next process. For an organi-
zation to function efficiently, it performs to identify and manage numerous linked
processes. The application for a system of processes in an organization is for the
identification and interactions of these processes with their management to produce
the desired outcome referred to as the “process approach.” The quality management
system of process approach emphasizes:
B. Karthika (*)
Department of Oral Medicine and Radiology, Priyadarshini Dental College and Hospital,
Pandur, Tamil Nadu, India
A. R. Vijayakumar
Department of Pharmacology, JIPMER, Karaikal, Puducherry, India

20 B. Karthika and A. R. Vijayakumar
• The understanding and meeting requirements

• The consideration of processes in terms of added value
• In obtaining results of process performance and effectiveness
• In improving processes based on objective measurement
Clarification of Concepts
ISO 13485 international standard is qualified by the phrase “as appropriate” for the
product to meet requirements; compliance with applicable regulatory requirements;
the organization to carry out corrective action; and the organization to manage risks.
When the term “risk” is used, the application of the term within the scope of this
international standard pertains to safety or performance requirements of the medical
device or meeting applicable regulatory requirements. When a need is required to be
“documented,” it is also essential to be established, implemented, and maintained.
When the term “product” is used, it also means “service.” Product is for the output
that is intended for, or required by, a customer, or any intended output resulting from
a product realization process. Regulatory requirements are to encompass require-
ments contained in any law applicable to the user of this international standard (e.g.,
statutes, regulations, ordinances, or directives), for the quality management system
and for the safety or performance of the medical device. In this international stan-
dard, the verbal forms and their indication are as follows: “shall” indicates a require-
ment; “should” indicates a recommendation; “may” indicates permission; “can”
indicates a possibility or a capability; information marked as “NOTE” is for guid-
ance in understanding or clarifying the associated requirement.
Quality Management System (QMS)
QMS criteria are superior business practices to set quality goals, to ensure regula-
tions and all requirements are understood and met, to train the employees, to control
the production processes, to purchase from the suppliers that can provide products
that meet requirements, and to correct the problems to make sure that they do not
happen again.
Once the QMS is established with all the criteria, a registrar is contracted to
conduct an audit, and the company will be ISO 13485 registered. ISO 13485-registered
companies can market and advertise their registration certificate. So the existing and
potential customers will know that you have a good QMS for your medical devices.
ISO 13485 international standard that describes QMS requirements for medical
devices contains five clauses that are numbered as 4, 5, 6, 7, and 8.
• Clause 4 for quality management system
• Clause 5 for management responsibility
• Clause 6 for resource management
• Clause 7 for product/service realization
• Clause 8 for measurement, analysis, and improvement (Fig. 1)
ISO 13485: Medical Devices – Quality Management Systems, Requirements… 21
6.0. Resource Management
Facilities controls
Plant equipment
Human resources
8.0. Measurement
7.0. Management Analysis and
Responsibility Improvement
5.0. Management
Design controls Responsibility CAPA
Material controls Customer
Incoming Management
complaint system
inspection review process
Quality system data
Production Quality plan
analysis
Control of Policies
In-process data
measuring analysis
equipment Audit data analysis
Customer
Orders
Contracts
Feedback
Specifications
Fig. 1 ISO 13485 model system. (Courtesy: David N. Muchemu. Designing a world-class quality
management system for FDA regulated industries: Quality system requirements (QSR) for
cGMP. Author House Publisher, Bloomington, Indiana; 2008: Page: 43)
ISO 13485 Standard

This standard can be used by an organization involved in all stages of the life cycle
of a medical device and by suppliers and other external parties providing product to
such organizations.
1. Scope of the Standard
• Is about the standard and how it applies to organizations.
• The requirements in this standard can be used by suppliers and other external
parties providing products.
• Exclusions of requirements in clause 6, 7, or 8 in the QMS depending on organi-
zations’ role.
1.1. International Standard Used by Suppliers or External Parties That Provide
Product Including QMS-Related Services to Such Organizations
1.2. The Requirement of Clause 6, 7, or 8 Can Be Not Applicable to the Organization
with Documented Justification
• “Risk” – pertains to safety and performance requirements, or meeting regulatory

requirements
• “Documented” – to be established, implemented, and maintained
• “Product” – now means the product or for service. The output that is intended for
a customer, or for an intended output of product realization
• “Regulatory requirements” – are the legal requirements for the quality manage-
ment system and for the safety or performance of the device
This international standard process is applicable to the organization, but not per-
formed by the organization; they are the responsibility of the organization and are
accounted for the organization’s quality management system by monitoring, main-
taining, and controlling the process.
2. Normative Reference of the Standard
References from another document used along with the standard; updated to ISO
9000:2015
3. Terms and Definitions of the Standard
It gives definitions that are related to medical devices:
• Removed: refers to supply chain explanation, active implantable medical device,
and active medical device
• Modified: refers to complaint, labeling, implantable or active, or sterile medi-
cal device
• Added: refers to authorized representative, clinical evaluation, distributor, and
importer, life cycle manufacturer, medical device family, performance evalua-
tion, post-market surveillance, product (from 9000:2005), purchased product,
risk, risk management, sterile barrier system, and sterile medical device
4. Quality Management System (Fig. 2)
4.1. The General Requirement

The entire clauses are reorganized:
• Document QMS and maintain its effectiveness.
• Document the role taken by the organization.
• Establishment based on risk approach to control the processes.
• Requirements validation of application of computer software.
4.2. Documentation Requirements
Re-organized paragraphs:
4.2.1. The Quality Manual
4.2.2. The Medical Device File (New Subclause)
4.2.3. To Have Control of Documents
4.2.4. To Have Control of Record – Confidential Health Information
4.2.5. Security of Documents/Records – Prevention of Loss
Fig. 2 Quality management system cycle
5. Responsibility of Management
5.1. Commitment of Management
• Ensure quality policy and quality objectives and conduct management review.
5.2. Customer Focus
• To make sure customer and regulatory requirements are met
5.3. Quality Policy
• To make sure commitment to comply with requirements, quality objectives
should be reviewed periodically to ensure appropriateness.
5.4. Planning
• Objectives of quality are measurable with quality policy and QMS plan.
5.5. Responsibility, Authority, and Communication
• Define responsibilities and authorities; identify management responsibility;
establish appropriate communication processes.
5.6. Management Review (Changes in Input and Outputs)
• Document procedures for management review; list inputs for review; record out-
put review.
6. Management Resource
6.1. Resource Provisions
• To determine and give resources to maintain QMS and to meet up applicable
regulatory and customer requirements
6.2. Human Resources (Changes in Skills and Training)
• Identify skills, provide training, evaluate effectiveness, and ensure awareness of
personnel.
6.3. Infrastructure (Changes in Requirements)
• Ensure infrastructure prevents product mix and orderly handling of product.
• Infrastructure includes building, workspace, process equipment, and supporting
service (transport, communication, or information services).
6.4. Work Environment and Contamination Control
6.4.1. Work Environment
• To document requirements for work environment to maintain health, cleanliness,
and clothing.
6.4.2. Contamination Control (New Subclause)
• The sterile medical device requirements to control contamination with microor-
ganisms or particulate matter
7. Product Realization
7.1. Product Realization Planning (Added to List)
• Document process for risk management.
• Ensure quality objectives and requirements for product.
• Provide resources, infrastructure, and work environment.
• Determine verification, validation, monitoring, measurement, inspection, test,
handling, storage, distribution, and traceability activities related to the product.
• Maintain records.
7.2. Processes Related to Customer
7.2.1. Determination of Product-Related Requirements
• Requirement defined by customer including delivery and post-delivery activities
• Regulatory requirement, user training, any other additional requirements
7.2.2. Review of Product Requirements
• Ensure capability to meet the defined requirement.
7.2.3. Communication
• Plan and document communication with customer on product info, enquiries,
contracts, handling orders, feedbacks, and advisory notices.
7.3. Design and Development (Fig. 3)
7.3.1. Design and Development Transfer (New Subclause)

• Transfer documented procedures of design and development outputs to
manufacturing.
7.3.2. Design Control and Development Changes
• To identify changes and to maintain records, to review, to verify, to validate, and
to approve before implementing
7.3.3. Design and Development of Files (New Subclause)
• Maintain design and development files for every medical device type or medical
device family.
7.4. Purchasing
7.4.1. Process of Purchasing (New Added)
• Evaluation criteria and selection of suppliers
• Monitoring and re-evaluation of suppliers
7.4.2. Purchasing Information (New Added)
• Information on product specifications, product acceptance, qualification of sup-
plier personnel
• Notification changes to purchased products
Fig. 3 Design and development process of medical device

7.4.3. Purchased Product Verification (New Added)

• Inspection process and actions to be taken on changes to the purchased product
7.5. Production and Provision for Service
7.5.1. Production Control and Service Provision (New Added)
• Monitoring and measuring process parameters, availability of equipment, imple-
mentation of operations such as labeling and packaging
7.5.2. Product Cleanliness (New Added)
• Clean prior to sterilization, supplied non-sterile and cleaning at customer end.
7.5.3. Installation Activities
• Req’s on installation of product
7.5.4. Servicing Activities (New Req’s Added)
• Servicing procedures analyze records.
7.5.5. Requirements Particular for Sterile Medical Devices
• Sterilization process parameters
7.5.6. Processes for Production Validation and Provision for Service (New Added)
• Special processes
7.5.7. Particular Requirements for Process Validation for Sterilization and for
Sterile Barrier Systems (New Added)
• Document procedures for the validation of processes.
7.5.8. Identification (New Req’s Added)
• Unique device identification (UDI)
7.5.9. Traceability
• Through records of components, materials, and conditions for the work environ-
ment used
7.5.10. Customer Property
• To identify, verify, protect, and safeguard customer property
7.5.11. Preservation of Product (New Added)
• Preserve during processing, storage, handling, and distribution.
• Protect from alteration, contamination, or damage.
7.6. Monitoring Control and Measuring Equipment
• Calibration of monitoring and measurement equipment
• Protected from damage
• Records maintenance
• Procedure for validation of computer software application used for monitoring
and measurements of requirements
8. Measurement, Analysis, and Improvement
8.1. General
• Conformity to product and QMS
8.2. Monitoring and Measurement
8.2.1. Feedback
• To monitor the quality, feedback document procedures serves as a main input.
8.2.2. Complaint Handling (New Subclause)
• Receive, record, analyze, investigate, and initiate corrective and prevention
action (CAPA).
8.2.3. Reporting to Regulatory Authorities (New Subclause)
• Report adverse events.
8.2.4. Internal Audit
• Ensure Quality management system (QMS) is effectively maintained, planned
intervals.
8.2.5. Monitoring and Measurement of Processes
• Methods for QMS process monitoring
8.2.6. Monitoring and Measurement of Product
• To verify product requirements met evidence of conformity to acceptance criteria
8.3. Nonconforming Product Control (New Added)
8.3.1. General
• Identification and control of nonconforming product
8.3.2. Actions Response to Nonconforming Product Detected Before Delivery
• Eliminate detected nonconformity.
8.3.3. Actions Response to Nonconforming Product Detected After Delivery
• Take actions; issue advisory notices.
8.3.4. Rework
• Undergo same review and approval.
8.4. Analysis of Data (New Req’s Added)
Fig. 4 QMS layout process. (Courtesy: David N. Muchemu. Designing a world-class quality
management system for FDA regulated industries: Quality system requirements (QSR) for
cGMP. Author House Publisher, Bloomington, Indiana; 2008: Page: 14)
• Statistical techniques to analyze data

8.5. Improvement: Corrective Action and Preventive Action (New Req’s Added)
• Eliminate causes of potential nonconformities (Fig. 4).
Effective on 1 March 2018, ISO 13485:2003 certificates published as an ISO
standard on 1 March 2016 will no longer be issued, modified, or revised. Once ISO
13485:2016 published reviewed accepted and voted for Harmonization in Europe.
EU harmonized standards are recognized for “presumed compliance” with EU med-

ical directive requirements (e.g., EN ISO 13485:2016 for CE marketing).
Medical Device Regulation
There are more detailed requirements on everything: previous MD Directive 60+
pages versus new regulation of 566 pages. It will greatly change how approval for
products is sought and maintained. Software in a medical device helps in assuring
medical device regulation. Established product must comply with this, so standards
were used in product development and clinical trial carried out and to rule out mar-
ket supply issues. This is equivalence level to predicate and contract in place, dis-
proportionately affect start-ups/smaller companies, reduce the number of new
products. Some devices will be up classified.
Medical device regulations also deals with clinical data requirements, common
specifications, unique device identification system, person responsible, revised eco-
nomic operator roles, general safety and performance requirements, cosmetic
devices/devices without an indented medical purpose, and unannounced audits:
MDR states at least once every 5 years. In Europe, additional medical device
Periodic Safety Update Reports (PSUR) and Post-Market Surveillance Reports
(PMSR) are required.
References
1. David N. Muchemu. Designing a world-class quality management system for FDA regu-
lated industries: Quality system requirements (QSR) for cGMP. Author House Publisher,
Bloomington, Indiana; 2008: Pages: 14–43. (ISBN-978-1-4343-4871-5 (sc); ISBN-13:978-1
-4343-4872-2(hc))
2. Medical devices—Quality management systems—Requirements for regulatory purposes.
Third edition. ISO 13485:2016(E)-03-01
3. Case Study: Clearing the Path to EU MDR Compliance.
ISO 14971 and ISO 24971: Medical Device
Risk Management
Thamizharasan Sampath, Sandhiya Thamizharasan, K. Vijay Kumar Shetty,

Abbreviations
CMR Carcinogenic, mutagenic and toxic for reproduction

EDs Endocrine disruptors
ISO International Organization for Standardization
PBT Persistent bioaccumulative toxic
vPvB Very persistent and very bioaccumulative
Highlights
• This chapter covers the importance and applications of risk analysis and risk
management process of medical devices.
• It also elucidates ISO regulations to minimize use-related hazards and assure that
intended users are able to use medical devices safely and effectively.
1 Introduction
Medical devices developed for human application are used for diagnostic or treat-
ment purposes. They may either be an instrument, an apparatus or a material.
Moreover, these devices can be used for daily patient care as well as for medical
scientific purposes. Researchers in charge to develop new medical devices are faced
T. Sampath (*)
Department of Pharmacology, Maitri College of Dentistry & Research Centre,
Anjora, Durg, Chhattisgarh, India
S. Thamizharasan
Maitri College of Dentistry & Research Centre, Anjora, Durg, Chhattisgarh, India
K. Vijay Kumar Shetty
Department of Pharmacology, Zydus Medical College and Hospital, Dahod, Gujarat, India
P. S. Timiri Shanmugam
Global Product Safety & Toxicology, Avanos Medical, Inc., Alpharetta, GA, USA

32 T. Sampath et al.
with the complex task of making a medical device safe for human use. This implies
that the device should be safe and effective. Risk management involves the identifi-
cation, understanding, control and prevention of failures that can result in hazards
when people use medical devices. Risk analysis plays a key role in the development
of medical devices design. Risk analysis, or hazard analysis, is a structured tool for
the evaluation of potential problems which could be encountered in connection with
the use of taking a drug, or using a medical device. Manufacturers are expected to
identify possible hazards associated with the design in both normal and fault condi-
tions. If any risk is judged unacceptable, it should be reduced to acceptable levels by
appropriate means. The latest version of ISO 14971:2019 (“Medical devices –
Application of risk management to medical devices”) was approved on 2 May 2019
by the Association for the Advancement of Medical Instrumentation (AAMI) and
on 10 May 2019 by the American National Standards Institute (ANSI).
ISO 14971:2019
2 Scope
It is the specified standard for risk management used to demonstrate compliance

with the risk management requirements of the medical devices. This international
standard specifies a process for a manufacturer to identify the hazards associated
with medical devices, including in vitro diagnostic (IVD) medical devices, to esti-
mate and evaluate the associated risks, to control these risks and to monitor the
effectiveness of the controls. The standard addresses risk management to patient,
operator, other parties, external equipment and/or the environment. Risk
Management Process ISO 14971 requires the manufacturer to establish, document
and maintain a risk management process for:
• Reviewing the intended use (intended purpose) of the medical device
• Identification of hazards (known and foreseeable)
• Estimation of the probability of occurrence of harm
• Estimation of the severity of each hazard and its harm
• Evaluation of associated risks (decision-making)
• Control of these risks
• Monitoring of the effectiveness of these controls throughout the whole life cycle
of a medical device
• This international standard does not apply to decisions on the use of a medical
device in the context of any particular clinical procedure or business risk
management.
• This international standard does not specify acceptable risk levels.
The risk management process does not end with the design and manufacturing
process but also includes applicable sterilization, packaging, labelling, storage, han-
dling/transport, distribution and market surveillance. The manufacturer shall apply
ISO 14971 and ISO 24971: Medical Device Risk Management 33
risk management from the initial conception until the ultimate decommissioning
and disposal of the product. Therefore, the gathering of post-production information
is a required part of the process.
3 Terms and Definitions
Accompanying documentation: materials accompanying a medical device and con-

taining information for the user or those accountable for the installation, use,
maintenance, decommissioning and disposal of the medical device particularly
regarding safe use
Benefit: positive impact or desirable outcome of the use of a medical device on the
health of an individual, or a positive impact on patient management or pub-
lic health
Harm: injury or damage to the health of people, or damage to property or the
environment
Hazard: potential source of harm
Hazardous situation: circumstance in which people, property or the environment is
exposed to one or more hazards
Intended use: use for which a product, process or service is intended according to
the specifications, instructions and information provided by the manufacturer
In vitro diagnostic medical device: whether used alone or in combination, intended
by the manufacturer for the in vitro examination of specimens derived from the
human body solely or principally to provide information for diagnostic, monitor-
ing or compatibility purposes and including reagents, calibrators, control materi-
als, specimen receptacles, software and related instruments or apparatus or other
articles
Life cycle: series of all phases in the life of a medical device from the initial concep-
tion to final decommissioning and disposal
Manufacturer: natural or legal person with responsibility for the design and/or man-
ufacture of a medical device with the intention of making the medical device
available for use, under his name, whether or not such a medical device is
designed and/or manufactured by that person himself or on his behalf by another
person(s)
Medical device: instrument, apparatus, implement, machine, appliance, implant,
reagent for in vitro use, software, material or other similar or related article,
intended by the manufacturer to be used, alone or in combination, for human
beings, for one or more of the specific medical purposes of:
–– Diagnosis, prevention, monitoring, treatment or alleviation of disease
–– Diagnosis, monitoring, treatment, alleviation of or compensation for an injury
–– Investigation, replacement, modification or support of the anatomy or of a
physiological process
–– Supporting or sustaining life
–– Control of conception
–– Disinfection of medical devices
–– Providing information by means of in vitro examination of specimens derived
from the human body, and which does not achieve its primary intended action
by pharmacological, immunological or metabolic means, in or on the human
body, but which may be assisted in its function by such means
Objective evidence: data supporting the existence or verity of something
Post-production: part of the life cycle of the medical device after the design has
been completed and the medical device has been manufactured, for example,
transportation, storage, installation, product use, maintenance, repair, product
changes, decommissioning and disposal
Procedure: specified way to carry out an activity or a process
Process: set of interrelated or interacting activities that use inputs to deliver an
intended result
Reasonably foreseeable misuse: use of a product or system in a way not intended by
the manufacturer, but which can result from readily predictable human behaviour
Record: document stating results achieved or providing evidence of activities
performed
Residual risk: risk remaining after risk control measures have been implemented
Risk: combination of the probability of occurrence of harm and the severity of
that harm
Risk analysis: systematic use of available information to identify hazards and to
estimate the risk
Risk assessment: overall process comprising a risk analysis and a risk evaluation
Risk control: process in which decisions are made and measures implemented by
which risks are reduced to, or maintained within, specified levels
Risk estimation: process used to assign values to the probability of occurrence of
harm and the severity of that harm
Risk evaluation: process of comparing the estimated risk against given risk criteria
to determine the acceptability of the risk
Risk management: systematic application of management policies, procedures and
practices to the tasks of analysing, evaluating, controlling and monitoring risk
Risk management file: set of records and other documents that are produced by risk
management
Safety: freedom from unacceptable risk
Severity: measure of the possible consequences of a hazard
State of the art: developed stage of technical capability at a given time as regards
products, processes and services, based on the relevant consolidated findings of
science, technology and experience
Top management: person or group of people who directs and controls a manufac-
turer at the highest level
Use error: user action or lack of user action while using the medical device that
leads to a different result than that intended by the manufacturer or expected by
the user
Verification: confirmation, through the provision of objective evidence that speci-
fied requirements have been fulfilled
4 General Requirements for Risk Management
Risk management involves the identification, understanding, control and prevention

of failures that can result in hazards when people use medical devices. Manufacturers
are expected to identify possible hazards associated with the design in both normal
and fault conditions. The risks associated with the hazards, including those resulting
from user error, should be calculated in both normal and fault conditions. If any risk
is judged unacceptable, it should be reduced to acceptable levels by appropri-
ate means.
Risk Management Process
The manufacturer shall establish, implement, document and maintain an ongoing
process for:
(a) Identifying hazards and hazardous situations associated with a medical device
(b) Estimating and evaluating the associated risks
(c) Controlling these risks
(d) Monitoring the effectiveness of the risk control measures
This process shall apply throughout the life cycle of the medical device. This
process shall include the following elements:
–– Risk analysis
–– Risk evaluation
–– Risk control
–– Production and post-production activities
4.1 Competence of Personnel
Persons performing risk management tasks shall be competent on the basis of edu-
cation, training, skills and experience appropriate to the tasks assigned to them.
Where appropriate, these persons shall have knowledge of and experience with the
particular medical device (or similar medical devices) and its use, the technologies
involved or the risk management techniques employed. Appropriate records shall be
maintained. Compliance is checked by inspection of the appropriate records (Fig. 1).
Fig. 1 Schematic representation of risk management process
4.2 Risk Management Plan
Risk management activities shall be planned for the particular medical device being
considered; the manufacturer shall establish and document a risk management plan
in accordance with the risk management process. The risk management plan shall
be part of the risk management file. This plan shall include the following:
(a) The scope of the planned risk management activities, identifying and describ-
ing the medical device and the life cycle phases for which each element of the
plan is applicable.
(b) Assignment of responsibilities and authorities.
(c) Requirements for review of risk management activities.
(d) Criteria for risk acceptability, based on the manufacturer’s policy for determin-
ing acceptable risk, including criteria for accepting risks when the probability
of occurrence of harm cannot be estimated. The criteria for risk acceptability
are essential for the ultimate effectiveness of the risk management process. For
each risk management plan, the manufacturer needs to establish risk accept-
ability criteria that are appropriate for the particular medical device.
(e) A method to evaluate the overall residual risk and criteria for acceptability of
the overall residual risk based on the manufacturer’s policy for determining
acceptable risk. It includes gathering and reviewing data and literature for the
medical device being considered and similar medical devices on the market and
can involve judgment by a cross-functional team of experts with application
knowledge and clinical expertise.
(f) Activities for verification of the implementation and effectiveness of risk con-
trol measures.
(g) Activities related to collection and review of relevant production and post-
production information.
If the plan changes during the life cycle of the medical device, a record of the
changes shall be maintained in the risk management file. Compliance is checked by
inspection of the risk management file.
4.3 Risk Management File
For the particular medical device being considered, the manufacturer shall establish
and maintain a risk management file. In addition to the requirements of other clauses
of this document, the risk management file shall provide traceability for each
identified hazard to:
–– The risk analysis
–– The risk evaluation
–– The implementation and verification of the risk control measures
–– The results of the evaluation of the residual risks
The records and other documents that make up the risk management file can
form part of other documents and files required, for example, by a manufacturer’s
quality management system. The risk management file need not physically contain
all the records and other documents. However, it needs to contain at least references
or pointers to all required documentation, so that the manufacturer can assemble the
information referenced in the risk management file in a timely manner.
5 Risk Analysis
The manufacturer shall perform risk analysis for the particular medical device. The
implementation of the planned risk analysis activities and the results of the risk
analysis shall be recorded in the risk management file. If a risk analysis or other
relevant information is available for a similar medical device, that analysis or infor-
mation can be used as a starting point for the new risk analysis. The degree of rele-
vance depends on the differences between the medical devices and whether these
introduce new hazards or significant differences in outputs, characteristics, perfor-
mance or results. The extent of use of an existing risk analysis is based on a system-
atic evaluation of the effects that the differences can have on the occurrence of
hazardous situations. In addition, the documentation of the conduct and results of
the risk analysis shall include at least the following:
(a) Identification and description of the medical device that was analysed
(b) Identification of the person(s) and organization who carried out the risk analysis
(c) Scope and date of the risk analysis
5.1 Intended Use and Reasonably Foreseeable Misuse
The manufacturer shall document the intended use of the particular medical device
being considered. The intended use should take into account information such as the
intended medical indication, patient population, part of the body or type of tissue
interacted with, user profile, use environment and operating principle. The manu-
facturer shall also document reasonably foreseeable misuse.
5.2 Identification of Characteristics Related to Safety
For the particular medical device being considered, the manufacturer shall identify
and document those qualitative and quantitative characteristics that could affect the
safety of the medical device. Where appropriate, the manufacturer shall define lim-
its of those characteristics. This documentation shall be maintained in the risk man-
agement file. Characteristics related to loss or degradation of the clinical performance
of a medical device that can result in unacceptable risk are sometimes referred to as
essential performance.
5.3 Identification of Hazards and Hazardous Situations
The manufacturer shall identify and document known and foreseeable hazards asso-
ciated with the medical device based on the intended use, reasonably foreseeable
misuse and the characteristics related to safety in both normal and fault conditions.
For each identified hazard, the manufacturer shall consider the reasonably foresee-
able sequences or combinations of events that can result in a hazardous situation and
shall identify and document the resulting hazardous situations (Fig. 2 and Tables 1,
2 and 3).
5.4 Risk Estimation
For each identified hazardous situation, the manufacturer shall estimate the associ-
ated risk(s) using available information or data. For hazardous situations for which
the probability of the occurrence of harm cannot be estimated, the possible conse-
quences shall be listed for use in risk evaluation and risk control. The results of
these activities shall be recorded in the risk management file. The system used for
qualitative or quantitative categorization of probability of occurrence of harm and
severity of harm shall be recorded in the risk management file. Risk estimation
incorporates an analysis of the probability of occurrence of harm and the severity of
the harm. Depending on the area of application, only certain elements of the risk
estimation process might need to be considered in detail. For example, when the
harm is minimal, an initial hazard and consequence analysis could be sufficient, or
when insufficient information or data are available, a conservative estimate of the
Fig. 2 Hazard and sequence of events

Table 1 Examples of hazards

Performance
Energy hazards Biological & Chemical hazards related hazards
Acoustic energy Biological agents Data
Infrasound Bacteria Access
Sound pressure Fungi Availability
Ultrasonic Parasites Confidentiality
Electric energy Prions Transfer
Electric fields Toxins Integrity
Leakage current Viruses Delivery
Earth leakage Chemical agents Quantity
Enclosure leakage Carcinogenic, mutagenic, Rate
reproductive causative, corrosive
Magnetic fields Diagnostic
information
Static discharge Acidic Examination result
Voltage Alkaline Image artefacts
Mechanical energy Oxidants Stock orientation
Kinetic energy Flammable, combustible, Image resolution
explosive
Falling objects fumes and vapors Patient identity
High pressure fluid injection Particles(including micro and Patient identity/
nano particles) information
Functionality
Moving parts Pyrogenic Alarm
Vibrating parts Solvents Critical
performance
Potential energy Toxic Measurement
Bending Asbestos
Compression Heavy metals
Cutting, shearing Inorganic toxicants
Gravitational pull Silica
Suspended mass Immunological agents
Tension Allergenic
Torsion Antiseptic substances
Radiation energy Latex
Ionizing radiation Immunosuppressive irritants
Accelerated particles(alpha particles, Cleaning residue sensitizing
electrons,protons,neutrons)
Gamma
x-ray
Non-ionizing radiation
Infrared
Laser
Microwave
(continued)
Table 1 (continued)
Performance
Energy hazards Biological & Chemical hazards related hazards
Ultraviolet
Thermal energy
Cryogenic effects
Hyperthermic effects
Table 2 Examples of events and circumstances

General category Events and circumstances
Requirements Inadequate specification of
Design parameters
Operating parameters
Performance requirements
In service requirements (e.g. maintenance, reprocessing)
Manufacturing process Insufficient control of
Manufacturing process
Changes to manufacturing process
Materials
Materials compatibility information
Subcontractors
Transport and storage Inadequate packaging
Contamination or deterioration
Inappropriate environment conditions
Environmental factors Physical factors (e.g. heat, pressure, time)
Chemical factors (e.g. corrosion, degradation, contamination)
Electromagnetic fields (e.g. susceptibility to electromagnetic
disturbance)
Inadequate supply of power
Inadequate supply of coolant
Cleaning disinfection Lack of validated procedures
and sterilization
Inadequate specification of requirements
Inadequate performance of cleaning, disinfection or sterilization
Disposal and scrapping No or inadequate information provided
Use error
Formulation Biodegradation
Biocompatibility
No information or inadequate specification provided
Incorrect formulations
Use error
Usability Confusing or missing instructions for use
Complex or confusing control system
Ambiguous or unclear presentation of setting measurements or other
information
(continued)
Table 2 (continued)
General category Events and circumstances
Misrepresentation of results
Insufficient visibility, audibility or tactility
Poor mapping of controls to actions or displayed information to actual
state
Controversial modes or mapping as compared to existing equipment
Use by unskilled or untrained personnel
Insufficient warming of side effects
Inadequate warming of hazards associated with re use of single use
medical devices
Incorrect measurement and other meteorological aspects
Incompatibility with consumables, accessories other medical devices
Incorrect patient identification
Slips, lapses and mistakes
Functionality Loss of electrical or mechanical integrity
Deterioration in performance (e.g. gradual occlusion of fluid change in
resistance to flow electrical conduction) as a result of ageing wear and
repeated use.
Security Unsecured data ports that are externally accessible (e.g. network, serial
or USB ports) Data without encryption
Software vulnerabilities that can be exploited
Table 3 Relationship between hazards, foreseeable sequences of events, hazardous situation

and harm
Foreseeable sequences of
Hazard events Hazardous situations Harm
Electromagnetic (1) Electrode cable Line voltage appears on Serious burns
energy (high unintentionally plugged electrodes Heart fibrillation
voltage) into power line receptacle
Chemical (voltatile (1) Incomplete removal of Development of gas Infarct
solvent, embolus) volatile solvent used in embolism (bubbles in the Brain damage
manufacuring blood stream) during
(2) Solvent residue converts dialysis
to gas at body temperature
Biological (1) Inadequate instructions Bacteria released into Bacterial
(microbial provided for airway of patient during infection
contamination) decontaminating re-used anaesthesia
anaesthesia tubing
(2) Contaminated tubing
used during anaesthesia
(continued)
Table 3 (continued)
Foreseeable sequences of
Hazard events Hazardous situations Harm
Functionality (no (1) Electrostatically Failure to deliver insulin Minor organ
delivery) charged patient touches to patient with elevated damage
infusion pump blood glucose level, no Decreased
warning given Consciousness
(2) Electrostatically
discharged (ESD) causes
pump and pump alarms to
fail
Functionally (no (1) Implantable Defibrillator cannot Death
output) defibrillator battery reaches deliver shock when an
the end of its useful life arrhythmia occurs
(2)Inappropriately long
interval between clinical
follow up visits
Measurement (1) Measurement error Incorrect information Progression of
(Incorrect Reported to clinician, disease
information) leading to misdiagnosis Serious injury
(2) No detection by user
and /or lack of proper
therapy
probability of occurrence can give some indication of the risk. Information or data
for estimating risks can be obtained from:
–– Published standards
–– Scientific or technical investigations
–– Field data from similar medical devices already in use
–– Usability tests employing typical users
–– Clinical evidence
–– Results of relevant investigations or simulations
–– Expert opinion
–– External quality assessment schemes for in vitro diagnostic medical devices
6 Risk Evaluation
For each identified hazardous situation, the manufacturer shall evaluate the esti-
mated risks and determine if the risk is acceptable or not, using the criteria for risk
acceptability defined in the risk management plan. If the risk is acceptable, it is not
required to apply the requirements given in the risk control process to this hazard-
ous situation, and the estimated risk shall be treated as residual risk. If the risk is not
acceptable, then the manufacturer shall perform risk control activities. The results
of this risk evaluation shall be recorded in the risk management file.
7 Risk Control
7.1 Risk Control Option Analysis
The manufacturer shall determine risk control measures that are appropriate for
reducing the risks to an acceptable level. The manufacturer shall use one or more of
the following risk control options in the priority order listed:
(a) Inherently safe design and manufacture
(b) Protective measures in the medical device itself or in the manufacturing process
(c) Information for safety and, where appropriate, training to users
The risk control measures selected shall be recorded in the risk management file.
During risk control analysis, the manufacturer determines that risk reduction is not
practicable; the manufacturer shall conduct a benefit-risk analysis of the resid-
ual risk.
7.2 Implementation of Risk Control Measures
The manufacturer shall implement the risk control measures selected in the risk
control option. Implementation of each risk control measure shall be verified.
Verification of effectiveness can also be performed as part of design and develop-
ment verification or process qualification, if the relationship between the effective-
ness in risk reduction and the result of design and development verification or
process qualification is known.
–– Design verification of a certain performance characteristic, such as dose accu-
racy of a drug injector, can serve as verification of effectiveness of risk control
measures ensuring safe drug dosing.
–– Process qualification can serve as verification of effectiveness of risk control
measures related to risk caused by variations in production output.
7.3 Residual Risk Evaluation
After the risk control measures are implemented, the manufacturer shall evaluate
the residual risk using the criteria for risk acceptability defined in the risk manage-
ment plan. The results of this evaluation shall be recorded in the risk management
file. If a residual risk is not judged acceptable using these criteria, further risk con-
trol measures shall be considered.
7.4 Benefit-Risk Analysis
If a residual risk is not judged acceptable using the criteria established in the risk
management plan and further risk control is not practicable, the manufacturer may
gather and review data and literature to determine if the benefits of the intended use
outweigh this residual risk. If this evidence does not support the conclusion that the
benefits outweigh this residual risk, then the manufacturer may consider modifying
the medical device or its intended use. Otherwise, this risk remains unacceptable. If
the benefits outweigh the residual risk, then proceed to risk control measures.
7.5 Risks Arising from Risk Control Measures
The manufacturer shall review the effects of the risk control measures with regard
to whether new hazards or hazardous situations are introduced or the estimated risks
for previously identified hazardous situations are affected by the introduction of the
risk control measures. Any new or increased risks shall be managed in accordance
with risk management protocol. The manufacturer shall also review the risk control
activities to ensure that the risks from all identified hazardous situations have been
considered and all risk control activities are completed.
7.6 Evaluation of Overall Residual Risk
After all risk control measures have been implemented and verified, the manufac-
turer shall evaluate the overall residual risk posed by the medical device, taking into
account the contributions of all residual risks, in relation to the benefits of the
intended use, using the method and the criteria for acceptability of the overall resid-
ual risk defined in the risk management plan. If the overall residual risk is judged
acceptable, the manufacturer shall inform users of significant residual risks and
shall include the necessary information in the accompanying documentation in
order to disclose those residual risks. If the overall residual risk is not judged accept-
able in relation to the benefits of the intended use, the manufacturer may consider
implementing additional risk control measures or modifying the medical device or
its intended use. Otherwise, the overall residual risk remains unacceptable.
8 Risk Management Review
Prior to release for commercial distribution of the medical device, the manufacturer
shall review the execution of the risk management plan. This review shall at least
ensure that:
–– The risk management plan has been appropriately implemented

–– The overall residual risk is acceptable
–– Appropriate methods are in place to collect and review information in the pro-
duction and post-production phases
The manufacturer shall establish, document and maintain a system to actively
collect and review information relevant to the medical device in the production and
post-production phases. When establishing this system, the manufacturer shall con-
sider following methods for the collection and processing of information.
–– Information generated during production and monitoring of the produc-
tion process
–– Information generated by the user
–– Information generated by those accountable for the installation, use and mainte-
nance of the medical device
–– Information generated by the supply chain
–– Publicly available information
–– Information related to the generally acknowledged state of the art
The manufacturer shall review the information collected for possible relevance
to safety, especially whether:
–– Previously unrecognized hazards or hazardous situations are present
–– An estimated risk arising from a hazardous situation is no longer acceptable
–– The overall residual risk is no longer acceptable in relation to the benefits of the
intended use
–– The generally acknowledged state of the art has changed
The collected information is determined to be relevant to safety; the following
actions apply:
Concerning the particular medical device, the manufacturer shall review the risk
management file and determine if reassessment of risks and/or assessment of new
risk is necessary. If a residual risk is no longer acceptable, the impact on previously
implemented risk control measures shall be evaluated and should be considered as
an input for modification of the medical device and shall evaluate the impact on
previously implemented risk management activities, and the results of this evalua-
tion shall be considered as an input for the review of the suitability of the risk man-
agement process by top management.
9 I SO/TR 24971:2013: Guidance on Application

of ISO 14971
Aim and Scope

ISO/TR 24971 has the same structure and numbering of clauses as the revision of
ISO 14971. Guidance is provided to help understand and implement each
requirement in ISO 14971. This new structure should make the guidance more rel-
evant and easier to navigate. Annexes to the guidance in ISO/TR 24971 have been
prepared to provide more detailed approaches to specific aspects of risk manage-
ment. The annexes include the following:
• Identification of hazards and characteristics of safety provides questions that can
aid in identifying the characteristics of the medical device that could affect safety.
• Risk analysis techniques provide guidance on some available tools that support
the performance of a risk analysis but emphasize that these techniques do not
include all steps of the risk management process.
• Risk acceptability considerations describe aspects that can be used as part of risk
control options analysis and be applied to risks for which the probability cannot
be estimated.
• Information for safety and information on residual risk seek to clarify the differ-
ences between “information for safety” and “disclosure of residual risk”. It also
provides guidance on information for safety as a risk control measure and how
residual risks can be disclosed to promote risk awareness.
• Guidance on risks related to (cyber)security outlines terminology used in secu-
rity risk management and the relationship between ISO 14971 and (cyber)secu-
rity risks.
• Components and devices designed not using ISO 14971 aim to address preparing
a risk management file retrospectively. It addresses how to build an initial risk
management file when all the processes and requirements described in ISO
14971 were not followed at the time when the device was initially designed. This
could be applicable for medical devices already available on the market or for
constituent components of a medical device, such as subsystems of non-
medical origin.
• Guidance for in vitro diagnostic medical devices is focused on the indirect risks
to patients from incorrect or delayed in vitro diagnostic results.
9.1 I nternational Product Safety Standards

in Risk Management
International product safety and process standards play a significant role in risk
management as described by ISO 14971. In principle, these standards are developed
using a type of risk management that can include identifying hazards and hazardous
situations, estimating risks, evaluating risks and specifying risk control measures.
When performing risk management activities, manufacturers can take advantage of
the work of the standards writers and need not repeat the analyses leading to the
requirements of the standard. International standards, therefore, provide valuable
information on risk acceptability that has been validated during a worldwide evalu-
ation process, including multiple rounds of review, comment and voting.
An international product safety standard can establish requirements that, when

implemented, result in acceptable risk for specific hazardous situations (e.g. safety
limits). The manufacturer can apply these requirements in the following way when
managing risk:
(a) Where an international product safety standard specifies technical requirements
addressing particular hazards or hazardous situations, together with specific
acceptance criteria, compliance with those requirements is presumed to estab-
lish that the residual risks have been reduced to acceptable levels unless there is
objective evidence to the contrary. For example, in IEC 60601-1, Medical elec-
trical equipment – Part 1: General requirements for basic safety and essential
performance, leakage current must be controlled to achieve an acceptable level
of risk. IEC 60601-1 provides leakage current limits that are considered to
result in an acceptable level of risk when measured under the conditions stated
in 8.7 of IEC 60601-1:2005. For this example, further risk management would
not be necessary. The following steps need to be taken in this case:
(i) Identify characteristics related to safety and identify hazards and hazard-
ous situations associated with the device as completely as possible.
(ii) Identify those hazards and hazardous situations relevant to the particular
medical device that are exactly covered by the international product safety
standard.
(iii) For those identified hazards and hazardous situations exactly covered by
the international product safety standard, the manufacturer may choose
not to estimate or evaluate the risks so identified but rather rely on the
requirements contained in the international standard to demonstrate the
completion of risk estimation and risk evaluation.
(iv) To the extent possible, the manufacturer should identify the design speci-
fications that satisfy the requirements in the standard and serve as risk
control measures.
(v) Verification of the implementation of the risk control measures for these
hazardous situations is obtained from the design documents. Verification
of the effectiveness of the risk control measures is obtained from the tests
and test results demonstrating that the device meets the relevant require-
ments of the international product safety standard.
(vi) If the relevant requirements are met, the associated residual risk is consid-
ered acceptable.
(b) Where an international product safety standard does not completely specify
technical requirements and associated tests and test acceptance criteria, the situ-
ation is more complex. In some cases, the standard directs the manufacturer to
perform specific tests related to known hazards or hazardous situations but does
not provide specific test acceptance criteria (e.g. IEC 60601-2-16, Medical
electrical equipment: Particular requirements for basic safety and essential per-
formance of haemodialysis, haemodiafiltration and haemofiltration equipment).

In some other cases, the standard can simply direct the manufacturer to investi-
gate specific hazards or hazardous situations in their risk analysis (IEC
60601-1:2005). The range of alternatives is too large to provide specific guid-
ance on how to use such standards in the risk management process. Manufacturers
are encouraged, however, to use the content of such standards in their risk man-
agement of the particular medical device.
(c) For hazards or hazardous situations that are identified for the particular medical
device but are not specifically addressed in any standard, the manufacturer
needs to address those hazards or hazardous situations in the risk management
process.
International Process Standards and ISO 14971
International process standards, as shown in the examples below, can often be used
in conjunction with ISO 14971. This is performed in one of two ways: The interna-
tional process standard requires application of ISO 14971 as part of the implemen-
tation of the international process standard, e.g. IEC 62304 on software life cycle
processes; or the international process standard is intended to be used in risk man-
agement, e.g. IEC 62366 on usability engineering and the ISO 10993 series on
biological evaluation. In either case, proper use of the international process standard
requires attention to the interfaces between that standard and ISO 14971 in order to
achieve acceptable levels of risk for the medical device. The two standards should
work together such that inputs, outputs and their timing are optimized. Three exam-
ples are given below to demonstrate this ideal situation.
9.2 IEC 62304: Medical Devices Software Life Cycle Processes
The risk management process is already very well addressed by the international
standard ISO 14971. Therefore IEC 62304 makes use of this advantage simply by a
normative reference to ISO 14971. Some minor additional risk management require-
ments are needed for software, especially in the area of identification of contribut-
ing software factors related to hazards. Whether software is a contributing factor to
a hazard is determined during the hazard identification activity of the risk manage-
ment process. Hazards that could be indirectly caused by software (e.g. by provid-
ing misleading information that could cause inappropriate treatment to be
administered) need to be considered when determining whether software is a con-
tributing factor. The decision to use software to control risk is made during the risk
control activity of the risk management process. The software risk management
process required in this standard has to be embedded in the device risk management
process according to ISO 14971.
9.3 I EC 62366: Application of Usability Engineering

to Medical Devices
IEC 62366:2007 identifies specific clauses where the usability engineering process
can supplement and interact with risk management as described in ISO 14971. It
requires the following: “An identification of characteristics related to safety (part of
a risk analysis) that focuses on usability shall be performed and “The manufacturer
shall identify known or foreseeable hazards (part of a risk analysis) related to usabil-
ity”. It makes several references to activities that would be undertaken as part of risk
management.
9.4 ISO 10993: Biological Evaluation of Medical Devices
Biological safety evaluation and hazard testing of medical devices shall be per-
formed in compliance with the ISO 10993 “Biological Evaluation of Medical
Devices” series as international standards. Based on the framework and principles
of ISO 10993-1 “Evaluation and Testing”, the necessary evaluation items can be
selected corresponding to the nature and duration of exposure of individual medical
devices with the human body. The test method guidelines in the ISO 10993 series
generally include lists of multiple test methods for each evaluation item. ISO
10993-3 specifies strategies for risk estimation, selection of hazard identification
tests and risk management, with respect to the possibility of the following poten-
tially irreversible biological effects arising as a result of exposure to medical
devices:
• Acute toxicity
• Chronic toxicity
• Irritation (eye, skin, mucosal surfaces)
• Hypersensitivity
• Genotoxicity
• Carcinogenicity
• Reproductive and developmental toxicity
The international standards have been continuously revised according to the
development of science and technology. Accordingly, an appropriate test method
must be selected, considering the most current international standards at the time
when testing is conducted.
EU Regulation
EU Regulation of RoHS: European Union directives have restricted the use of cer-
tain hazardous substances in medical devices and implants. Hazardous substances
are categorized per EU Regulation 1272/2008 (Classification, Labelling and
Packaging of substances/mixtures and substances identified in EU Regulation
1907/2006) (REACH: Registration, Evaluation, Authorisation and Restriction of

Chemicals). EU 1272/2008 REACH contains all hazardous chemicals list. SVHC
(substance of very high concern) contains CMR substances like N,N-
Dimethylanilinium Tetrakis (pentafluoropheny) borate, dibutyltin hydrogen borate
and perboric acid and restricted substances list of EDs, PBT and vPvB. Chemicals
that are substances of very high concern are to be phased out and replaced with safer
alternative chemicals. In addition with CMR, EDs, PBTs and vPvB, the lists extend
with flammable gas, flammable aerosol, oxidizing gas, gases under pressure, flam-
mable liquid, flammable solid, self-reactive substance or mixture and chemicals
capable of causing skin corrosion, irritation, serious eye irritation, respiratory/skin
sensitization, germ cell mutagenicity, specific target organ toxicity and hazard to the
aquatic environment and ozone layer. RoHS specifies maximum levels by weight
for the following ten restricted materials. The first six applied to the original RoHS,
while the last four phthalates were added under RoHS III. The expanded list for
RoHS 3 is thus as follows:
• Lead (0.1%)
• Mercury (0.1%)
• Cadmium (0.01%)
• Hexavalent chromium (0.1%)
• Polybrominated biphenyls (PBB) (0.1%)
• Polybrominated diphenyl ethers (PBDE) (0.1%)
• Bis(2-ethylhexyl) phthalate (DEHP) (0.1%)
• Butyl benzyl phthalate (BBP) (0.1%)
• Dibutyl phthalate (DBP) (0.1%)
• Diisobutyl phthalate (DIBP) (0.1%)
As per RoHS guidelines, device designers are required to replace these chemi-
cals in their products with less hazardous alternatives. The hazardous substances
present in any of the medical device or implants should be less than 0.1 W/W of the
device. Acceptable justification must be given if the CMR or endocrine-disrupting
substances (e.g. lead compounds, other heavy metals, phenols) are present above
0.1 per cent by weight in these device types. The restriction of DEHP, BBP, DBP
and DIBP shall apply to medical devices, including in vitro medical devices, and
monitoring and control instruments, including industrial monitoring and control
instruments, from 22 July 2021. Medical device manufacturers are advised to thor-
oughly review the conformity assessment procedures applicable to their device to
avoid delays in the product review and approval process. In addition to the require-
ments of RoHS III (EU Directive 2015/863), medical device manufactures may be
subject to other EU directives and regulations addressing the use of hazardous sub-
stances and the control of electrical and electronic waste. These include EU Directive
2012/19/EC on Waste Electrical and Electronic Equipment (II), and EU regulation
(1907/2006), as well as EU directives on the disposal of batteries, and on product
packaging and packaging waste. According to EU Directive (2011/65/EU), medical
devices have to follow the restrictions regarding the use of hazardous substances.
9.5 eveloping the Policy for Determining the Criteria

D
for Risk Acceptability
According to 3.2 of ISO 14971:2007, top management is required to define and

document the policy for determining the criteria for risk acceptability. This policy is
intended to ensure the following:
–– Criteria are based upon applicable national or regional regulations.
–– Criteria are based upon relevant international standards.
–– Criteria take into account available information such as the generally accepted
state of the art and known stakeholder concerns.
–– The applicable regulatory requirements in the regions where the medical device
is to be marketed.
–– The relevant international standards for the particular medical device or an
intended use of the medical device that can help identify principles for setting the
criteria for risk acceptability.
–– Information on the state of the art can be obtained from review of the literature
and other information on similar medical devices the manufacturer has marketed,
as well as those from competing companies.
–– The validated and comprehensive concerns from the main stakeholders. Some
potential sources of information on the patient and clinician perspective can
include news media, social media, patient forums as well as input from internal
departments with expert knowledge of stakeholder concerns such as the clinical
department. The manufacturer should provide guidelines for developing the
actual criteria for risk acceptability to be used in the risk management plan for
the particular medical device being considered.
9.6 Production and Post-production Feedback Loop
The initial risk assessment is based on experience with similar medical devices or
applications on the market, or on assumptions when new medical devices are
released to the market. Information received after market entry is valuable for con-
firming or correcting assumptions and estimates (both overestimates and underesti-
mates), or identifying omissions made during the risk analysis and risk control
phases. The feedback loop is established to collect and evaluate such information
for potential relevance to medical device safety. The feedback loop should consist
of the following steps:
–– Observation and transmission
–– Assessment
–– Action
Observation and Transmission

An observation provides information on, or experience with, a medical device that
should be compared against the current risk management file. The observation can
come from a number of different sources each of which can have a bearing on the
safety of the medical device.
• Information from manufacturing or research and development (R&D) activities
within or contracted by the manufacturer
• Information from installation, servicing and/or training personnel within or con-
tracted by the manufacturer
• Information from the use/users of the medical device (e.g. customer complaints,
user surveys)
• Information from experience with competitor’s medical devices through incident
reports (e.g. from databases provided by local regulatory agencies to collect and
generate an overview of device experience)
• Clinical information (e.g. post-market clinical trials on the manufacturer’s own
medical devices or other published clinical literature on competitors’ and similar
medical devices)
• Information on new or amended standards and regulations
For information to be relevant to a manufacturer’s medical device, it need not be
directly related to their own or a competitor’s product. Information relating to simi-
lar medical devices with similar intended use or similar principles of operation can
yield useful post-market information on the relevance of the risks of the manufac-
turer’s medical device. When designing a means of acquiring or detecting post-
market information, manufacturers should be careful not to introduce bias into the
process. The means of acquiring or asking for feedback should be neutral with
regard to achieving negative or positive feedback. Furthermore, feedback should
include events that have occurred (including corrective action) as well as events that
could occur (including preventive action). For any post-market information to be
useful, it has to be communicated to the persons or department within the organiza-
tion that has the responsibility and authority to compare against the current risk
management file and enact change where necessary.
The means of transmission of this information will depend on the source of the
information. Some information will be pulled (initiated by the manufacturer), and
some information will be pushed (initiated by sources like the customer, authorities
or patient). In either case, the organization should ensure that efficient communica-
tion channels are planned and established to allow for timely and accurate receipt of
information. The rate at which the manufacturer pulls information from the various
sources (including users) depends on the maturity of the medical device, its technol-
ogy and the specific market. Various departments within the manufacturer’s organi-
zation can receive and handle different kinds of information, for example:
• Customer complaints or adverse event reports
• Service and installation reports
• New or revised regulations, standards or guidance
• Production non-conformance reports

It is important that all relevant information from these groups is reviewed and
distributed to that part of the manufacturer’s organization with the responsibility
and authority for the risk assessment. Where the probability of events (e.g. compo-
nent failures) is a relevant factor contributing to the evaluation of risk, statistical
trending of such events should be considered.
Assessment
Any revision to the risk assessment based on new observations should be subject to
the same level of control and review as the initial risk assessment. This would
include any subsequent identification of risk control measures, if required. Such
controls should include review and approval by individuals in the same functions or
departments as those who signed off originally. Any new safety-related observations
are to be assessed using the current criteria for risk acceptability. New observations
related to safety should be compared with the established risk management file to
test the validity of any assumptions made. Several questions are suggested below:
(a) Is the intended use still valid?
(b) Is there an increasing trend of off-label use?
(c) Are there occurrences of misuse which were not foreseen in the original risk
management process?
(d) Is there evidence of new hazards or hazardous situations not originally identi-
fied in the hazard identification process?
(e) Are the severity and probability estimations for a particular risk still valid?
(f) Is there any evidence that the criteria for risk acceptability should be adjusted?
(g) Is the effectiveness of risk control measures proven adequate?
(h) Does the risk/benefit analysis accurately represent the actual market experience?
If data suggest correction or adjustment of the current risk management file, the
residual risks need to be evaluated based on the new data. In addition, the overall
residual risk of the device should be reviewed.
Information for Safety Information for safety is regarded as a risk control mea-
sure. It is the least preferred option after inherent safety by design and protective
measures. This means that information for safety should be used after the manufac-
turer has determined that further risk reduction by making the medical device inher-
ently safe and taking protective measures is not practicable. The text for information
for safety can be prescribed by local regulations. The verification of the effective-
ness of the information for safety can be performed by the usability engineering
process. Information for safety needs to give the user clear instructions of what
actions to take or to avoid a hazardous situation or harm from occurring. This is
usually provided in the form of warnings or precautions. Information for safety can
be given in the form of a warning label attached to medical devices or as a warning
statement in the instructions for use. Some examples are given below:
• Warning: Do not step on surface.
• Warning: Do not remove cover, risk of electric shock.
• Warning: Use with caution.

Disclosure of Residual Risk Disclosure of residual risk is descriptive and can pro-
vide background on the residual risks involved in using the medical device. The aim
is to disclose in the accompanying documents information to enable the user, and
potentially the patient, to make an informed decision that weighs the residual risks
against the benefits of using the medical device. The manufacturer should consider
means and media to disclose the residual risk. This information can be significant in
the process of clinical decision-making. Within the framework of the intended use,
the operator or the user can decide in which clinical settings the medical device can
be used to achieve a certain benefit for the patient. The disclosure of the residual risk
can also be useful for the operator, the user or the hospital organization to prepare
the patient for possible side effects or hazards that can occur during or after the use
of the medical device. Note that operator, user and patient can be the same person,
for example, for medical devices used in the home healthcare environment. Some
examples are given below to illustrate the residual risks associated with using the
medical device and such side effects that are normally disclosed. The residual risks
of radiation therapy for tumours can include the possibility of erythema or epilation.
Patients undergo magnetic resonance imaging (MRI); they sometimes experience
anxiety due to being in an enclosed space, hearing the loud noise generated by the
equipment and needing to remain still during imaging.
Evaluation of Overall Residual Risk

After the assessment of every identified separate hazardous situation, the manufac-
turer then considers the combined impact of the individual residual risks and decides
whether the overall residual risk meets or exceeds the criteria for residual risk
acceptability stated in the risk management plan. This step is particularly important
for complex medical systems and for medical devices with a large number of indi-
vidual risks. The evaluation can be used for making a case that the product is safe.
However, the determination of overall residual risk is a difficult and challenging
task that cannot be achieved simply by numerically adding all individual risks. It is
even uncertain if adding risks is possible at all, because each probability of occur-
rence of harm is related to a different severity of that harm. This difficulty also arises
for the following reasons:
Even in the later stages of medical device development, confidence in the prob-
ability estimates can vary considerably. Some probabilities are known precisely
either from history with similar medical devices or from testing. Other probabilities
are only estimates and might be known very imprecisely or not at all, such as the
probability of a software failure. Also, it is usually not possible to combine the
severities of individual harms within the broad categories usually used in risk analy-
sis. ISO 14971 does not specify that the criteria for risk acceptability for individual
risks need to be the same as the criteria for overall risk acceptability. The criteria
used to evaluate individual risks are usually based on the probability of occurrence
of particular severities of harm.
The key to successful risk management in medical device design is to start early.
As soon as conceptual designs are available, the risk management process can
begin. A preliminary hazard analysis can be useful in selecting the concept with the
highest level of inherent safety. Later, as the design is developed, design reviews at
key points in the development process will allow changes to be made without sig-
nificantly affecting the project schedule. The further along in the design process that
changes are identified, the fewer choices are available to mitigate hazards without
significant schedule implications.
Generally, risk management activities will identify opportunities to improve
device performance. The benefits of conducting risk analysis during medical device
design can be significant and can be used to offset some or all of the cost of imple-
menting risk-mitigating measures. There is always a trade-off in how to manage
risk. Hardware or software controls are generally viewed as more effective since
they are more reliable than humans. However, since there is need for human interac-
tion in the operation of all medical devices, the element of risk needs to be ade-
quately evaluated. Minimizing the level of routine human intervention will reduce
risk and improve efficiency. Such risk reduction must be weighed against the cost of
automating tasks that can be performed by individuals.
References
1. ISO 14971: 2019 Medical devices – Application of risk management to medical devices ANSI/
AAMI/2019.
2. ISO/TR 24971:2013 Medical devices – Guidance on the application of ISO 14971.
ISO 19227: Implants for Surgery –
Cleanliness of Orthopedic Implants
Nandakumar Palani
1 Introduction
Medical implants are planted into a human body by surgery or naturally formed
cavity and are planned to retain over short or longer period depending upon the type
of surgery. FDA came up with standards to classify the devices which are placed in
the human body regardless of the location and period also called as medical implants.
Implantable devices are partly human-made implants or natural implants which
are fully introduced into the subject and planned to retain after the surgery for a
period of time based on the need.
The cleanliness of the implants involves various steps and process based on the
ISO 19227 Implants for Surgery – Cleanliness of Orthopaedic Implants.
Cleaning of orthopaedic implants is an important step in the process, and to
achieve the cleanliness, biocompatibility and controlling the microbiological load
are required for the sterilization process.
The application of the implants decides the constitutive material to manufacture
the implant which should be safe and free from the contaminants that can be released
from or reside on their surface. Cleanliness of orthopaedic implants is a key factor
to ensure the biocompatibility of an implant. Cleaning is a needed step in the pro-
cess to remove implant material contaminations coming from the manufacturing
process. In cleaning materials should not react with constitutive materials and dam-
age the biocompatibility or disable the performance of the implant. The cleaning
agents should have proven the biocompatibility and does not damage or impair the
implant performance.
N. Palani (*)
R&D Engineer, Medical Devices, Milpitas, USA
M.Sc., Electronics, Chennai, India

58 N. Palani
Based on these requirements, the cleaning process validation and the biological
evaluation of the implant are interconnected according to ISO 10993-1.
The cleaning process for orthopaedic implants can be sterile or non-sterile which
is the manufacturer responsibility to provide implants clean from manufacturing
contaminants.
The cleaning validation is to evaluate the cleaning process effectiveness in reduc-
ing contaminants in the form of physical, chemical and biological below a defined
level. The evaluation and validation of cleaning methods is a critical task which
requires in-depth knowledge of the manufacturing process on orthopaedic implants
to identify contaminants and potential reactions with implant materials and chemi-
cal used in the cleaning process.
The effectiveness of the cleaning process is done during the manufacturing pro-
cess in a separate environment as an alternative to final cleaning; the cleanliness of
implants can be controlled by manufacturing in a clean environment and with clean
processes.
The international ISO 19227:2018 “Implants for surgery—Cleanliness of ortho-
pedic implants—General requirements” specifies requirements for the cleanliness
of orthopaedic implants and test methods for the cleaning process validation.
Based on the standard ISO 19227:2018, the organized process for cleanliness of
orthopaedic implants allows to reduce particles and chemical and biological con-
taminants below a defined level during manufacturing process. To make this hap-
pen, the implementation of the ISO 19227 standard, the manufacturer needs several
steps to be set up:
• A review on the risk assessment on the cleaning process (development, valida-
tion and processing methods)
• A defined method development based on implant material characteristics, manu-
facturing steps/process and the implant performance
• A defined level of cleanliness requirements after final cleaning
• A cleaning methods validation for each implant
• A biological evaluation according to ISO 10993-1 and a validation of the steril-
ization process (Fig. 1)
Material and Methods and Results
2 General Requirements
2.1 Quality Management System
The set of methods or activities carried out for the implant cleanliness following this
document shall be transferred to a formal quality management system.
The QMS which is widely used across all the countries for medical devices is
ISO 13485.
ISO 19227: Implants for Surgery – Cleanliness of Orthopedic Implants 59
Fig. 1 Physical, chemical and biological contaminants
2.2 Risk Management
Risk management is an iterative cycle which is done during the design, development
and validation of the implant cleaning process and with continuing the implementa-
tion of cleaning methods.
The risk management process involves the implant cleaning process which is
evaluated to achieve an accepted level of cleanliness, for example, controlled envi-
ronment for cleaning and the manufacturing process.
The manufacturing process of an implant includes cleaning process and possible
contaminants and its hazards, for example, the manufacturing steps are identified at
each stage and based on which the design and validation of a manufactured implant
involves cleaning process performed within a risk management system.
Hazards-related risks in cleaning are considered during the design of the clean-
ing process and when establishing design requirements for the critical cleaning pro-
cess and the final cleaning step. Annexure A identifies some of the areas which
cause possible contamination during the cleaning process and can be a harm.
Hazards-related risk assessment after the cleaning process shall be done once the
designing of the cleaning process is completed and shall include characteristics of
the implant material, manufacturing process before starting cleaning, characteristics
involved in the cleaning process and, after implementing the final cleaning, the
implant exposed to environment. Requirements for cleanliness shall be defined con-
sidering the contaminants which are intended to be removed by final cleaning step,
and additionally contaminants are introduced by the cleaning process itself.
The following minimal questions shall be addressed during a risk assessment:
(i) What is the involvement of potential contaminants associated with the implants
during the implant manufacturing process and implant cleaning process?
60 N. Palani
(ii) What are the risks involved in these contaminants during the manufacturing
and cleaning process?
(iii) What are the potential interactions involved between the contaminant sub-
stances and the implant material?
(iv) What are the implant cleaning process involved in previous steps or other oper-
ations for removing these potential contaminants from the surface?
(v) What are the potential contaminants brought in by the implant cleaning
process?
Risk assessment-based additional questions shall be addressed which are part of
the manufacturing process:
(i) What are the test methods selected for the validation of the cleaning process
able to assess the level of the potential contaminants on the implants, consider-
ing the limit and accuracy of the method?
(ii) What are the acceptance criteria for each cleaning step involved?
(iii) Following validation, what process control requirements are required to main-
tain cleanliness during manufacturing?
(iv) What are the process changes or improvements required in revalidating the
product effective cleanliness?
Based on cleanliness acceptance criteria, cleaning validation can be performed.
2.3 Design of Cleaning Process
The in-process cleaning design requirements and the final cleaning shall be defined,
based on the implant material characteristics, its intended performance and manu-
facturing process before cleaning, and also the hazards introduced by cleaning pro-
cess are analysed (refer Annexure A). The cleaning processes shall be designed
based on the cleanliness acceptance criteria of the implant material after final clean-
ing which are addressed.
The manufacturer and the cleaning subcontractor (if applicable) shall define the
in-process cleanings which are critical based on the risk analysis of the manufactur-
ing process and the in-process cleaning step during the final cleanliness of the
implant. The risk assessment shall be used to determine level of severity and num-
ber of occurrences. Subsequent activities in the design, verification and validation
of the implant manufacturing and cleaning processes (including inspection steps)
should then concentrate on the development of control measures to mitigate
these risks.
Even the drying operation which is performed at the end of the cleaning shall be
considered to be part of the cleaning.
The cleaning process shall be designed in such a way to not degrade the biocom-
patibility and the intended performance of the implant.
The cleaning process shall be designed in order to limit contamination of the

implant with cleaning agents, rinsing agents or contaminants coming from the
cleaning process itself.
The cleaning process shall be able to decrease the contaminations coming from
the previous manufacturing steps to an adequate predetermined level.
During final cleaning of implants, in order to prevent contamination of implants,
a controlled environment or protection shall be implemented between final cleaning
and packaging.
Note 1: Controlled environment does not necessarily mean the use of a clean room.
While clean rooms are usually used for implants delivered sterile, this might not
be the case for implants delivered non-sterile.
Note 2: ISO 14644 (all parts) contains information which might be useful, if clean
rooms and associated controlled environments are used.
The cleaning facilities can be chosen by the manufacturer in order to simplify
validation or verification activities of the cleaning process. The criteria for defining
the cleaning families shall be justified and documented. In an implant represented
by the worst-case specimen for a cleaning family, the manufacturer shall take the
specification of cleanliness, the ability of the implant to be cleaned as well as the
equivalence of the cleaning process of the worst-case specimen and the cleaning
process of the implant.
2.4 Validation Process
The in-process cleaning and final cleaning process shall be validated in order to
establish that the processes consistently yield implants complying with the cleanli-
ness acceptance criteria defined for final cleaning.
Note 1: Cleaning processes and agents might influence the materials, surface prop-
erties, coatings or intended performance(s) of the implant.
Note 2: Guidance for validation of processes is given in IMDRF
SG3-N99-10-2004.
The validation of the cleaning processes shall address the following (if applicable):
(a) Types of contamination to be removed which is identified during
the risk assessment
(b) Implant characteristics:
1. Implant materials
2. Implant size, shape and accessibility
(c) Cleaning steps:
1. Removing contaminations from the implant material with differ-
ent cleaning agents
2. Removing cleaning agents with rinsing agents
3. Removing rinsing agents
62 N. Palani
Validation shall be conducted on each implant. Validation shall comprise tests

which demonstrate at relevant level of the process and even at the worst-case
scenario the cleanliness requirements can be fulfilled. The process consis-
tently produces implant meeting its cleanliness acceptance criteria.
Note 3: In some cases the relevant level of the process might be both the lower and
upper, while in other cases only one of these levels might be relevant.
Note 4: ASTM F3127 provides guidance on cleaning process validation methods.
During the cleaning process, the worst-case specimen shall be used to conduct
validation under the worst-case scenarios as determined by the manufacturer or
cleaning subcontractor (if applicable). When determining the worst-case condi-
tions, each cleaning steps like cleaning, rinsing and drying shall be taken into con-
sideration. Based on the risk assessment, the manufacturer shall justify and
document why any implant or test dummy is the worst case.
As a result of the risk assessment outcomes, there shall be changes made to the
processing and manufacturing method like installations and/or parameters. The risk
assessment shall determine if the cleaning process shall be revalidated and deter-
mine the extent of the revalidation. If the implant cleaning method and the cleanli-
ness specifications or the worst-case specimen of a cleaning family is changed, the
cleaning process shall be revalidated. Cleaning validation is interconnected with the
biological evaluation and implant sterilization validation. Even if cleaning process
validation gives a high result and level of confidence risks regarding cleaning is
acceptable, the acceptability and validation of the cleaning design is only possible
after implants undergo biological evaluation according to ISO 10993-1 and implant
sterilization validation. If any new hazards are identified during this biological eval-
uation which can be mitigated by the cleaning process, the impact of these new
hazards on cleanliness acceptance criteria and cleaning validation shall be reas-
sessed. The manufacturer decides the order of cleaning validation, biological evalu-
ation and implant sterilization validation. Cleaning validations are typically
performed before or in parallel to biological evaluation and implant sterilization
validation.
Note 5: A typical order for cleaning validation, biological evaluation and implant
sterilization validation is given in Fig. 3.
Note 6: Cleanliness, microbiological contamination and biocompatibility of the
implant might be influenced by the implant packaging.
2.5 Sampling Process
A sampling plan with an appropriate number of samples shall be established as part

of the risk assessment of the cleaning process. When appropriate, sampling plans
can be based upon statistically valid rationale for number of test specimens.
Each worst-case condition shall be tested when validating under worst-case con-
ditions. At least three cleaning batches shall be tested when establishing the repro-
ducibility of the process.
2.6 Manufacturing of Test Substances
In order to establish the conformity to the requirements of this document, tests shall
be conducted on specimens manufactured, cleaned and packaged with methods and
installations and in an environment representative of or more challenging than the
manufacturing, cleaning and packaging process applied to the implant.
For the validation of critical in-process cleanings, packaging of specimens can be
required between cleaning and testing of specimens, even if a packaging is not per-
formed during the normal manufacturing at this stage. In this case, care shall be
taken to ensure that the packaging does not influence the cleanliness of the
specimens.
If a test (e.g. cytotoxicity) requires that specimens be sterilized, the sterilization
method shall be that applied for terminal sterilization (for implants delivered sterile)
or recommended for sterilization by the user (for implants delivered non-sterile).
The processing method, installations and parameters used for the manufacturing,
cleaning, packaging and sterilization (if applicable) of the test specimens shall be
documented.
2.7 Testing Methods and Efficiency
All the test methods used to demonstrate the conformity to the requirements of this
document shall be validated and documented.
Note 1: Requirements for the competence of testing laboratories can be found in
ISO/IEC 17025.
The following elements shall be documented, if applicable:
(a) Justification of the test method(s) used according to the types of
contaminant that can be present on the implant
(b) Extraction efficiency
(c) Detection limit, quantitation limit and accuracy of the method
(d) Extraction blanks and reference materials
(e) Adequacy to demonstrate the conformity to the predetermined
acceptance criteria
Note 2: Methods for the validation of analytical procedures can be found in
ICH Q2(R1).
64 N. Palani
3 leanliness Evaluation: Test Methods and Cleanliness

C
Acceptance Criteria After Final Cleaning
3.1 Detailed View
Test methods are to be considered when assessing the performance of each critical
in-process cleaning and/or final cleaning. If adequately justified, some of the tests
may be excluded based on the cleanliness requirements of the implant, the charac-
teristics of the production and/or the cleaning process, the data gathered from previ-
ous cleaning processes and the data available from history.
Based on the type of contamination that can be present on the implant, other tests
may be conducted. The preliminary cleanliness requirements shall be established by
documenting the acceptance criteria for each test. Final cleanliness requirements
shall be established after the results of the biological evaluation according to ISO
10993-1 and the results of the implant sterilization validation are available.
Note 1: For the relation between production and/or cleaning design, validation and
risk management, see Fig. 2.
Note 2: For the relation between cleaning validation, biological evaluation and
sterilization validation, see Fig. 3.
3.2 Visual Test
Acceptance criteria for visual inspection for visible contaminants remaining after
cleaning shall be established by the manufacturer of the implant.
After cleaning, the implant being inspected shall comply with the manufacturer’s
acceptance criteria.
Note: EN 13018 is one method that can be used for acceptance criteria for visual
inspection.
3.3 Bioburden Test
If the purpose of the cleaning process is to ensure that the bioburden is less than or
equal to a predetermined level, the bioburden on the implant shall be determined as
specified in ISO 11737-1.
Specimens shall not be sterilized.
The predetermined level shall be sufficiently low such that the sterilization
method specified is adequate to achieve the desired sterility assurance level.
The results shall be less than or equal to the predetermined level.
Fig. 2 The relation Implant Characteriscs and

between cleaning design,
manufacturing steps/process
validation and risk
management
Definition of cleanliness
requirements after final
cleaning of the Implant
Cleaning process
Designing phase
Risk assessment of
Activities performed within a risk management process hazards and cleaning
process
Acceptable No
risks?
Yes
Definition of the
cleanliness acceptance
criteria for final cleaning
Validation for Cleaning

process
Cleanliness
No
met with the
requirements
Yes
Process Verification for
Cleaning continuity
Complying
No Yes
with cleaning
requirements
3.4 Bacterial Endotoxins
If the purpose of the cleaning process is to reduce the bacterial endotoxin contami-
nation, then a validated test shall be conducted to measure the level of bacterial
endotoxins.
If an endotoxin limulus amoebocyte lysate (LAL) test is used, it shall be con-
ducted according to an established method described in a recognized pharmaco-
poeia after extraction from the implant with a validated method. The level of
bacterial endotoxin per implant shall be not more than 20.0 endotoxin units.
66 N. Palani
Definition of cleaning Implant

process design
Definition of cleanliness review
Definition of cleanliness based on contaminants
Yes
Cleaning
process No
Validation for Cleaning hazard
process
mitigated?
Yes
Biological Biological evaluation
contamination and according to ISO 10993-1
evaluation of the and implant sterilization Hazard in No
implant packaging implant
contamination?
Biological No
Acceptable
risks?
Yes
Validation for Cleaning

process
Fig. 3 Shows how cleaning validation, biological evaluation and sterilization validation are related
Note 1: Orthopaedic implants are not usually in contact with cerebrospinal fluid. In
case of contact with cerebrospinal fluid, other limits can apply.
Note 2: AAMI ST72 gives helpful assistance for selection of test methods and
acceptable levels of endotoxin contamination. It also gives helpful information
on the effect of sterilization on endotoxin contamination.
Note 3: European Pharmacopoeia, Section 2.6.14, and USP, Section <85>, present
appropriate methods for LAL testing.
3.5 Organic Contaminants

Detailed View
For chemical analysis of organic contaminants, a number of methods can be consid-

ered as common practice. Each method possesses advantages and disadvantages
and might not detect all organic contaminants possible in the production of ortho-
paedic implants and/or introduced by the cleaning process.
Selection of the method(s) to be applied shall be based on, at least:

(a) Type of contamination that can be present on the implants
(b) Type of implant material(s)
(c) Sensitivity of the analytical method
The total organic carbon (TOC) method or another suitable method shall be used for
detection of water-soluble organic contaminants.
The total hydrocarbons (THC) method or another suitable method shall be used
for detection of hydrocarbons soluble in non-polar solvents, unless there is no risk
of contamination with hydrocarbons.
Requirements for extraction and detection for the TOC and THC methods are
described.
Note 1: Some implant intrinsic materials might release organic contaminants in the
extraction solvent, and it might be necessary to implement adequate procedures
to differentiate between intrinsic materials of the implant and contaminants.
The tests may be conducted on either sterilized or non-sterilized specimens.
Note 2: Sterilization can have an influence on type and number of organic contami-
nants resulting out of production and/or cleaning.
Biological evaluation data from devices with known organic contamination, manu-
factured with similar materials and manufacturing and cleaning processes, may
be used to establish preliminary or, if appropriate, final acceptance levels for
organic contaminants.
Note 3: TOC and THC methods are able to detect a large spectrum of organic con-
taminants without the possibility of identification of specific contaminants. For
the TOC method, water is used for extraction, which results in reduced exhaus-
tiveness with respect to non-polar contaminants. Both methods are useful to
demonstrate, during the cleaning validation, that the process is under control.
They do not intend to demonstrate that specific organic contaminants are non-
toxic or are non-critical with respect to biological effects. If a company has no
historical data on TOC or THC tests that can be related to a corresponding
biological evaluation, the limits set forth in NF S94-091 (0,500 mg per implant
for TOC and 0,500 mg per implant for THC) can serve as a starting point for
acceptance levels. Specific organic contaminants can already be critical in con-
centrations significantly below the limits given by NF S94-091. Both type and
amount of the single organic contaminants are relevant.
Note 4: One common approach is to first quantify the contamination. Subsequent
identification of the contaminants can be helpful to understand the type of con-
tamination (e.g. in case of untypically high contamination). However, the identi-
fication before quantification of contamination can be helpful to define allowable
limits of contamination.
68 N. Palani
Extraction Method
Organic contamination shall be determined after exhaustive extraction from the

implant using an appropriate solvent.
For water-soluble organic contaminants, water of sufficient purity not to interfere
with the test method shall be used as a solvent.
For hydrocarbon contaminants, non-polar solvents are preferable for extraction
and should be used. The solvent used for THC tests shall be chosen in order not to
decompose the tested material and in order to avoid leaching from the material. If
compatible with the material, hexane or halogenated solvents may be used. For
example, for UHMWPE and PEEK implants propyl alcohol may also be used
despite being a low-polar solvent.
Care shall be taken that the equipment to be used for extraction does not interfere
with the solvent.
The extraction conditions shall be justified.
Note 1: Extraction methods can be found in ISO 10993-12, ASTM F2459 or
ASTM G136.
The exhaustiveness of extraction shall be demonstrated.
Note 2: When the quantity extracted is below the quantification limit after the first
extraction, it can be considered that exhaustiveness of extraction has been
demonstrated.
The exhaustiveness of extraction conditions shall be verified on the worst-case spec-
imen prior to finalizing testing on the cleaning family.
Detection Method
Detection including quantitation and/or identification of organic contamination as

selected shall be performed by validated methods.
The TOC, if investigated, shall be determined in the extracts and shall be quanti-
fied using such methods as described in EN 1484, European Pharmacopoeia 2.2.44
or USP <643>.
The THC, if investigated, shall be determined in the extracts and shall be quanti-
fied using methods such as gas chromatography as described in ISO 9377-2, Fourier
transform infrared spectroscopy (FTIR) as described in ASTM D7066-04 or another
validated test method.
3.6 Inorganic Contaminants
The inorganic contaminants likely to be present on the implant shall be identified

during the risk assessment as required.
The inorganic contaminants identified to be critical in the risk assessment shall

be determined after exhaustive extraction from the implant using water, water sup-
plemented with acid or another adequate solvent, if justified.
Care shall be taken that the equipment to be used for extraction does not interfere
with the solvent.
The extraction conditions shall be justified.
Note 1: Extraction methods can be found in ISO 10993-12, ASTM F2459 or
ASTM G136.
The exhaustiveness of extraction shall be demonstrated.
Note 2: When the quantity extracted is below the quantification limit after the first
extraction, it can be considered that exhaustiveness of extraction has been
demonstrated.
The exhaustiveness of extraction conditions shall be verified on the worst-case spec-
imen prior to finalizing testing on the cleaning family.
Note 3: Some implant intrinsic materials might release inorganic contaminants in
the extraction medium, and it might be necessary to implement adequate proce-
dures to differentiate between intrinsic materials of the implant and
contaminants.
After extraction, a suitable method shall be used in order to assess inorganic con-
taminants. Examples of suitable methods are:
(a) Inductively coupled plasma in combination with atomic or opti-
cal emission spectrometry
(b) Inductively coupled plasma in combination with mass
spectrometry
(c) Ionic chromatography
(d) Ionic chromatography in combination with mass spectrometry
Note 4: If water is used for extraction, the conductivity of the extract can be used to
indicate soluble ionic species contamination before using more specific test
methods.
The inorganic contaminant acceptance levels shall be determined using the data on
the biological effects of each inorganic contaminant.
Note 5: A possible method for determining allowable limits for inorganic contami-
nants is provided in ISO 10993-17. Acceptance criteria for elemental impurities
can also be found in ICH Q3D.
3.7 Particulate Contamination
If the purpose is to demonstrate cleanliness regarding particulate contaminants, then

corresponding investigations shall be conducted.
Selection of type and sensitivity of the test shall be performed based on the
results of the risk management process. If extraction is conducted, care shall be
70 N. Palani
taken to avoid particles produced as a result of mechanical forces applied during the
extraction process.
Note: AAMI TIR42 deals with the evaluation of particulates associated with vas-
cular implants. However, AAMI TIR42:2010, Clause 8 and Annex A give helpful
assistance for selection of acceptable levels and test methods of particulate con-
tamination that could be applied to other types of implants.
3.8 Cytotoxicity
The cytotoxicity of the orthopaedic implant shall be determined using a method

described in ISO 10993-5. The specimens shall be sterilized.
Any orthopaedic implant demonstrating a cytotoxic effect as defined in ISO
10993-5 shall be investigated to determine the cause of the cytotoxic effect. If this
effect is related to contamination not removed by the cleaning process or to the
cleaning process itself, control measures to mitigate this risk shall be implemented.
Note: Cytotoxicity is usually part of the biological evaluation of the implant as per
ISO 10993-1. It is a useful in vitro test, sensitive to many types of contaminants,
which can be used to assess the effectiveness of the cleaning process. However,
even if a cytotoxic effect is observed, this might not be related to the cleaning
process, and other root causes might have to be investigated.
4 Cleaning Validation
Guidance on setting the acceptance criteria and what types of residuals to look for
in a cleaning validation, every manufacturer has a defined set of tests and accep-
tance criteria based on the regulations to screen for potential contaminants and
residuals.
The tests allowed to be part of the manufacturing process are based on the risk
and acceptance criteria of the device using the below steps:
• Risk analysis of the manufacturing process to identify most critical contaminants
and residuals
• Selection of analytical tests that can detect targeted residuals
• Selection of a sampling strategy to get results based on the correct and meaning-
ful set of data
• Development of acceptance criteria based on assessment of patient safety, his-
torical data of device and patient, toxicological risk assessment or biocompatibil-
ity tests
The exact method to determine how clean enough the implant is has been a chal-
lenging measurement with the validation process. The acceptance criteria are set
based on the analytical results from measuring the cleanliness to those tests that
provide an indication of device safety (like cytotoxicity testing). However, the dif-
ficulty with using a simple biocompatibility test to set acceptance criteria is that
there are occasions where a device may be safe, but not clean, and occasions when
a device may be clean, but not safe.
Cytotoxicity testing has commonly been used as an indicator that device cleanli-
ness is acceptable, and because cytotoxicity testing is an extremely sensitive test,
this does provide a good general indication of cleanliness. However, it should not be
assumed that passing cytotoxicity equals safety. There is, after all, a whole suite of
biocompatibility tests addressing biological risks outside of cytotoxicity that are
necessary to support safety.
If passing a cleaning validation does not provide an indication of patient safety,
and the analytical methods used for cleaning validations are not appropriate or sen-
sitive enough for toxicological risk assessment, perhaps the previous ways of setting
acceptance criteria for cleanliness are misguided.
Understanding that demonstrating device safety is a task separate from validat-
ing cleanliness, ISO 19227 prescribes a set of tests for demonstrating cleanliness
along with acceptance criteria broadly applicable to orthopaedic implants. These
tests and acceptance criteria (where specified) are outlined below:
• Visual test – acceptable when meeting specifications of the manufacturer
• Bioburden test – acceptable when the level of specified sterility assurance is met
• Bacterial endotoxin – acceptable when less than 20.0 endotoxin units
• Total organic carbon (TOC) – acceptable when less than 500 μg/device
• Total hydrocarbon content (THC) – acceptable when less than 500 μg/device
• Metals – acceptable when less than limits established by ICH Q3D or 10993-17
• Cytotoxicity – acceptable when passing per 10993-5
The most significant takeaways from ISO 19227 are the suggested acceptance
criteria for common analytical tests that have, up to now, been difficult to interpret
as they do not have the specificity and sensitivity to adequately indicate safety.
Separating the ideas of safety from cleanliness helps to keep the determination of
safety within the realm of biocompatibility per ISO 10993 and allows manufactur-
ers to set common-sense acceptance criteria in situations where criteria based on
biocompatibility do not make sense.
Ultimately, for cleanliness of final finished devices, the points of greatest value
of a cleaning validation per ISO 19227 are to demonstrate control over processing,
know the level of cleanliness at the time biocompatibility was established and then
track cleanliness looking for unexpected changes using routine monitoring to know
when biocompatibility might be in question.
72 N. Palani
5 Continued Process Verification (CPV)
To ensure the fulfillment of defined cleanliness requirements, a routine monitoring

of the critical process parameters and/or process environment, according to docu-
mented procedures, shall be implemented.
Routine control testing of the cleaning processes shall be established as part of
the quality management system to document the type and time interval for each
periodic test.
The frequency for performing each test shall be determined considering the
reproducibility of the process, the risks related to any contaminants as well as the
frequency and volume of manufacture.
6 Documentation
All documents and records required to demonstrate conformity to this document

shall be established and maintained in a manner consistent with the requirements of
the manufacturer’s quality management system.
nnexure A: (Informative) Potential Sources of Harm

A
in a Cleaning Process
During the design of a cleaning process, at least the hazards relating to the following
characteristics should be considered:
–– Shape of implants and accessibility of its different surfaces
–– Constitutive material(s) of the implant
–– Contamination of the implant before cleaning
–– Physical-chemical characteristics of the implant
–– Cleaning techniques
–– Materials coming into contact with implants
–– Cleaning equipment, fixtures, baskets and control systems
–– Maintenance methods and frequency
–– Cleaning agent/compounds used
–– Concentration of the cleaning agent
–– Purity and potential toxicity of the liquid agents, especially for the last cleaning
or rinsing steps
–– Action of the cleaning agent on bacteria and fungi
–– Action of the cleaning agent on physicochemical contamination
–– Cleaning temperature
–– Mechanical effects during cleaning (ultrasound, agitation and spraying)
–– Position of implants during cleaning, rinsing and drying

–– Load of the cleaning unit
–– Cleaning time
–– Renewing of the cleaning agent
–– Succession of the cleaning and rinsing steps
–– Rinsing agent used
–– Rinsing temperature
–– Mechanical effects during rinsing
–– Renewing of the rinsing agent
–– Rinsing time, flow and volume
–– Drying method
–– Drying temperature
–– Drying time
–– Aeration, HEPA filtration, air locks, cascading air pressurization
References
1. ISO 10993-12, Biological evaluation of medical devices—Part 12: Sample preparation and
reference materials
2. ISO 10993-17, Biological evaluation of medical devices—Part 17: Establishment of allowable
limits for leachable substances
3. ISO 14644 (all parts), Cleanrooms and associated controlled environments
4. ISO 14971, Medical devices—Application of risk management to medical devices
5. ASTM F3127, Standard guide for validating cleaning processes used during the manufacture
of medical devices
6. NF S94-091, Implants for surgery—Validation requirements for cleaning process of orthopae-
dic implants before final packaging
7. IMDRF SG3/N99-10:2004, Quality Management Systems—Process Validation Guidance
8. European pharmacopeia 2.2.44, Total organic carbon in water for pharmaceutical use
9. European Pharmacopoeia 2.6.14, Bacterial endotoxins.
10. ISO 9377-2, Water quality—Determination of hydrocarbon oil index—Part 2: Method using
solvent extraction and gas chromatography
11. ISO 10993-1, Biological evaluation of medical devices—Part 1: Evaluation and testing within
a risk management system
12. ISO 10993-5, Biological evaluation of medical devices—Part 5: Tests for in vitro cytotoxicity
13. ISO 11737-1, Sterilization of medical devices—Microbiological methods—Part 1:
Determination of a population of microorganisms on products
14. ASTM D7066-04, Standard Test Method for dimer/trimer of chlorotrifluoroethylene (S-316)
Recoverable Oil and Grease and Nonpolar Material by Infrared Determination
15. BS_ISO_19227 Implants for Surgery—Cleanliness of orthopedic implants—General
Requirements
16. ISO and IEC maintain terminological databases for use in standardization at the following
addresses: IEC Electropedia: available at http://www.electropedia.org/; ISO Online browsing
platform: available at https://www.iso.org/obp
ISO 21534: Non-active Surgical
Implants – Joint Replacement Implants

Abbreviations
ANT Anterior
KGy Kilogray
NPL National Physical Laboratory
POST Posterior
UHMWPE Ultrahigh-molecular-weight polyethylene
Highlights
• The chapter provides information on ISO and EU regulatory process involved in
the joint replacement implants manufacturing process.
• It also explains the importance of material analysis in the design and develop-
ment of non-active surgical implant devices.
1 Scope
This international standard specifies particular requirements for total and partial
joint replacement implants, artificial ligaments and bone cement, hereafter referred
to as implants. For the purposes of this international standard, artificial ligaments
and their associated fixing devices are included in the term “implant”. It specifies
requirements for intended performance, design attributes, materials, design evalua-
tion, manufacturing, sterilization, packaging and information to be supplied by the
T. Sampath (*)
S. Thamizharasan

manufacturer. The latest version of BS EN ISO 21534:2009 (Non-active surgical

implants. Joint replacement implants. Particular requirements) was approved by
CEN which is published on 31 October 2009. It is identical to ISO 21534:2007.
2 Normative References
The following referenced documents are indispensable for the application of this
document.
ISO 4287: Geometrical Product Specifications (GPS) Profile method – Terms, defi-
nitions and surface texture parameters
ISO 7206-4: Partial and total hip joint prostheses – Determination of endurance
properties of stemmed femoral components
ISO 7206-8: Partial and total hip joint prostheses – Methods of determining endur-
ance performance of stemmed femoral components
ISO 14155-1: Clinical investigation of medical devices for human subjects – General
requirements
ISO 14242-1: Wear of total hip-joint prostheses – Loading and displacement param-
eters for wear-testing machines and corresponding environmental conditions
for test
ISO 14242-2: Wear of total hip-joint prostheses – Methods of measurement
ISO 14243-2: Wear of total knee-joint prostheses – Methods of measurement
ISO 14630-1: Non-active surgical implants – General requirements
ISO 14879-1: Total knee-joint prostheses – Determination of endurance properties
of knee tibial trays
Artificial ligament device: including its necessary fixing devices, intended to aug-
ment or replace the natural ligament
Joint replacement implant: implantable device including ancillary implanted com-
ponents and materials, intended to provide function similar to a natural joint and
which is connected to the corresponding bones
Mean centre: position within the spherical head for which the average of the dis-
tances to a set of points uniformly distributed over the surface of the sphere
is minimum
Radial separation value: difference between the mean radius of the spherical sur-
face and the radius to the point on the spherical surface furthest from the
mean centre
ISO 21534: Non-active Surgical Implants – Joint Replacement Implants 77
4 Intended Performance
For the purpose of this international standard, the intended performance of implants
shall conform to Clause 4 of ISO 14630, and the design input shall additionally
address the following matters:
–– Intended minimum and maximum relative angular movement between the skel-
etal parts to which the joint replacement implant is attached
–– Expected maximum load actions (forces and moments) to be transmitted to the
bony parts to which the joint replacement implant is attached
–– Dynamic response of the body to the shape/stiffness of the implants
–– Expected wear of articulating surfaces
–– Suitability of the dimensions and shape of the implant for the population for
which it is intended
–– Strength of the adhesion and durability of surface coatings or surface treatments
–– The clinical indications and contra-indications for the use of a particular implant
are complex and should be reviewed by the surgeons when they are selecting
implants to be used for particular patients, relying upon their own personal judg-
ment and experience. The lifetime of an implant depends on the interaction of
various factors; some are the responsibility of the manufacturer, some, such as
the implantation technique, are the responsibility of the surgeon in conducting
the operation, and some relate to the patient, for example, the biological and
physiological response to the implant, the medical condition of the patient, the
conduct of the patient in respect of increasing body weight, carriage of heavy
loads and adopting a high level of physical activity.
5 Design Attributes
The development of the design attributes to meet the performance intended by the
manufacturer shall conform to the requirements of Clause 5 of ISO 14630, and in
addition, account shall be taken of the following points:
–– The strength of adhesion and durability of surface coatings and surface treatments
–– The wear of the articulating and other surfaces
–– Stability of the implant while allowing prescribed minimum and maximum rela-
tive movements between the skeletal parts
–– Avoidance of cutting or abrading tissue during function other than insertion
or removal
–– The creep resistance and rupture characteristics, particularly as they relate to
ligaments
Methods of assessment of the wear of articulating and other surfaces are pre-
scribed in ISO 14242 and ISO 14243 (Table 1).
Table 1 Surface finish of metallic or ceramic partial implants

Articulating surfaces of metallic or ceramic Surface roughness Radial separation
components value value
Total joint replacement >0, 1 μm
Partial joint replacement >0, 5 μm
Convex spherically total joint replacement >0, 05 μm >10 μm
Spherically partial joint replacement >0, 5 μm >100 μm
Concave spherically total joint replacement >2 μm >200 μm
6 Materials
ISO 14630 states that the acceptability of materials may be demonstrated by selec-
tion from the materials found suitable by proven clinical use in similar applications;
for the purposes of this international standard, proven use should be demonstrated
by records of implantation of at least 500 of the implants and recorded satisfactory
clinical use over a period of not less than 5 years. The list of international standards
for materials found acceptable through proven use for the manufacture of implants
or for use in association with implants is given below (Table 2).
For the articulating surfaces of joint replacement implants, the following combi-
nations of the materials are listed below. They have been found to be acceptable in
particular applications provided adequate attention is given to design, surface finish
and surface treatment (Table 3).
Dissimilar Metals or Alloys
For applications in which two dissimilar metals or alloys or the same metals or
alloys in different metallurgical states are in contact where articulation is not
intended, combinations used shall not produce unacceptable galvanic effects. For
applications where one metal or alloy is in contact with another and articulation is
not intended, the following metallic combinations involving the metals listed in
Table 1 have been found to be acceptable and can be used provided adequate atten-
tion is given to design, surface finish, surface treatment and metallurgical condi-
tions. The international standards for acceptable and unacceptable metallic
combinations for use in non-articulating bearing surfaces of implants are listed
below (Table 4).
7 Design Evaluation
Joint replacement implants shall be evaluated in order to demonstrate that the

intended performance is achieved. This evaluation shall be in accordance with
Clause 7 of ISO 14630 together with the particular requirements. This evaluation
shall be undertaken using components fully representative of the final condition
ready for implantation.
Table 2 Materials used in joint replacement implants

International
standard for
materials Acceptable material for the manufacture of implants
ISO 5832 Wrought stainless steel, unalloyed titanium, wrought titanium 6-aluminium
4-vanadium alloy, cobalt-chromium-molybdenum casting alloy, wrought
cobalt-chromium-tungsten-nickel alloy, wrought cobalt-nickel-chromium-
molybdenum alloy, forgeable and cold-formed cobalt-chromium nickel-
molybdenum-iron alloy, wrought cobalt-nickel-chromium
molybdenum-tungsten-iron alloy, wrought high nitrogen stainless steel,
wrought titanium 6-aluminium 7-niobium alloy, wrought cobalt-chromium-
molybdenum alloy
ISO 5833 Acrylic resin cements
ISO 5834 Ultrahigh-molecular-weight polyethylene (powder and moulded forms)
ISO 6474 Ceramic materials based on high purity alumina
ISO 13356 Ceramic materials based on yttria-stabilized tetragonal zirconia (Y-TZP),
ceramic hydroxyapatite
ISO 13779 Coatings of hydroxyapatite
Table 3 List of international standards for materials found acceptable or not acceptable for
articulating surfaces of implants
Unsuitable combinations of
Suitable material combinations for articulating surfaces materials for articulating surfaces
(a) Wrought stainless steel/UHMWPE (a) Stainless steel/titanium-based
(b) Wrought high nitrogen stainless steel/UHMWPE alloy
(c) Cobalt-chromium-molybdenum casting alloy/ (b) Stainless steel/stainless steel
UHMWPE (c) Stainless steel/unalloyed
(d) Wrought cobalt-chromium tungsten-nickel alloy/ titanium
UHMWPE (d) Stainless steel/cobalt-based
(e) Forgeable and cold-formed cobalt-chromium-nickel- alloys
molybdenum-iron alloy/UHMWPE (e) Unalloyed titanium/unalloyed
(f) Wrought cobalt-nickel-chromium-molybdenum- titanium
tungsten-iron alloy/UHMWPE, wrought titanium (f) Unalloyed titanium/titanium-
6-aluminium 4-vanadium alloy 2/UHMWPE based alloys
(g) Wrought titanium 6-aluminium 7-niobium alloy/ (g) Unalloyed titanium/cobalt-
UHMWPE based alloys
(h) Ceramic materials based on alumina 2/UHMWPE (h) Unalloyed titanium/UHMWPE
(i) Ceramic materials based on zirconia/UHMWPE (i) Titanium-based alloys/
(j) Ceramic materials based on alumina/ceramic materials cobalt-based alloys
based on alumina
(k) Forgeable and cold-formed cobalt-chromium-nickel-
molybdenum-iron alloy/forgeable and cold-formed
cobalt-chromium-nickel-molybdenum-iron alloy
(l) Wrought cobalt-chromium-molybdenum alloy/
cobalt-chromium-molybdenum casting alloy
(m) Wrought cobalt-nickel-chromium-molybdenum alloy/
UHMWPE
(n) Wrought cobalt-chromium-molybdenum alloy/
UHMWPE
Table 4 List of materials found acceptable or non-acceptable for metallic combinations for non-
articulating contacting surfaces of implants
Suitable combinations of dissimilar metals for Non-acceptable metallic combinations for
non-articulating contacting surfaces non-articulating contacting surfaces
(a) Cobalt-based alloys/titanium-based alloys (a) Stainless steel/cobalt-based alloys
(b) Cobalt-based alloys/other cobalt-based (b) Stainless steel/unalloyed titanium
alloys
(c) Stainless steel/titanium-based alloys
(d) Stainless steel/stainless steel
(e) Stainless steel/cobalt-based alloys
Preclinical evaluation shall consider:

–– Biocompatibility of any materials not previously used.
–– Mechanical loads and the related movements to which the implants can be sub-
jected when functioning as prescribed by ISO 14630.
–– Fatigue testing of highly stressed parts in accordance with ISO 7206-4, ISO
7206-8 and ISO 14879-1.
–– Wear testing of articulating bearing surfaces in accordance with, e.g. ISO
14242-1, ISO 14242-2 and ISO 14243-1.
–– The suitability of the dimensions and shape of the implant for the intended popu-
lation. The suitability of the dimensions and shape of the implant for the intended
population can be demonstrated by cadaver implantation; the use of imaging
systems such as X-ray, CAT scan or magnetic resonance imaging; or reference to
corresponding implants of proven clinical use.
–– Adhesion and durability of coatings if present.
Surface roughness measurement: Surface roughness shall be measured accord-
ing to one of the methods given in ISO 4287.
Sphericity measurement: Radial separation values for sphericity shall be measured
according to a method demonstrated to be accurate and repeatable. A suitable
method is described in the NPL.
Clinical investigation: The clinical investigation shall be conducted according to the
general requirements of ISO 14155-1.
Post-market surveillance: The post-market performance of joint replacement
implants shall be determined. Suitable methodologies include survival analysis
(with revision as the endpoint) and clinical assessment. Where it is available,
relevant information from joint replacement registries are taken into account.
8 Manufacture and Inspection
Metal Surfaces
All polishing operations on metallic components shall be performed using an
iron-free material. Clean, degrease, rinse and dry all components and examine the
articulating surfaces using normal or corrected vision. The surfaces shall be free of
any imperfections that would impair their function and also be free from deposited
finishing materials or other contaminants. Examples of imperfections which might
impair function include scale, tool marks, nicks, scratches, cracks, cavities, burrs
and other defects.
Plastic Surfaces
Articulating surfaces of plastic components shall not be prepared using non-
removable abrasive or polishing compounds. Clean, degrease (if necessary), rinse
and dry the components and examine them using normal or corrected vision. The
surfaces shall be free from particulate contamination.
Ceramic Surfaces
Ceramic components shall be cleaned, degreased, rinsed, dried and examined
using normal or corrected vision. The articulating surfaces shall be free of any
imperfections that would impair their function. Examples of imperfections which
might impair function include particulate contamination, chemical discolouration
(spots or larger areas), tool marks, nicks, chips, cavities and cracks.
9 Sterilization
The effects of the sterilization process shall not impair the intended performance of
the implant. Implants containing UHMWPE and sterilized by ionizing radiation
shall not be supplied for clinical use if an accumulated dose of radiation higher than
40 kGy has been received. This requirement does not apply if radiation intended to
improve the mechanical characteristics of the material is combined with the radia-
tion for sterilization purposes. The manufacturer shall conduct an investigation, and
record the results, to ascertain the expiry date to be marked on the labelling for the
implant.
10 ackaging and Information Supplied by

P
the Manufacturer
Labelling of Implants
Labelling for implants designed for use on one side of the body only shall bear
the symbol “LEFT'” or “L” for implants to be used on the left side or “RIGHT” or
“R” for implants to be used on the right side.
Table 5 Labelling of implants for use with or without bone cement

Implants usage Primary legend Alternative legend
Implants intended to be used with bone For use with cement Cemented
cement
Implants intended to be used without bone Uncemented Cementless
cement
Implants intended to be used optionally Use with cement or No legend
uncemented
Instructions for Orientation of Implants

The instruction leaflet and/or manual shall, where necessary, indicate the required
orientation of the implant relative to the body part. It shall also refer to the relevant
marking(s) on the implant or the label.
Markings for Orientation of the Implants
The implant shall bear the symbol “ANT” on the front and/or “POST” on the
back where this is necessary for interpretation of the instructions relating to the
required orientation of the implant relative to the body given in the instruction leaf-
let and/or manual.
Placing of Markings on Implants
Markings shall be placed on the implant where they will not impair its intended
function.
Restrictions on Use
If an implant is intended for a restricted population, this shall be stated in the
instructions for use or in the manual.
Re-sterilization of Zirconia Ceramics
Components manufactured from zirconia ceramics shall include an instruction
advising users “Do not sterilize using moist heat”.
Labelling for implants shall bear an appropriate legend as shown in Table 5.
Reference
1. EN ISO 21534:2009 – Non-active surgical implants – Joint replacement implants. CEN,

31.09.2009.
ISO 16061: Instrumentation for Use
in Association with Non-active Surgical
Implants—General Requirements
Karnika Singh
1 Introduction
ISO 16061 lays out the general requirements for instruments that are used in coop-
eration with “non-active surgical implants”. These requirements are applied to
instruments during the time of manufacturing and refurbishment. This ISO is also
applicable to power-driven instruments, but not to the power source itself. The
safety requirements included in this ISO are associated with intended performance
of the device, design, material, manufacturing, sterilization, packaging, and infor-
mation provided by the manufacturer. ISO 16061 does not apply to instruments
related to dental implants, transendodontic and transradicular implants, and oph-
thalmic implants. The ISO 16061:2015 is the latest version of this ISO.
2.1 Associated Implant
It is a non-active surgical implant that is used along with the intended instrument
during a surgical procedure.
K. Singh (*)

84 K. Singh
2.2 Instrument
It is a non-active medical device associated with a respective non-active surgical

implant that is utilized during surgical procedures.
2.3 Resupplied Instrument
This refers to instrument or set of instruments that were returned to the manufac-
turer and have been issued again.
3 Intended Performance
The “intended performance” of an instrument would be defined with the following

things in mind, in terms of safety, and documented as well:
(i) Functional characteristics
(ii) Intended circumstances for use
The published standards, published clinical and scientific literature, and vali-
dated test results should be taken into account. Also the extent to which the intended
performance of the instrument was reached would also be determined.
4 Design Attributes
The design attributes of an instrument would be evolved keeping in mind its intended
performance as defined by the manufacturer. The following things should be taken
into account while deciding the design attributes:
1. Physical, mechanical, and chemical properties of the materials used in the
instrument
2. Contamination levels of microbiological and particulate materials
3. Ease of use, cleaning, and maintenance
4. Expected degradation of the material characteristics because of sterilization
and storage
5. Impact of contact between the instrument and body, the implant, and other
instruments
6. Shape and dimensions of the instrument itself, along with their desirable effects
on the body
7. Wear properties of materials and its consequences on the instrument itself and
its body
ISO 16061: Instrumentation for Use in Association with Non-active Surgical… 85
8. Insertion, removal, and interconnection of parts

9. Degree of fluid leakage and/or diffusion of materials into and out of instruments
10. Efficiency and stability of instruments intended for measurement
11. Capability of the instrument or part of instrument that would be located by
means of an external imaging device
12. Compatibility with any medicinal element incorporated put into or used with
the instrument
5 Selection of Materials
The materials to be used in the instrument shall be chosen with reference to the
properties to be incorporated in the instrument so that it serves the intended purpose.
The following things should be taken into consideration: effects of manufacturing,
handling, sterilization, and storage along with any treatment (chemical, electro-
chemical, thermal, mechanical, etc.) put on the surface or some surface of the instru-
ment for modifying its properties. Potential reactions of instrument materials that
may happen with human tissues and body fluids should be taken into account. The
relevance of a given material for a particular application will be determined by:
(i) Documented evaluation in accordance with ISO 109993-1.
(ii) Choosing from the materials found suitable by proven clinical use in related
applications. The list of some materials can be found in Annex A attached with
the original ISO 16061 document.
6 Design Evaluation
6.1 General
Instruments would be evaluated along with the implant they are designed for so that
it can be demonstrated that the intended purpose of the instrument has been real-
ized. For safety demonstration, preclinical evaluation and risk analysis would be
done according to ISO 14971.
6.2 Preclinical Evaluation
If preclinical evaluation is needed, the testing conditions would be similar to those

of intended use.
86 K. Singh
6.3 Clinical Evaluation
The required clinical evaluation would be placed on the following:

(i) Critical assessment of appropriate scientific and clinical literature related to
safety, performance, design characteristics, and intended use of the instrument
or established similar instruments
(ii) Critical assessment of all the results obtained from all clinical investigations
conducted with the associated implant under the intended conditions for use
(iii) Association of the clinical data provided in (i) and (ii) above
Whenever a clinical study is performed, it will be managed according to
ISO 14155.
7 Manufacture
Instruments will be manufactured according to specifications of the required design

attributes.
8 Sterilization
8.1 Products Supplied Sterile
In order for an instrument to be labelled “STERILE” (terminally sterilized instru-

ment), the probability of the presence of a viable microorganism on the instrument
has to be equal or less than 1 X 10-6 at least in theory. Manufacturers are allowed to
use other sterility assurance levels, as long as it is supported by a documented risk
assessment. The ethylene oxide sterilization would be done in accordance with ISO
11135. The sterilization by irradiation would be done according to ISO 11137-1,
ISO 11137-2, and ISO 11137-3. If sterilization were to be done by moist heat, it
would be done according to ISO 17665-1.
8.2 Products Provided Non-sterile
For such instruments the manufacturer has to specify at least one relevant steriliza-
tion method that does not negatively affect the functional safety of the product. The
restriction of no multiple sterilizations shall be informed. For the instruments that
are marked non-sterile or declared to have the ability to be sterilized again, the
manufacturer will provide information about handling such instruments according
to ISO 17664.
9 Packaging
9.1 Protection from Damage in Storage and Transport
The packaging has to be custom designed for each instrument for conditions speci-
fied by the manufacturer for storage, transport, and handling (including temperature
control, humidity, and ambient pressure, if applicable). The packaging has to ensure
that it will protect the instrument against damage and deterioration but at the same
time does not unfavourably affect the intended performance of the instrument.
9.2 Maintenance of Sterility in Transit
The instruments that are labelled “STERILE” would be packaged in a way that they
stay sterile under normal storage, transport, and handling conditions with the excep-
tion of damaged protective packaging or opened. The packaging has to comply with
ISO 11607-1 and ISO 11607-2.
10 Information Supplied by the Manufacturer
10.1 General
Any information that is supplied by the manufacturer intended for direct visual
recognition should be easy to read under illumination of 215 lx by normal vision,
corrected vision if applicable, from a distance that includes the form and size of the
individual instrument. If the space were limiting on the instrument’s individual
packaging, the appropriate information would be given on an insert, accompanying
document, or on the next coating of packaging, as relevant. The markings on small
or specialized instruments that are not visible by the eye need to be made recogniz-
able by using electronic methods, etc. Wherever relevant, symbols, abbreviations,
and identification colour can be used in the labelling and accompanying documents
of the instruments. All these elements (symbols, abbreviations, colours, etc.) should
comply with ISO 15223-1. If there are no standards available for such usage, then
manufacturer would describe each entity used, in the supplied documentation. All
the information supplied by the manufacturer has to be clear such that it is not con-
fused with other important information. It should be understandable to the intended
user or people in general.
All units of measurement shall be indicated in SI units according to ISO 80000-1.
Comparable units can be stated in parenthesis. The safety information of the instru-
ment should be put on the instrument itself as far as possible. It can also be put on
individual packaging or sales packaging if required. If neither of the above options
88 K. Singh
is feasible, this information should be supplied in the leaflet accompanying each

instrument or unit. Wherever relevant, the instruments containing user adjustable
control would clearly specify the function of each control. All the detachable com-
ponents that are intended for usage separately from the original instrument would be
identified by their batch code or by other relevant method. The format of any date
would be YYYY-MM-DD, or YYYY-MM, or YYYY, complying with ISO 8601.
11 Labeling
The label should contain the following information:

(i) If the package holds any radioactive substance, it should have the appropriate
marking specifying the type and activity of the radioactive substance.
(ii) Name and address of the manufacturer, comprising the city and the country
at least.
Description of the instrument, its model designation, if possible, the batch
number/serial number of the instrument followed by a relevant identification,
for example, “LOT”, “SN”, or the lot, or serial number symbols ISO
7000-2492 and ISO 7000-2498, respectively. See ISO 15223-1:2012, 5.14
and 5.16.
(iii) A clear statement describing the intended purpose of the instrument so that it
is not at all unclear to the user.
(iv) In the case of a terminally sterilized instrument, the contents that are steril-
ized should be indicated along with the method of sterilization, for example,
the word “STERILE” or the sterile symbol ISO 7000-2499, or one of the
“sterilized using…” symbols ISO 7000-2500, ISO 7000-2501, ISO
7000-2502, and ISO 7000-2503. See ISO 15223-1:2012, 5.20 or 5.21, 5.22,
5.23, and 5.24.
(v) If two identical or similar instruments are sold as both sterile and non-sterile,
it has to be clearly indicated on the contents of particular package if they are
non-sterile, wherever appropriate, for example, the “non-sterile” symbol ISO
7000-2609. See ISO 15223-1:2012, 5.26.
(vi) The “use by date” should be expressed as year and month, for example, the
“use by date” symbol ISO 7000-2607. See ISO 15223-1:2012, 5.12.
(vii) It should be clearly indicated when the instrument is intended only for a sin-
gle use, for example, the “do not reuse” symbol ISO 7000-1051. See ISO
15223-1:2012, 5.2.
(viii) Indicate any specific storage and/or handling conditions.
(ix) Specific operating instructions.
(x) Any warnings or precautions associated with the usage.
12 Instructions for Use
The instructions for use should contain the following information wherever relevant:
(i) The presence of any radioactive substance in the package along with its type
and activity.
(ii) Contact details of the manufacturer with the city, country, and tele-
phone number.
(iii) Instrument description and its model designation.
(iv) The intended purpose of the instrument should be clearly specified.
(v) The intended performance discussed in clause 4 and any relevant side
effects.
(vi) Enough information to allow the user to choose a suitable instrument for
themselves. Such information should include the instrument size, its acces-
sories, related devices, etc. so that the user can get a safe combination.
(vii) If the instrument is terminally sterile, it should be indicated on the contents
of the package along with the method of sterilization, for example, the word
“STERILE” or the sterile symbol ISO 7000-2499, or one of the “sterilized
using…” symbols ISO 7000-2500, ISO 7000-2501, ISO 7000-2502, and
ISO 7000-2503. See ISO 15223-1:2012, 5.20 or 5.21, 5.22, 5.23, and 5.24.
(viii) If similar or identical instrument is sold in both sterile and non-sterile condi-
tions, it should be accompanied by a set of instructions for sterilizing the
contents of the instrument.
(ix) Instructions for the process of sterilization with appropriate cycle parame-
ters for the non-sterile instrument or for handling the contents of a sterile
package that got non-sterile due to opening of the package or damage.
Maximum number of permitted re-sterilizing cycles should be specified.
(x) If the instrument is proposed to be reused, method of appropriate processing
before reuse involving cleaning, disinfection, if relevant the process of ster-
ilization with applicable cycle parameters and restrictions for the number of
reuses, if any.
(xi) Clear indication stating the intent of instrument as “single use”, for example,
the “do not reuse” symbol ISO 7000-1051. See ISO 15223-1:2012, 5.2.
(xii) Particulars of any treatment of handling required before the instrument can
be used, for example, final assembly, cleaning, sterilization, etc.
(xiii) Any specific storage and/or handling conditions.
(xiv) Warnings or precautions concerned with use, containing limitations on
chemicals (e.g. alcohol) or other environmental conditions to which the
instrument may get rationally exposed to during the clinical setting.
(xv) It should be expressed on the instrument if the whole instrument or any of its
fragments can be detected externally by an imaging device along with the
kind of device for this purpose.
(xvi) Instructions for legitimate disposal of the instrument and any specific or odd
risks should be pointed out.
(xvii) Information about any medicinal products incorporated into or used with the
instrument should be given wherever relevant.
90 K. Singh
(xviii) Date of issue or the latest revision of the instructions of use should be indi-
cated if needed.
13 Instruments with Measuring Function
The limits of accuracy of such instruments should be indicated by a mark or on the

label on the instrument as well as in the instructions for use. The gauges used for
component size selection and go/no-go decisions are exempt from this requirement.
14 Restrictions in Combinations
If the instrument is designed for use in combination with other instruments, devices,
or equipment, any limitations in the use of the combinations should be written on
the label or in the user instructions.
15 Marking on Instruments
Instruments should be marked with the following entities:

(i) Manufacturer’s name or trademark
(ii) Batch code or serial number, wherever relevant
(iii) Catalogue/article number, if relevant, and/or size implication, if required for
safe selection or use
If the markings on the instrument would affect its performance or that there is not
enough space to mark the instrument because of its small size, the instrument label
shall supply all the required information.
16 Instruments Intended for Single Use
For instruments that are intended for single use, the user instructions would contain
the information about the recognized characteristics and technical factors noted to
the manufacturer that could offer a risk if the instrument is reused.
Reference
ISO 16061:2015(E) Instrumentation for use in association with non-active surgical implants—
General requirements
ISO 22442: Medical Devices Utilizing
Animal Tissues and Their Derivatives

Abbreviations
AAMI Association for the Advancement of Medical Instrumentation

BSE Bovine spongiform encephalopathy
CDC Centers for Disease Control and Prevention
CJD Creutzfeldt-Jakob disease
CPMP Certified Project Management Professional
GMP Good manufacturing processes
ISO International Organization for Standardization
NaOH Sodium hydroxide
PrPTSE Prion protein associated transmissible spongiform encephalopathy
PRNP Prion protein
TSE Transmissible spongiform encephalopathy
WHO World Health Organization
OIE World Organisation for Animal Health
Highlights
• This chapter covers requirements and guidance for the evaluation of medical
devices manufactured utilizing animal tissues or derivatives.
T. Sampath (*)
S. Thamizharasan
Krithaksha V.
RMKSSS, RMK Group of Institutions, Chennai, Tamil Nadu, India
Global Product Safety & Toxicology, Avanos Medical, Inc.,
Alpharetta, GA, USA

• This chapter provides detailed information on validation and elimination of

transmissible spongiform encephalopathy agent.
1 Part 1: Application of Risk Management
1.1 Scope
This part of ISO 22442 applies to medical devices other than in vitro diagnostic
medical devices manufactured utilizing materials of animal origin, which are non-
viable or have been rendered non-viable. It specifies, in conjunction with ISO
14971, a procedure to identify the hazards and hazardous situations associated with
such devices, to estimate and evaluate the resulting risks, to control these risks and
to monitor the effectiveness of that control. Furthermore, it outlines the decision
process for the residual risk acceptability, taking into account the balance of resid-
ual risk, as defined in ISO 14971, and expected medical benefit as compared to
available alternatives. This part of ISO 22442 is intended to provide requirements
and guidance on risk management related to the hazards typical of medical devices
manufactured utilizing animal tissues or derivatives such as (a) contamination by
bacteria, moulds or yeasts; (b) contamination by viruses; (c) contamination by
agents causing transmissible spongiform encephalopathies (TSEs); and (d) material
responsible for undesired pyrogenic, immunological or toxicological reactions. For
parasites and other unclassified pathogenic entities, similar principles can apply.
The text of ISO 22442-1:2015 has been approved by CEN as EN ISO 22442-1:2015
without any modification. This second edition cancels and replaces the first edition
(ISO 22442-1:2007), of which it constitutes a minor revision.
Animal: any vertebrate or invertebrate [including amphibian, arthropod (e.g. crus-

tacean), bird, coral, fish, reptile, mollusc and mammal] excluding humans (Homo
sapiens)
Cell: smallest organized unit of any living form which is capable of independent
existence and of replacement of its own substance in a suitable environment
Derivative: substance obtained from an animal material by a manufacturing pro-
cess, for example, hyaluronic acid, collagen, gelatine, monoclonal antibodies,
chitosan, albumin
Elimination: removal process by which the number of transmissible agents
is reduced
ISO 22442: Medical Devices Utilizing Animal Tissues and Their Derivatives 93
Inactivation: process by which the ability to cause infection or pathogenic reaction

by a transmissible agent is reduced
Medical device: any instrument, apparatus, implement, machine, appliance,
implant, in vitro reagent or calibrator, software, material or other similar or
related article, intended by the manufacturer to be used, alone or in combination,
for human beings for one or more of the specific purpose(s):
–– Diagnosis, prevention, monitoring, treatment or alleviation of disease
–– Diagnosis, monitoring, treatment, alleviation of, or compensation for,
an injury
–– Investigation, replacement, modification or support of the anatomy or of a
physiological process
–– Supporting or sustaining life
–– Control of conception
–– Disinfection of medical devices
–– Providing information for medical purposes by means of in vitro examination
of specimens derived from the human body, and which does not achieve its
primary intended action in or on the human body by pharmacological, immu-
nological or metabolic means, but which may be assisted in its intended
function
Non-viable: having no potential for metabolism or multiplication
Technical agreement: binding contract between two or more parties that assigns
responsibilities for technical requirements
Tissue: organization of cells and/or extracellular constituents
Transmissible agents: bacteria, mould, yeast, parasites, viruses, TSE agents and
unclassified pathogenic entities
1.3 Risk Management Process
Device Contact with the Patient
The quantity of material, the contact surface area and the type(s) of the material
coming into contact with body tissues or fluids as well as the type of body tissue or
fluid it comes into contact with shall be addressed in the risk analysis. Medical
devices such as orthopaedic shoes or components such as leather straps that come
into contact only with intact skin represent a low infective risk. The quantity of
material coming into contact is one of the factors in producing biological effects.
The structure of animal tissues being processed can affect the inactivation and/or
elimination of transmissible agents, and the potential for retaining viable cells can
be affected by the structure of the animal tissues and derivatives being processed.
Material Incorporated in the Medical Device
The following factors shall be addressed, if applicable:

(a) If viable, animal materials are utilized in the manufacture of the medical device,
verification that the final medical device contains no viable animal material.
(b) The intended use of any animal tissue or derivative.
(c) Geographical source, species, age and feeding (including animal-derived pro-
tein) of animals.
(d) Veterinary control, conditions under which the animal materials are recovered,
potential for cross-contamination.
(e) The type and anatomical source of tissue.
(f) The production process, particularly if it uses materials pooled from more than
one animal.
(g) The nature of material utilized in the medical device (e.g. intact tissue).
(h) The method of utilization or incorporation into the medical device. In the case
of medical devices utilizing several relevant constituents (e.g. from various spe-
cies, origin or tissues) or several similar types of constituents produced using
different methods, each individual constituent should be analysed separately.
Device Material Sterility and Other Microbiological Controls
Given the biological nature of animal tissues or derivatives, variations in the biobur-
den of bacteria, mould and yeast of the animal material shall be estimated.
Unwanted Outputs of Substances
The possible presence of toxic residue related to the manufacturing process utilized
or degradation by-products shall be addressed taking into account the physical char-
acteristics (e.g. porosity, heterogeneity) and chemical composition of animal tissues
or derivatives.
Identification of Hazards and Hazardous Situations
The possible hazards associated with animal tissues or derivatives shall be identified
and documented. Particular attention shall be applied to possible hazards posed by
animal tissues or derivatives with regard to:
–– Potential contamination by transmissible agents and their susceptibility to elimi-
nation and/or inactivation during processing
–– Potential for contaminants on the finished material which can cause an undesired
pyrogenic, immunological or toxicological reaction
–– Potential for the finished material itself to cause an undesired pyrogenic, immu-
nological or toxicological reaction
1.4 Risk Evaluation and Risk Control
In accordance with ISO 14971, all identified risks shall be evaluated. Biological
safety shall be evaluated in accordance with ISO 10993-1. Risk evaluation for trans-
missible agents shall be implemented by separately addressing the risks related to
different categories of transmissible agents. Annex B identifies the main categories
of risk that should be considered. Regarding the TSE risk, compliance with require-
ments specified in Annex C for certain animal materials can indicate risk accept-
ability. Annex C combines elements of risk evaluation and risk control.
Risk Control for Viruses and TSE Agents
Risk control shall be implemented by separately addressing the risks related to dif-
ferent categories of viruses and TSE agents. After defining the characteristics of the
product, the medical device manufacturer shall comply with the relevant require-
ments of both ISO 22442-2 and ISO 22442-3, except where either the animal spe-
cies is such that manufacturers cannot fully meet the requirements of ISO 22442-2
or an inactivation process in accordance with ISO 22442-3 would cause unaccept-
able degradation. Tallow derivatives, animal charcoal and amino acids that are
acceptable for TSE risk as discussed in Annex C, due to their processing and not
their sourcing, shall also be considered to have acceptable risk regarding viruses.
Regarding TSE risk, risk control measures specified in Annex C for certain animal
materials shall be applied where relevant. If the manufacturer considers any require-
ment not to be relevant, the rationale and justification shall be documented. For
medical devices where an inactivation process causes unacceptable degradation,
manufacturers may rely on ISO 22442-2 in order to meet the requirements of this
part of ISO 22442. If the animal species is such that manufacturers cannot fully
meet the requirements of ISO 22442-2, they shall demonstrate that the level of inac-
tivation of transmissible agents in a validated manufacturing process, as required in
ISO 22442-3, is sufficient to achieve an acceptable level of risk.
Risk Control of Other Hazards
Risk control related to bacteria, moulds and yeasts, as well as undesired pyrogenic,
immunological and toxicological reactions shall be implemented according to avail-
able standards. Tallow derivatives, animal charcoal and amino acids that are accept-
able for TSE risk as discussed in Annex C, due to their processing and not their
sourcing, shall also be considered to have acceptable risk regarding bacteria, moulds
and yeasts, subject to maintenance of proper storage conditions. The manufacturer
shall conduct periodic microbiological studies to identify and quantify the initial
bioburden of the incoming animal material for the production of the medical device.
Residual Risk Evaluation
The TSE risk may be judged acceptable if the following criteria are both met, taking
into account the availability of alternative materials: (a) the residual risk estimate
indicates that the TSE risk has been controlled at an acceptable level; (b) the medi-
cal benefit arising from the intended use of the device is judged to outweigh the
residual risk estimate. Guidance on risk management applicable to TSE agents is
given in Annex D. Acceptability can be based on conformity with requirements
specific to some animal materials given in Annex C or requirements relevant to
sourcing, collection and handling of bovine materials given in ISO 22442-2:2015,
Annex A. Regarding the TSE residual risk, specific considerations are provided in
Annex C. Some derivatives such as tallow derivatives, animal charcoal, milk deriva-
tives, wool derivatives and amino acids manufactured according to conditions men-
tioned in Annex C are considered as presenting an acceptable TSE risk. Where the
TSE risk has not been controlled at a level that presents an acceptable level of risk
to users or recipients, the overall risk may only be judged acceptable when balanced
by exceptional benefit and feasibility considerations.
Evaluation of Overall Residual Risk Acceptability
The evaluation of the overall residual risk acceptability shall take into account the
balance between the residual risk after implementation of all risk control measures
and the expected medical benefit, as compared to available alternatives. Where
residual risks exist with regard to the contamination with transmissible agents, the
evaluation should specifically discuss the risks and benefits of—using alternative
materials that do not present the risk of contamination with these transmissible
agents, such as synthetic materials, materials from other animal species or materials
from human origin, and—applying whole product alternatives for the same intended
purposes. Where the risk has not been controlled at a level that presents an accept-
able level of risk to users or recipients, the overall risk may only be judged accept-
able when balanced by exceptional benefit and feasibility considerations.
Documentation
The rationale that the risk is acceptable shall be documented in the risk manage-
ment file.
Production and Post-production Information System
Manufacturers shall ensure that the system will identify changes in the zoonosis
status of the chosen source of animal materials.
2 Part 2: Controls on Sourcing, Collection and Handling
2.1 Scope
This part of ISO 22442 specifies requirements for controls on the sourcing, collec-
tion and handling (which includes storage and transport) of animals and tissues for
the manufacture of medical devices utilizing materials of animal origin other than
in vitro diagnostic medical devices. It applies where required by the risk manage-
ment process as described in ISO 22442-1. Selective sourcing is considered to be
especially important for transmissible spongiform encephalopathy (TSE) risk man-
agement. The manufacturers should refer to ISO 22442-3 for information on the
validation of the elimination and/or inactivation of viruses and TSE agents. This
part of ISO 22442 does not cover the utilization of human tissues in medical devices.
–– Collection: removal of tissues from animals

–– Low-risk herd: herd of bovine animals in which, for at least the previous 8 years:
(a) There has been documented veterinary monitoring
(b) There has been no case of BSE
(c) There has been no feeding of mammalian-derived protein
(d) There is a fully documented breeding history
(e) There is a fully documented use of veterinary medicines and vaccines
(f) Each animal is traceable
(g) Genetic material has been introduced only from herds with the same BSE-
free status
–– Veterinarian: person designated by the relevant competent authority as suitably
qualified for the responsibility delegated to him or her relating to ante- and post-
mortem inspection of animals and/or relevant certification
2.3 Quality System Elements
A documented system shall be established and maintained to control the quality of

materials of animal origin and shall be verified by the medical device manufacturer.
This system shall address the animal source and the following factors:
(a) Specification of the geographical origin (such as country or region) of the ani-
mal material, state of health of the animals and acceptance criteria for animals
taking into account the source species, perceived risk from pathogens and abil-
ity to obtain appropriate assurances. The geographical origin can include the
animal’s place of birth and the countries or regions in which it has lived during
its lifetime as well as its place of slaughter. It is advisable that the manufacturer
document the extent to which the geographical origin of the animal can be
traced taking into account the application of risk management.
(b) Hygiene and quality assurance requirements to be met by the slaughterer
including the provisions in the slaughterhouse to prevent cross-contamination
within and between animals.
(c) Procedures for the collection, preservation, handling, storage and transport of
materials of animal origin.
For the control of processed animal material suppliers, the medical device manu-
facturer shall document, to the extent feasible, the practices of the specialized indus-
tries to which clauses of the various parts of ISO 22442 have been applied.
Manufacturers should apply relevant provisions of ISO 22442 to natural substances
such as milk, hair and wool, although these are not covered by the definition of
derivatives.
Procedures
The documented procedures and instructions required by this part of ISO 22422
shall be established, implemented and maintained. These procedures and instruc-
tions shall be approved on issue and shall be controlled as follows. The manufac-
turer shall establish and maintain procedures to control all documents and data that
relate to the requirements of this part of ISO 22442. These documents shall be
reviewed and approved for adequacy by authorized personnel prior to issue. This
control shall ensure that (a) the pertinent issues of appropriate documents are avail-
able at all locations where operations essential to the effective functioning of the
quality system are performed and (b) obsolete documents are promptly removed
from all points of issue or use. Changes to documents shall be reviewed and
approved by the same functions/organizations that performed the original review
and approval unless specifically designated otherwise.
Personnel
Responsibility for the collection, handling and storage of materials shall be assigned
to qualified personnel as follows. The manufacturer shall establish and maintain
procedures for identifying the training needs and provide for the training of all per-
sonnel performing activities affecting quality. The manufacturer shall ensure that
personnel performing specific assigned tasks are qualified on the basis of appropri-
ate education, training and/or experience as required. Appropriate records of train-
ing shall be maintained.
Current Regulatory Requirements and Guidance
Due account shall be taken of relevant current regional regulatory requirements or

guidance including the OIE International Animal Health Code.
2.4 Sourcing
The animal material shall not be compromised by cross-contamination before, dur-

ing or after slaughter. Animals shall be confirmed as having been declared fit for
human consumption. It is the responsibility of the manufacturer to ensure that the
material is fit for its intended use.
Species and Strain
For each material or derivative, the risk of certain diseases is dependent on the ani-
mal species and possibly strain, and this shall be taken into account for the estab-
lishment of control measures.
Geography
The risk of certain diseases is dependent on the geographical origin and this shall be
taken into account for the establishment of control measures. Geographical origin
can include conception, birth, rearing and slaughtering. If required by the risk man-
agement process, in the case of domesticated/farmed species, the geographical
region/country of birth and the summary of main locations of residence up to time
of slaughter shall be recorded. In the case of wild species, the region/location of
capture and the country/region of birth shall be recorded if known. The use of wild
mammalian species shall be addressed in the risk assessment.
2.5 Inspection
Sourcing of animal material shall be subject to control and individual inspection by

a veterinarian. There will, however, be some source species where this is not pos-
sible (e.g. fish, crustaceans). If individual animals cannot be inspected, the justifica-
tion for this shall be documented and a relevant sampling plan provided. Bovine,
caprine, cervid, equine, ovine and porcine species shall be subject to ante-mortem
veterinary inspection. Animals showing locomotive system abnormalities or neuro-
logical disorders shall not be used for the production of medical devices except for
tallow derivatives, animal charcoal and amino acids that are acceptable. The
inspection shall include at least the following: (a) visual inspection; (b) palpation of
specified organs; (c) incision of organs and lymph nodes; (d) investigation of anom-
alies, e.g. inconsistency, colour and smell; and, (e) if necessary, laboratory tests.
Where indicated by risk assessment, for materials (including pooled blood supplies)
for direct use in medical devices and that are not subject to a validated process to
reduce TSE risk in line with ISO 22442-3, consideration shall be given to the appli-
cation of a test for the presence of TSE in the source animal. Animal tissues derived
from certain species (e.g. fish, crustaceans) require a modified approach since vet-
erinary surveillance is not practicable in the same way as for other animal tissues.
Manufacturers should apply relevant sections of this part of ISO 22442 to such
materials but may need to rely on other procedures which have been shown to be
effective for risk reduction.
Certification
Material of animal origin intended for utilization in medical devices shall originate
from animals confirmed by a veterinarian as being fit for human consumption.
Records to demonstrate conformance with veterinary inspection criteria at the abat-
toir, certificate details and source shall be available. For species where such certifi-
cation by a veterinarian cannot be obtained, a status equivalent to “fit for human
consumption” is required such as a confirmation of apparent good health.
2.6 Traceability
Where the risk management undertaken according to ISO 22442-1 indicates that it
is both necessary and feasible, a traceability system shall be established. The extent
of traceability shall be defined by the outcome of the risk assessment taking into
account those official information systems that exist.
2.7 Collection
Materials derived from TSE susceptible species (including pooled blood supplies)
intended for direct use in medical devices and that are not subject to a validated
process in line with ISO 22442-3 to reduce TSE risks to an acceptable level deter-
mined by the risk management process shall be harvested from slaughterhouses
designated by the medical device manufacturer. The manufacturer shall be respon-
sible for ensuring that the collection of the material is conducted in accordance with
the documented procedures. The manufacturer shall review and specify the systems
for certification and traceability when tissues of animal origin are pooled at the
place of slaughter or subsequently. The limits of pooling permitted shall be justified
and documented.
2.8 Handling
If any material of animal origin requires further dissection or trimming, it shall be

removed as soon as possible to an area separate from that used for slaughtering and
collection. This area shall be suitably equipped and maintained at an appropriate
level of cleanliness and environmental protection. Implements for dissection and
trimming shall be kept clean to minimize risk of cross-contamination. Ideally, a
dedicated set of tools should be used for trimming and kept separate from the ones
used for harvesting. Source materials to be utilized in medical devices shall be seg-
regated for delivery according to a documented procedure. The manufacturer shall
be responsible for ensuring that the handling of the material is conducted in accor-
dance with the documented procedures.
2.9 Storage and Transport
Collected material shall be stored and transported in closed containers. The condi-
tions for storage and transport shall not compromise compliance with the relevant
qualities of the animal material, in particular, by environmental or enzymatic degra-
dation or microbial proliferation. The manufacturer shall be responsible for ensur-
ing that the storage and transport of the material is conducted in accordance with the
documented procedures.
3 art 3: Validation of the Elimination and/or Inactivation

P
of Viruses and Transmissible Spongiform Encephalopathy
(TSE) Agents
3.1 Scope
This part of ISO 22442 specifies requirements for the validation of the elimination
and/or inactivation of viruses and TSE agents during the manufacture of medical
devices (excluding in vitro diagnostic medical devices) utilizing animal tissue or
products derived from animal tissue, which are non-viable or have been rendered
non-viable. It applies where required by the risk management process as described
in ISO 22442-1. It does not cover other transmissible and non-transmissible agents.
–– Model TSE agent: TSE agent that displays a known resistance to physical and/
or chemical processing used as reference by analogy for the inactivation of rel-
evant TSE agents and thereby demonstrating the effectiveness of the process
used for inactivation
–– Model virus: virus that displays a known resistance to physical and/or chemical
processing used as reference by analogy for the inactivation of relevant viruses
and thereby demonstrating the effectiveness of the process used for inactivation
–– Overall reduction factor: sum of the reduction factors of the individual pro-
cess steps
–– Permissive cell: cell that can become infected with the virus under study and in
which that virus replicates
–– Reduction factor: ratio of the virus or TSE agent load in the relevant material
used or the device prior to the inactivation or elimination step and the virus or
TSE agent load after the inactivation or elimination step when it is ready for the
next step in the manufacturing process, expressed as the number of tenfold
reduction
–– Relevant TSE agent: TSE agent known to, or likely to, contaminate the source
material or other materials used in the manufacturing process
–– Relevant virus: virus known to, or likely to, contaminate the source material or
other materials used in the manufacturing process
–– Revalidation: set of documented procedures to confirm an established validation
–– Scaled-down process: scaling down process at a specified reduced scale which
simulates the performance parameters as used in the full-scale production process
–– Sterilization: validated process used to render a product free of all forms of
viable microorganisms
–– Validation documented: procedure for obtaining, recording and interpreting the
results required to establish that a process will consistently yield product com-
plying with predetermined specifications
3.3 Risk Management

Sourcing and Manufacturing Process
A documented system shall be established and maintained to control the source of

raw materials of animal origin. ISO 22442-2 shall be used to meet this requirement
as far as applicable. The manufacturing process shall be established to minimize the
load of viruses and TSE agents in starting materials, intermediate products and fin-
ished products. Appropriate documented protocols and procedures shall be estab-
lished to ensure that the validated processing parameters will be applied during the
routine manufacturing processes.
Documented Procedures
The documented procedures and requirements of this part of ISO 22442 shall be
implemented. Documentation and records shall be reviewed and approved by desig-
nated personnel. Procedures for any literature review and/or any inactivation study
shall be documented, and records shall be retained for a period defined by the
manufacturer.
Calibration
An effective system shall be established, documented and maintained for the cali-
bration of all controlling, indicating and recording instruments used for validation.
Equipment
Appropriate equipment as specified in a protocol shall be used. All equipment

requiring planned maintenance shall be maintained in accordance with documented
procedures. Records of maintenance shall be retained. In particular, any equipment
shall be capable of delivering its intended process within defined limits. In addition,
if the equipment used during validation is not identical to that used in normal pro-
duction cycles, adequate documentation shall be available to demonstrate that the
performance parameters are equivalent to those used in the production cycle.
Experimental Systems
Additional parts of the experimental systems used for validation studies such as
chemicals, cell systems and laboratory animals shall be adequately identified, justi-
fied, controlled and documented.
3.4 Literature Review
Conduct of the Literature Review
A literature review shall be performed in order to identify and analyse data on the
elimination and/or inactivation of viruses and TSE agents. Technical information
from the literature review shall be used in optimizing the design of an inactivation
and/or elimination study. Any extrapolation based on the inactivation of viruses and
TSE agents shall be justified and documented. Intrinsic variability of materials of
animal origin utilized in medical devices and of manufacturing processes can lead
to misinterpretation of the validity of published data and shall be taken into account.
Viruses
The manufacturer shall demonstrate whether the literature review provides an indi-
cation of which inactivation and/or elimination steps are likely to be effective. A
literature review is a prerequisite to performing a viral inactivation study. In excep-
tional cases, if a manufacturer chooses not to perform a study, this shall be justified
and documented. If the available information does not support the elimination and/
or inactivation of viruses, then an alternative risk management strategy shall be
implemented (see ISO 22442-1).
TSE Agents
The literature review shall consider which of the published methods for elimination
and/or inactivation of TSE agents are likely to be suitable for the medical device
under consideration. In particular, the materials of animal origin and manufacturing
processes referred to in the literature shall be comparable to those used for the medi-
cal device under consideration. A validated inactivation study shall be performed
when the comparability of materials and processes cannot be demonstrated or spe-
cific claims are made for inactivation of TSE agents by the manufacturer. If the
available information does not support the elimination and/or inactivation of TSE
agents, then an alternative risk management strategy shall be implemented.
3.5 limination and/or Inactivation Study of Viruses

E
and TSE Agents
Protocol
The protocol for a study to demonstrate the elimination and/or inactivation of

viruses and TSE agents during manufacture shall detail the following including, if
applicable, values and acceptability criteria:
(a) The identified risks associated with the tissue concerned (ISO 22442-1).
(b) Identification of the relevant agent(s).
(c) The rationale for the choice of the particular combinations of model agents: The
models for an elimination and/or inactivation study shall be chosen by the man-
ufacturer; the justification for the choice of model(s) shall be documented.
(d) Identification and definition of the manufacturing stage(s) chosen to eliminate
and/or inactivate the relevant viruses and TSE agents.
(e) Documentation of any scaling down, including demonstration of the validity of
the scaled-down version of the manufacturing process.
(f) The methods of calculation for the reduction factors.
Conduct of the Study
The study shall be conducted in accordance with the protocol.
3.6 Final Report
A final report shall be compiled containing:

–– The literature review
–– A critical evaluation of the data obtained during any elimination
–– Inactivation study undertaken
–– An overall conclusion
–– Reference to this part of ISO 22442
3.7 Review of Final Report
Procedures for a review of the final report by persons designated as responsible shall
be documented. A review of the final report shall be conducted when significant
changes in the manufacturing process(es) occur and/or when relevant information
not previously considered in the final report becomes available, e.g. valid scientific
evidence, scientific literature and authoritative publications. If necessary, corrective
actions and/or additional studies shall be undertaken and reported to revalidate the
manufacturing process. Records of any review of the final report shall be retained.
The manufacturer shall assure that all critical parameters identified in the final
report are monitored and controlled during manufacture.
4 art 4: Principles for Elimination and/or Inactivation

P
of Transmissible Spongiform Encephalopathy (TSE)
Agents and Validation Assays for Those Processes
4.1 Scope
This technical report offers suggestions for designing and conducting validation
assays to help determine if processes used in the manufacture of medical devices
derived from non-viable animal tissues might serve to reduce the risk of iatrogenic
transmission of transmissible spongiform encephalopathies (TSEs). The TSE-
removal methods used to process animal tissues should also reduce the risk of trans-
mitting TSE infections via non-viable tissues of human origin; this technical report
does not address this issue. Some current information on human tissues and TSEs is
presented which may be applied by analogy to other animal tissues.
For the purposes of this document, the terms and definitions given in ISO 22442-1,
ISO 22442-2, ISO 22442-3 and ISO 14160 apply.
4.3 Elimination of TSE Agents: Basic Considerations
TSEs of Concern
BSE of cattle is the only TSE of animal origin known so far to have transmitted
disease to humans (i.e. a zoonosis). Scrapie, while of theoretical concern, has not
been recognized as a zoonosis in spite of hundreds of years of experience.
Nonetheless, some competent regulatory authorities have adopted precautionary
policies that discourage the sourcing of ovine-derived and caprine-derived inject-
able materials from herds with a history of scrapie. The susceptibility of sheep and
goats to infection with the BSE agent has posed another more recent concern.
Although pigs have been experimentally infected with the BSE agent, they were not
infected when exposed by the oral route, and no naturally transmitted porcine TSE
has been recognized, and most authorities remain generally satisfied that porcine
tissues are an unlikely source of human exposure to any TSE agent. The same thing
is true for tissues of other animals less commonly used in the manufacture of medi-
cal devices, such as horses.
Animal Tissues of Concern
Examples of animal tissues currently used in their non-viable form to manufacture

medical devices include porcine heart valves, bovine pericardium and bovine col-
lagen. While none of these tissues have been demonstrated to contain a TSE agent,
experiments with animal tissues have been very limited in number, and the assays
used vary in sensitivity of detection. Furthermore, it is conceivable that almost any
animal tissue collected as part of routine slaughter might be accidentally contami-
nated with higher-risk tissues. Regulations and procedures requiring removal, seg-
regation and safe disposal of “specified-risk” materials from animal
carcasses—especially from carcasses of older animals—should reduce but not com-
pletely eliminate this risk. The European Commission has recently proposed “risk
proportionate rules for animal by-products” to clarify and facilitate risk manage-
ment in selection of source materials of animal origin.
Tissues Infected with TSE Agents
Agents might contaminate tissues in two ways: (1) a tissue infected during the TSE
disease process and (2) infectivity introduced into the tissue from infected tissue
(e.g. due to contact with tissues of the nervous system or lymphoreticular cells or
from blood in the tissues). This second or “exogenous” source of contamination
with a TSE agent might occur during harvesting of the tissue from an infected
source or from instruments or surfaces contaminated with TSE agent from a previ-
ously handled source. These distinctions are important for several reasons:
Endogenously infected tissues (except for tissues of the CNS, which have been
found to contain the great majority of total infectivity in the body of an infected
animal) generally contain very small amounts of agent, so suitable models to vali-
date methods for eliminating endogenous infectivity are logistically difficult to
develop. Exogenous contamination is more easily modelled by intentionally spiking
tissues with TSE agents of known provenance, biological characteristics and con-
tent of infectivity as defined by titrations in susceptible animals. The selection of
model agents for validation studies is constrained by several considerations:
(a) Although the actual unpassaged TSE agent likely to be present in the tissue of
concern might be considered most “relevant” for purposes of validating
inactivation/removal studies, the infectivity titres in such agents are usually
both unknown and lower than those of rodent-adapted agents.
(b) In handling of the BSE agent and rodent-adapted strains derived from BSE
agent, regulatory authorities may require high-containment research facilities
not widely available. In general, studies with rodent-adapted scrapie agent have
been considered acceptable, keeping in mind that reported resistance of various
strains of TSE to inactivation procedures has not been uniform.
4.4 Potential Methods to Eliminate TSE Agents
Methods for Inactivating Infectivity Most authorities recommend that, whenever

possible, TSE agents potentially contaminating source materials be inactivated
rather than simply separated from the raw materials. The presence of residual active
agent might pose a continuing danger of later accidental contamination of a tissue-
derived product as well as contaminating manufacturing facilities and non-
disposable equipment. However, unfortunately, most of the physical and chemical
methods known to be effective for inactivating TSE agents are relatively harsh and
often impair the functional properties of tissues. For sanitizing the facilities and
processing equipment that cannot be destroyed after single use or protected from
direct contact with potentially contaminated materials, decontamination methods
that reliably inactivate TSE agents are preferred to those that simply remove
the agents.
Physical Methods for Inactivating TSE Infectivity
Heat When suspensions of tissue from scrapie-infected rodents were rapidly

heated with continuous stirring, relatively rapid loss of infectivity occurred within a
few minutes reaching the assay limit of detection. However, macerates and dried
preparations of TSE agents retained some infectivity even after long exposures to
heat. Dry heat appears to be less effective than moist heat for inactivating TSE
agents. One series of studies even found small amounts of infectivity in ash from
scrapie agent incinerated in an oven at temperatures up to 600 oC, though not at a
higher temperature. Tissue devices are unlikely to tolerate heat treatments adequate
to inactivate TSE agents without loss of function. There have been suggestions that
for adequate decontamination of TSE agents, one should specify exposure to steam
in a porous-load autoclave for at least 18 min at 20-bar pressure. This has been
shown to be ineffective. The World Health Organization Consultation warned that
such treatment was unlikely to decontaminate a surface soiled with dried-on tissue
from a TSE-contaminated source. A consultant to the US CDC cautioned that many
pathogens survive heat and chemical treatments when contaminated surfaces have
not been thoroughly cleaned and that thorough cleaning of critical surfaces must be
employed for safe reuse of all medical devices.
Radiation The TSE agents have resisted inactivation by both ultraviolet and ion-
izing radiations.
Chemical Methods for Inactivating TSE Infectivity
Alkaline Hydrolysis Treatments Exposure to sodium hydroxide (≥1N, especially

at elevated temperatures) has been found effective in removing infectivity from both
aqueous suspensions and tissues dried onto surfaces and is widely used in laborato-
ries dealing with TSE agents. The hazards posed by NaOH are well known. The
corrosive properties of NaOH for autoclaves seem to have been exaggerated, so
long as solutions are carefully contained to prevent direct contact with critical sur-
faces of the chamber. Calcium hydroxide treatments, widely used in the manufac-
ture of gelatines, appeared to be much less effective than NaOH in removing scrapie
and BSE infectivity from spiked preparations of animal bones, although the addi-
tion of heat was highly effective. A number of alkaline-based formulations (mix-
tures of chemicals with alkaline sources) are claimed to be as effective as low
concentrations of alkalinity. These effects appear to be formulation-specific and will
depend on the formulation, temperature and concentration of the specific product.
These treatments are less destructive to tissues, but the studies to date have not com-
pared their efficacy to higher concentrations of alkali treatments.
Acid Treatments TSE agents have been substantially if not completely inactivated
by exposures to concentrated formic acid and, more recently, to acetic acid in a solu-
tion of sodium dodecyl sulphate. Sodium hypochlorite (household chlorine bleach
at concentrations ≥5%) has been found effective in removing TSE infectivity from
scrapie-contaminated suspensions and surfaces and is widely used in situations
where the corrosive effects on metals are not a problem. Chloramine and other
halides have been found less effective. Liquid hydrogen peroxide has also been
found to lack utility for decontaminating TSE agents, although in low-temperature
gaseous form it might be more effective.
Treatments with Phenolic Disinfectants
A proprietary phenolic disinfectant has been reported to eliminate scrapie infectiv-

ity from contaminated suspension to the limit of detection. Treatment with phenol
itself failed to eliminate infectivity.
Protease Treatments
Stimulated by the widely accepted prion theory, studies investigating effects on

infectivity of TSE agents from several protease treatments have been investigated,
yielding variable results. As noted above, thorough cleaning is undoubtedly impor-
tant in freeing surfaces of infectivity, and protease treatments probably facilitate
that process. Whether proteases have an additional specific effect of inactivating
TSE agents by cleaving the prion protein is less clear.
Guanidine and Other Chaotropic Chemical Treatments
Treatments with guanidine and other chaotropic chemicals have been found to
reduce infectivity. Some reports suggested that the apparent inactivation was revers-
ible when the chaotropic chemical was removed.
Combined Treatments
Limited experience suggests that combinations of TSE-inactivating treatments hav-

ing different chemical and physical actions might be more effective than either
treatment used separately. Examples of potentially effective combined treatments
have included NaOH with heat, including boiling in neutral detergent and acetic
acid in detergent solution. Potential damage to autoclaves may be mitigated by the
use of covered containers to isolate the NaOH from the autoclave interior.
Ineffective Treatments
Ethylene oxide gas, alcohols, mercurial disinfectants and a number of other treat-
ments commonly used to sanitize or sterilize surfaces have not been found useful for
decontamination of TSE agents; research with such treatments has been limited.
Aldehydes not only failed to inactivate TSE agents; they may have stabilized the
infectivity. More ineffective treatments may be found in the document from the UK
government, which lists ineffective treatments.
4.5 ethods for Removing TSE Infectivity Without

M
Inactivating Infectivity
Although physical methods such as chromatography, sedimentation, filtration and

partition of fractions offer some promise for reducing amounts of TSE infectivity in
complex biological mixtures (e.g. blood and its components and plasma and its frac-
tions), it is unlikely that selective removal of infectivity from intact non-viable tis-
sues would be feasible.
4.6 xperimental Validation of Methods for Eliminating TSE

E
Agents from Medical Devices Utilizing Non-viable
Animal Tissues
Although limited study has been attempted using methods expected to reduce if not
eliminate TSE agents exogenously contaminating human non-viable tissues, few if
any studies have directly attempted to decontaminate animal-derived tissues. As
outlined in ISO 22442, all parts, the more appropriate method for reducing risk is
careful selection of low-risk source animals and tissues and good manufacturing
processes (GMPs) to reduce opportunities for exogenous contamination with neural
tissues and, to a lesser extent, lymphoreticular and intestinal tissues.
efining of Product Families for Purposes of Designing TSE Process

D
Validation Studies
For purposes of this document, the definitions of product families described in

AAMI TIR37:2007 Section 4 that are appropriate to evaluation of validation assays
for elimination/removal of TSE agents from medical devices utilizing non-viable
animal tissues should apply here as well. The products selected for experimental
validation should, as closely as feasible, resemble the manufactured product of con-
cern and be considered by one or more expert consultants to constitute an accept-
able realistic representative of a product family.
election and Testing of Product for Establishing and Verifying

S
the Infecting Dose of TSE Agent
For purposes of this document, the considerations for nature of the test product
sampling conditions, sample item portions, considerations regarding use of multiple
batches and assays of fluids extracted from test products that are appropriate to
evaluation of validation assays for elimination/removal of TSE agents from medical
devices utilizing non-viable animal tissues should apply here as well. Note that
assays of TSE agents, whether by preliminary immunoassays of protease-resistant
PrPTSE or—especially—by subsequent bioassay in animals, are considerably more
technically difficult, time-consuming (months or years for bioassays) and expensive
than are cultures of bacteria and fungi, and that must be taken into account when
selecting numbers of replicates for testing.
TSE Agent Spiking Materials
Limited but accumulating evidence suggests that, while all TSE agents share most
biological and physical properties, including unusual resistance to inactivation by a
variety of treatments, strains have differed substantially in that resistance. It seems
prudent to select for spiking a tissue infected with a strain of TSE agent more rather
than less resistant to the inactivation procedure under study so long as the spike
material is relevant to the manufacturing process. While it might be argued that
worst-case scenarios are unrealistic representations of manufacturing situations, the
logistics of validation models have usually required that tissues containing very
high concentrations of TSE agent (usually meaning infected brain tissue suspen-
sions, fragments or macerates) be employed as spiking materials. It must be
acknowledged that such materials, most often prepared from brains of rodents
infected with rodent-adapted strains of TSE agent (especially scrapie agent), might
not closely resemble naturally infected tissues either in amounts or biological and
physical properties of the agent or in some properties of the matrix (tissue of origin).
However, in general, it has not been feasible to validate processes for eliminating
TSE agents from raw materials except by spiking with rodent-adapted TSE agent
strains in rodent brain tissues for several reasons.
(a) Titres of TSE agent in naturally infected tissues are generally not known, nor is
the susceptibility of available rodents to infection with field isolates (often
poor). Tissues other than brain have much lower titres of both PrPTSE (often
not detectable) and infectivity than brain.
(b) Well-characterized standard reference materials prepared from tissues of natu-
rally infected animals are not yet widely available.
(c) Transgenic mice or other rodents—e.g. European bank voles consistently sus-
ceptible to infection with field isolates of TSE agents—are not generally avail-
able except in a few research laboratories.
4.7 Availability of Bioassay Animals
Rodent-adapted TSE agents, commonly derived from strains of sheep scrapie but
recently from BSE as well, have been used in pilot studies to investigate methods
for eliminating infectivity experimentally spiked into various raw materials or inter-
mediates. The 263K hamster-adapted strain of scrapie agent and similar strains
assayed in golden Syrian hamsters have been especially useful. The 301V mouse-
adapted strain of BSE agent assayed in conventional mice might be more predictive
of the probable behaviour of BSE agent in bovine tissues.
Transgenic mice engineered to express amino acid sequences of other species in
the PRNP gene may be useful in certain situations but pose several problems.
(a) Mice overexpressing prion proteins have developed non-transmissible neuro-
logical diseases histopathologically resembling TSEs later in life, which some-
times confused the interpretation of infectivity assays.
(b) Most lines of PRNP–transgenic mice can currently be obtained only as gifts
from the developers.
Compared with some strains of conventional mice, the superiority of mice
expressing bovine PRNP amino acid sequences has not been rigorously demon-
strated to date, although some lines may prove to be more sensitive. (Human-derived
TSE agents infrequently transmit disease to conventional mice, and—since assays
using nonhuman primates have become increasingly unfeasible—transgenic mice
expressing human PRNP amino acid sequences appear to offer the most practical
assays of infectivity.) As noted above, European bank voles have been described as
highly susceptible to a number of TSE agents; however they appeared to be rela-
tively less sensitive than mice to the BSE agent and to the emerging Nor98 strain of
scrapie agent, and, in any case, colony-raised voles are not widely available.
It might be argued that methods for eliminating the infectivity of animal-derived
TSE agents should most appropriately be studied using materials from naturally
infected animals assayed in susceptible animals of the same species; although that
has been done to a limited extent to investigate pathogenesis of BSE by assays in
calves and scrapie in sheep, it is generally not practical to study elimination of TSE
infectivity in large animals.
Potential Development of Cell Culture Assays for Infectivity
Several cell lines have been described that support the propagation of selected TSE
agents. Although the cells showed no recognizable cytopathic effect, PrPTSE could
be detected. Such a cell culture assay has been reported to be much more sensitive
than direct detection of PrPTSE in the original infected tissue. Unfortunately, cell
culture assays have not been developed for detection of BSE agents, field isolates of
scrapie agents from sheep or human-derived TSE agents. In addition, false-positive
PrPTSE results have posed a problem. The development of reliable and sensitive
cell culture-based assays for animal TSE agents would greatly facilitate the valida-
tion of methods to eliminate the agents from animal-derived materials.
Correlations Between PrPTSE and Infectivity Assays
Although PrPTSE has usually been detected in tissues and tissue extracts containing
TSE infectivity, a number of reports failed to demonstrate PrPTSE in materials con-
taining considerable amounts of infectivity. Furthermore, immune reactive proteins
with properties of PrPTSE have been found in tissues that did not contain detectable
agent transmitting spongiform encephalopathy. Several investigators have asserted
that it is possible to generate TSE infectivity from tissues of animals that were never
exposed to the agents. This confusing situation urgently requires clarification but
serves as a caution when interpreting results of assays for PrPTSE. Although several
reports claimed that innovative assays for PrPTSE were more sensitive than rodent
bioassays of infectivity, those claims remain to be independently verified in com-
parative blinded and randomized studies.
eductions in Infectivity Compared with Failure to Detect at Limits

R
of Detection
Confirmed reductions in amounts of infectivity estimated by assays can be consid-

ered informative so long as the tests have used robust methods with a sufficient
number of replicate experiments and assays within each experiment to assure that
results are repeatable. Just as for estimates of reductions in infectivity for other
infectious agents, considerable caution must be exercised when relying on results of
variable assays, and especially when reductions are less than 1000-fold. For that
reason, some authorities have recommended that two validated infectivity-reducing
processes, each based on a different chemical-physical principle, be employed in
any manufacturing scheme claiming to reduce the risk of contamination. For bio-
logical products, FDA policies have recommended that each of the two processes
reduce spiked infectivity by at least ten-thousand-fold before asserting a claiming
that a manufacturing method is likely to reduce the risk of contamination with a
defined pathogen to an acceptable level.
4.8 equirements for Stepwise Reductions in PrPTSE

R
and Infectivity Versus Whole-Process Validation
Although it would be especially reassuring to validate the effectiveness of an entire

manufacturing process by eliminating substantial amounts of relevant TSE infectiv-
ity spiked into real starting material in a realistic pilot model, yielding a functional
end product completely free of detectable infectivity, such validation may not be
achievable for several reasons. The input infectivity in starting material may be
modest; various steps may greatly dilute the amount of original materials reaching
the final product. This dilution introduces a sampling problem in the design of the
experiment. If there is no infectious dose in a sample due to dilution, one will see a
false-negative in the assay used. The solution to this problem is to test more sam-
ples, which is often not feasible. Surface-volume relationships are not maintained in
scaled-down pilot models. Therefore, as for viral validations of biologic products, it
is more often necessary to spike individual intermediate steps with model TSE
agents, attempting to simulate realistic process conditions and conditioning of the
intermediates, and then to infer probable overall effectiveness of a whole production
scheme by adding orthogonal log reduction factors to yield a probable total log
reduction value, keeping in mind attendant uncertainties.
Annexures
nnexure A: Guidance on the Application of This Part

A
of ISO 22442
Application to Materials from Animal Sources This international standard is

applicable to materials such as:
–– Porcine heart valves, bovine bones, cattle ligaments and bovine pericardium
–– Derivatives of animal tissues, such as chondroitin sulphate obtained from shark
and collagen derived from hides, and of animal blood or serum
–– Materials produced in vivo by relevant animals, e.g. antibodies utilized in the
manufacturing process
–– Starting materials such as bovine serum albumin, enzymes, culture media includ-
ing those used to prepare working cell banks, master cell banks or master seeds
for products such as hyaluronic acid
Application to Materials Supplied by Third Parties This part of ISO 22442 can
be applied when the materials used by medical device manufacturers have been
prepared from animal sources by third parties or subcontractors. An example is
gelatine derived from animal hides or bones. In considering the risks associated
with the use of these products, the medical device manufacturers should seek evi-
dence from their suppliers as to whether relevant requirements of this international
standard have been applied in assessing the suitability of the animal material or
whether alternative approaches were applied.
nnexure B: Graphical Representation of Part of the Risk

A
Management Process for Medical Devices Utilizing
Animal Material
nnexure C: Special Requirements for Some Animal Materials

A
Considering the Risk Management for TSE Agents
C.1 Collagen Collagen is a fibrous protein component of mammalian connective

tissue. For collagen, documentation to demonstrate compliance with this part of
ISO 22442 shall be provided, taking into account the relevant requirements of this
annex. When completing the risk management required by this part of ISO 22442,
consider the following: For collagen produced from bone, the bone shall be sourced
from countries with minimal exposure to BSE. Sourcing bone from countries with
limited exposure to BSE shall be justified by reference to other applicable risk con-
trol measures. Bone shall not be sourced from countries where infection with the
BSE agent is confirmed at a higher level, unless from a low-risk herd as defined in
ISO 22442-2. For collagen produced from bones, the manufacturing conditions
specified for gelatine are applicable.
–– Collagen produced from hides and skins does not usually present a significant
TSE risk provided that cross-contamination with potentially infected materials,
for example, central nervous tissues, is avoided during their procurement. To
demonstrate compliance with the requirements of this part of ISO 22442, it is
necessary to incorporate measures to prevent cross-contamination and to docu-
ment the measures that are adopted in the technical agreement between the col-
lagen supplier and the medical device manufacturer to prevent such
cross-contamination. Collagen shall be obtained from animals declared as fit for
human consumption.
C.2 Gelatine Derived from Hides and Bones
Gelatine is a natural, soluble protein, gelling or non-gelling, obtained by the partial
hydrolysis of collagen produced from bones, hides and skins, tendons and sinews of
animals. For gelatine, documentation to demonstrate compliance with this part of
ISO 22442 shall be provided, taking into account the relevant requirements listed in
this annex. Gelatine shall be obtained from animals declared as fit for human
consumption.
Hides as the Starting Material On the basis of current knowledge, hides used for
gelatine production represent a safer source material when compared to bones.
Gelatine produced from hides does not usually present a significant TSE risk pro-
vided that cross-contamination with potentially infected materials, for example,
central nervous tissues, is avoided during their procurement. To demonstrate com-
pliance with the requirements of this part of ISO 22442, it is necessary to incorpo-
rate measures to prevent cross-contamination and to document the measures that are
adopted to prevent such cross-contamination in the technical agreement between
the gelatine supplier and the medical device manufacturer.
Bones as the Starting Material Where bones are used to manufacture gelatine,
the quality of the starting materials is the primary parameter that will ensure the
safety of the final product. Therefore, the following shall be applied:
–– Subject to national legislation, bone shall be sourced from countries with mini-
mal or limited exposure to BSE. Bone shall not be sourced from countries where
infection with the BSE agent is confirmed at a higher level, unless from a low-
risk herd as defined in ISO 22442-2.
–– Skulls and spinal cords shall be removed from the collected bones (raw/starting
material) from cattle of a specific age as defined in national legislation.
–– Additionally, vertebrae shall be removed from the raw/starting materials from

cattle of all ages from countries with limited exposure to BSE.
C.3 Bovine Blood Derivatives General foetal bovine serum is commonly used in
cell cultures. Foetal bovine serum should be obtained from foetuses harvested in
abattoirs from healthy dams fit for human consumption, and the womb should be
completely removed. The foetal blood shall be harvested in a dedicated space or
area by cardiac puncture into a closed collection system using an aseptic technique.
New born calf serum is obtained from calves aged less than 20 days and calf serum
from animals aged less than 12 months. In the case of donor bovine serum, given
that it can be derived from animals less than 36 months old, the BSE status of the
donor herd shall be well defined and documented. In all cases, serum shall be col-
lected according to specified protocols by personnel trained in these procedures and
the precautions necessary to avoid cross-contamination with higher-risk tissues.
C.4 Stunning Methods If blood is obtained from slaughtered animals, the method
of slaughter is of importance to ensure the safety of the material. It has been dem-
onstrated that stunning by a captive bolt stunner with or without pithing, as well as
by pneumatic stunner, especially if it injects air, can destroy the brain and dissemi-
nate brain material into the blood stream. There is evidence that non-penetrative
stunning can cause some central nervous system (CNS) embolism. The stunning
methods shall be described for the bovine blood collection process unless the mate-
rial is sourced from a country of negligible geographical BSE risk. Where sourcing
of blood is from countries with limited exposure to BSE, a non-penetrative stunner
or electronarcosis shall be used for slaughter of animals over 12 months of age. The
use of non-penetrative stunning shall be justified on the basis of an estimate of the
risk of dissemination of brain particles into the blood.
C.5 Tallow Derivatives Tallow is fat obtained from tissues including subcutane-
ous, abdominal and intermuscular areas and bones. Tallow derivatives, such as glyc-
erol and fatty acids, manufactured from tallow by rigorous processes, are thought
unlikely to be infectious. For this reason, such materials manufactured under the
conditions at least as rigorous as those given below shall be considered as present-
ing an acceptable TSE risk, irrespective of the geographical origin and the nature of
the tissues from which tallow derivatives are derived.
C.6 Animal Charcoal Animal charcoal is prepared by carbonization of animal tis-
sues, such as bones, using a temperature >800 °C. Irrespective of the geographical
origin and the nature of the tissue, animal charcoal prepared under these conditions
shall be considered as presenting an acceptable TSE risk.
C.7 Milk and Milk Derivatives Certain materials, including lactose, are extracted
from whey, the spent liquid from cheese production following coagulation.
Coagulation can involve the use of calf rennet, an extract from abomasums, or ren-
net derived from other ruminants. A risk assessment for lactose and other whey
derivatives produced using calf rennet was performed and concluded that the TSE
risk is negligible if the calf rennet is produced in accordance with the process
described in the CPMP risk assessment report. Subject to national legislation, milk
derivatives manufactured according to the conditions below are considered as pre-
senting an acceptable TSE risk: the milk is sourced from healthy animals under the
same conditions as milk collected for human consumption; no other ruminant-
derived materials, with the exception of calf rennet, are used in the preparation of
such derivatives (e.g. pancreatic enzyme digests of casein).
C.8 Wool and Its Derivatives Wool and its derivatives, such as lanolin and wool
alcohols, shall be considered in compliance with this part of ISO 22442, provided
the wool is sourced from live healthy animals. Wool derivatives produced from wool
that is sourced from slaughtered animals declared “fit for human consumption” are
considered as presenting an acceptable TSE risk if the manufacturing process in
relation to pH, temperature and duration of treatment meets at least one of the stipu-
lated processing conditions listed as follows: treatment at pH ≥13 (initial; corre-
sponding to concentrations of sodium hydroxide ≥0,1 mol/l) at ≥60 °C for at least
1 h; this normally occurs during the reflux stage of the organic-alkaline treatment;
molecular distillation is at ≥220 °C under reduced pressure.
C.9 Amino Acids Amino acids can be obtained by hydrolysis of animal materials
from various sources. Amino acids prepared using the following processing condi-
tions are considered as presenting an acceptable TSE risk: amino acids produced
from hides and skins by a process which involves exposure of the material to a pH
of 1–2, followed by a pH >11 and heat treatment at 140 °C for 30 min at 3 bar; the
resulting amino acids or peptides shall be filtered after production; analysis shall be
performed using a validated and sensitive method to control any residual intact mac-
romolecules with a justified limit set.
nnexure D: Information Relevant to the Management

A
of TSE Risk
TSE The naturally occurring transmissible spongiform encephalopathies (TSEs)

include scrapie (in sheep and goats), chronic wasting disease (in mule deer and elk),
bovine spongiform encephalopathy (BSE) in cattle as well as kuru and Creutzfeldt-
Jakob disease (CJD) in humans. It is difficult to detect agents causing these diseases
in vivo. After latency periods of up to many years, the agents cause disease and,
finally, lead to death. No means of therapy is known. Current information on the
characteristics of the causative agents is limited. These agents are extremely resis-
tant to most of the chemical and physical procedures that inactivate conventional
viruses. They do not induce a detectable immune response. There are natural barriers
which limit their interspecies spread of transmissible agent, but they can be crossed
under appropriate circumstances. This is usually dependent upon strain, dose, route
of exposure and the species barrier. Studies in laboratory animals have shown that
intracerebral inoculation is the most efficient route of transmission.
Risks for Humans There is considerable circumstantial evidence that the variant
form of human CJD (vCJD) arose from BSE and it is prudent to accept that the BSE
agent can be transmitted to man. This part of ISO 22442 therefore contains a num-
ber of requirements to ensure that risks are controlled if biological materials from
species susceptible to TSE are used for the manufacture of medical devices. This
annex provides guidance that should be followed to minimize the risks of contami-
nation. It identifies where requirements elsewhere in this part of ISO 22442 are
applicable and where information from other sources is relevant. All devices should
be considered on a case-by-case basis.
Risk Management for TSE Agents The safety of a medical device, in terms of its
potential for passing on a TSE agent, is dependent on a number of factors. The eight
most important factors below should be analysed, evaluated and managed:
–– Animal species used
–– Geographical sourcing
–– Nature of starting tissue
–– Slaughtering and processing controls to prevent cross-contamination
–– Methods used to inactivate or remove TSE agents
–– Quantities of animal starting material required to produce one unit of the medi-
cal device
–– Quantities of material of animal origin coming into contact with the patients
and users
–– Route of administration
References
1. BS EN ISO 22442-1:2015 Medical devices utilizing animal tissues and their derivatives Part 1:
Application of risk management
2. BS EN ISO 22442-2:2015 Medical devices utilizing animal tissues and their derivatives Part 2:
Controls on sourcing, collection and handling
3. BS EN ISO 22442-3:2007 Medical devices utilizing animal tissues and their derivatives Part
3: Validation of the elimination and/or inactivation of viruses and transmissible spongiform
encephalopathy (TSE) agents
4. ISO/TR 22442-4: Medical devices utilizing animal tissues and their derivatives — Part 4:
Principles for elimination and/or inactivation of transmissible spongiform encephalopathy
(TSE) agents and validation assays for those processes
ISO 11137: An Overview on Radiation
for Sterilization of Medical Devices
and Healthcare Products
Balu Venugopal, Sunitha Chandran, and Amita Ajit
1 Introduction
Sterilization, in the context of medical devices, aims to eliminate the pathogenicity

associated with it by removing the number of microorganisms present on it. Any
device before sterilization will have microorganisms even in low numbers, catego-
rizing it to be nonsterile. In this context, sterility thus refers to the absence of viable
microorganisms on medical devices. A ready to use medical device in humans for
treatment, therapy or research has to be free of microorganisms, and the process
employed for its sterilization has to follow the international standards to ensure vali-
dation of the sterilization process.
Apart from achieving sterility, methods to ensure sterility and its validation are
also important. It is necessary that the method of sterilization implemented is reli-
able and reproducible with similar levels of performance every time. This stresses
that the kinetics of inactivation of microorganisms employed should remain the
same whenever the same sterilization methods are employed. In short, the achieve-
ment of its repeatability is of utmost necessity. The kinetics of inactivation by any
sterilizing agent depends on the extent of treatment and the number of microorgan-
isms surviving after treatment. So the process of sterilization employed should be
able to provide appropriate microbicidal activity ensuring minimum probability for
having a microorganism on the medical device post-sterilization. The standard
B. Venugopal
Department of Health Research, New Delhi, India
S. Chandran
SCTIMST-TIMed, Biomedical Technology Wing, Sree Chitra Tirunal Institute for Medical
Sciences and Technology, Thiruvananthapuram, Kerala, India
A. Ajit (*)
Scientific Consultant (Biologics) & Life Member, Kerala Academy of Sciences,
Thiruvananthapuram, Kerala, India
122 B. Venugopal et al.
specific probability values differ from country to country as per the regulatory
requirements of the respective countries. However, to ensure uniformity of stan-
dards, international standards and guidelines are to be considered.
This chapter deals with the process of radiation sterilization of medical devices
and its requirements in healthcare products as described by the International
Organization for Standardization (ISO). Complying with ISO standards ensures
consumer satisfaction by delivering quality products suiting the purpose and effi-
cient use meeting international standards. This chapter thus describes the develop-
ment, validation and routine control of the sterilization process including operational
and performance qualification of the unit, routine calibration and maintenance. This
chapter also discusses various methods employed to establish the sterilization dose
for each specific product as per the ISO standards. The following document pro-
vides the guidelines for proper dose measurement, also termed as dosimetry to
determine the amount of dose absorbed by each product to ensure complete
sterilization
2 Sterilization by Irradiation
Sterilization by irradiation is one of the common methods of sterilization used in the

medical industry and is considered safe and cost-effective. Irradiation is generally
considered to be advantageous over other sterilization methods due to its better
penetration resulting in complete sterilization and is independent of temperature
and pressure fluctuations. The effect or impact of radiation depends on the resis-
tance of microorganisms to radiation and the microorganism’s capability to repair
single-strand breaks due to the activity of their DNA repair enzymes. Means of
radiation can either be a radionuclide 60Co or 137Cs (gamma irradiation), a beam
from an electron generator or an X-ray generator.
2.1 Characterization of the Sterilizing Agent
Sterilization by radiation requires an irradiator that can generate a radiation beam.

The microbicidal activity of the radiation process employed will be critical in deter-
mining the sterility of the product or the sterilization efficiency of the process
employed. The effect of irradiation on the functional efficiency of the product post-
sterilization should also be assessed to identify the appropriate sterilization method.
For example, in the case of X-ray irradiator, the probability of induced radioactivity
in the sterilized product has to be assessed. The quality and composition of the
material used in the manufacture of the medical device may also influence the use
of radiation in the sterilization process. Effect of the radiation dose on the surround-
ing environment is yet another parameter to be considered while selecting a steril-
ization method. All these parameters should be considered for identifying and
ISO 11137: An Overview on Radiation for Sterilization of Medical Devices and… 123
characterizing an appropriate sterilization method for safe and effective

sterilization.
2.2 Characterization of the Equipment
The equipment/the irradiator used for the sterilization should ideally be designed in
accordance to the ISO standards that will meet the requirements of the material to
be sterilized, and the software used should be able to deliver the required process
outcome. The general requirement for an irradiator will include the following as per
ISO standard 11137-1:
–– The operating requirements, specifications and routine maintenance schedule of
the irradiator
–– Type of radionucleotide or gamma irradiation system for a gamma irradiator
–– The characteristics and energy of the beam for electron and X-ray beam
irradiators
–– Construction and operation of the conveyor system and its details
–– Dimension and nature of irradiation containers
–– Position and status display of the gamma source when it is operational
–– The premises of the irradiator
–– Procedure to segregate irradiated products from non-irradiated products
–– Procedure to cease the irradiation and conveyor movement as and when required
2.3 Sterilization Process
Sterilization process includes a series of actions or operations needed to achieve the

specified requirements for sterility. For a product to be sterilized effectively, the
maximum microbicidal potential of the irradiation dose has to be ensured. This is
calculated by determining the maximum acceptable dose and the sterilization dose.
The maximum acceptable dose is the highest dose used to sterilize the product with-
out compromising its specified functional requirements including safety, quality
and performance throughout its life after sterilization. Before radiation sterilization,
it is necessary to determine if the material including its packaging can withstand the
effect of radiation employed. Various materials interact with the ionizing radiation
differently, and it is important to identify the highest safe dose to be used for steril-
izing each material component without affecting their shelf life.
The basic technical requirements for performing a sterilization process and its
validation include:
• The supply of product/product representatives including its packaging material
that has to be irradiated
• A facility to assess product function post-sterilization to confirm if any func-

tional requirements are compromised
• An irradiator/appropriate source of radiation that can deliver the required amount
of radiation dose
• Settings to determine and establish the sterilization dose
• An ISO competent microbiological laboratory for bioburden determination
• Requirements for performing the dosimetry
3 Validation
Validation involves generation and storage of documented procedure for obtaining,

recording and interpreting the results that will establish if the process consistently
yielded the product complying with predetermined specifications. This includes the
installation of the irradiator, conducting routine control of sterilization process
including the operational and performance qualification. All the sterilization records
should be traceable at any point of time for any batch of medical devices. Proper
auditing should be done to analyse records and servicing activities associated with
the sterilization instrument and its process. Part of ISO 11137-1:2015, “Sterilization
of health care products—Radiation: Requirements for development, validation and
routine control of a sterilization process for medical devices”, describes validation
and routine control in detail.
Installation validation includes testing and documentation of the functioning of
the irradiator, conveyor system and ancillary equipment including the software and
the irradiation source at the time of installation. Any modification or alteration at the
time of installation has to be recorded. This usually includes the initial calibration
of the entire instrumentation set-up of the irradiator pertaining to its performance,
monitoring and recording.
Validation for operational qualification determines the capability of the equip-
ment to deliver the exact doses and range of doses as specified in the software as per
the requirement of the products to be irradiated. Dose mapping also forms a part of
operational qualifications where it determines the distribution of irradiation doses at
various parts of the irradiation container. Dose mapping has to be performed in an
irradiation container when it is filled to its full capacity using a product of homoge-
neous density that will allow precise dose mapping. In case of gamma and X-ray
irradiators, the time setting of generation and duration of the dose has to also be
validated in correspondence to the conveyor speed.
The performance qualification as defined by ISO is the “process of obtaining and
documenting evidence that the equipment, as installed and operated in accordance
with the operational procedures, consistently performs as per the predetermined
criteria and thereby yields the product meeting its said specification”. Validation for
performance qualification will allow continuous monitoring and recording of the
performance delivered by the irradiator as specified according to the sterilization
requirements. Dose mapping is routinely performed to determine the location and
magnitude of minimum and maximum dose. Apart from validating the installation
and performance of the irradiator, the process of irradiation also has to be validated.
The process specification in general includes the following:
• Product dimensions including density and orientation packaging details
• Pattern of product loading in the irradiation container
• The conveyor path(s)
• The maximum acceptable dose
• The sterilization dose
• Time taken from manufacturing to completion of irradiation
• The routine dosimeter monitoring position
• Dose at the monitoring position(s), minimum and maximum doses
Routine control and monitoring of the irradiator and the process of sterilization
is important to maintain the quality control of the sterilization process. This includes
validation of the product requirements for irradiation, validation of dosimetry and
the system requirements. The irradiated products should be verified for complete
sterilization using appropriate methods like sterilization indicators. There should be
appropriate mechanisms to segregate sterilized and non-sterilized products which
are validated. All the product validation procedures including periodic tests, calibra-
tions, maintenance tasks and necessary requalification should be performed and
recorded before the product is released from the sterilization department. The initial
validation has to be followed by continuous monitoring for system and process
effectiveness and sterilization dose audits. This will ensure the performance qualifi-
cation of the system and the process in appropriate intervals leading to complete
sterilization.
4 Establishing Sterilization Dose for Irradiation of Products
ISO 11137-2:2015, Sterilization of health care products—Radiation; Part 2:

Establishing the sterilization dose, describes methods that can be used to determine
the sterilization dose. Sterilization dose is the minimum dose required to achieve
sterility. Determination of sterilization dose is influenced by various factors, and
depending on the parameters assessed, there are various methods to determine the
sterilization dose.
4.1 Factors Influencing the Bioburden on a Product
The sterilization process and dosage will be determined by the bioburden levels on
the product to be irradiated. Bioburden is defined as the population of viable micro-
organisms on or in product and/or sterile barrier system. Bioburden levels are classi-
fied as low, moderate and high depending on the initial amount of microorganism
present on the product before irradiation. A bioburden level of 1–10 is considered as

low, 10–100 is considered moderate, and 100–1000 is considered high. The product
to be sterilized also plays an important role in determining the bioburden and steril-
ization dose settings. The material with which the product is manufactured, product
size and design, the manufacturing process and environment are factors that influence
the intensity of bioburden on an item. Along with the above-mentioned parameters,
the number and type of microorganisms on the product also determine the amount of
bioburden on the product and thereby the dose requirement for sterilization.
4.2 Identifying a Product Family
It is not necessary to validate and demonstrate the sterility of every product that
undergoes irradiation for sterilization. Depending on the number of products per
batch and the number of batches to be sterilized, either a few batches or a few num-
bers of products from each batch can be validated for demonstrating successful
sterilization. The product used for validation of sterilization would thus represent a
product family. Forming product families will save time and cost for establishing
and validating the sterilization dose for similar products. For a product to be used as
a representative of the product family, it has to have a similar bioburden intensity
(number and type of microorganism on the product) as that of the product family.
Other parameters include the size, complexity of the product and its environment of
manufacturing.
The products used for the determination of sterilization dose and validation can
be either a master product, equivalent product or simulated product. A master prod-
uct refers to a product which presents a higher bioburden possibility than any other
material in the product family. A group of products can be considered equivalent
when the group members require the same sterilization dose for irradiation purpose.
The other parameters to be considered include the manufacturing volume and avail-
ability of the product. To reduce the wastage of products for dose determination,
simulated or surrogate products can also be used for establishing sterilization dose
and validation. A simulated product should be solely made for the establishment and
validation of sterilization dose and is not meant for clinical use. For a surrogate prod-
uct to replace the original product, it has to represent an equal or higher bioburden
than the original product. The simulated product should also be similar in terms of
raw material used for manufacturing, size of the product and manufacturing process.
4.3 Sample Item Portion
A defined portion of a healthcare product that is to be tested and used for establish-
ment and validation of sterilization dose is called a sample item portion (SIP). The
value of SIP is calculated based on the nature of the product to be sterilized and
based on either its length, mass, volume or surface area. For a product of SIP value
1, when the average bioburden of a product is greater than or equal to 1.0, it is rec-
ommended to use the entire product for sterilization validation. But in some cases,
it is not feasible for large medical devices to be used in full for sterilization valida-
tion. In such cases, the largest portion of the product should be selected. For prod-
ucts of SIP value 1 and average bioburden less than 1.0, it is always recommended
to use the entire product for validation. If the bioburden is evenly distributed across
the item, any portion can be considered as SIP, and in case of uneven distribution,
the portion of the product that presents the highest challenge shall be used as
SIP. Care has to be taken to make sure that no additional bioburden is added to the
SIP while preparing and placing the SIP for sterilization validation. It is recom-
mended to prepare SIP in environmentally controlled conditions using the same
non-irradiated material to prevent additional bioburden and to simulate the final
product. Non-irradiated SIPs are validated using the test of sterility in a way that 17
of the 20 SIPs should show a positive test of sterility (i.e. presence of microorgan-
isms in a microbiological test) before irradiation and the same products will be
again subjected for the test of sterility after irradiation with verification of the
selected dose. Tests of sterility experiments are usually performed using soybean
casein digest broth.
5 Determination of Sterilization Dose
Once the material for sterilization is ready, the challenge is to identify and standard-
ize an irradiation dose appropriate for the material. The dose setting methods were
originally developed by Tallentire and subsequently modified as per requirement.
The method determines the probability of having a surviving microorganism after
irradiation in comparison to the initial number of microorganism prior to irradia-
tion. A sterilization dose for a product means the minimum dose that can be used for
irradiation for attaining a definite sterility assurance level (SAL). SAL as defined in
ISO document is the “probability for having a viable microorganism being present
on a product unit after sterilization”. This suggests that the probability of identify-
ing a microorganism on the material irradiated with this specific dose should be one
in one million units tested or 10−6. To reduce the harm created by the absorbed dose
of radiation by the material, it is necessary to understand the bioburden on the mate-
rial prior to sterilization. This subsequently allows control of the radiation dose
proportional to the bioburden. The current methodologies for determining the radia-
tion dose depend on the natural bioburden present on the material which is evalu-
ated by a series of test of sterility experiments performed in a standard microbiology
laboratory before and after irradiation. Once the bioburden is identified, the refer-
ence table provided by ANSI/AAMI/ISO 11137 standards may be followed to set
appropriate applied dose in kilogray (kGy) corresponding to the intensity of biobur-
den. This is considered as the reference SAL or verification dose. Verification dose
according to ISO is defined as the “radiation predicted to give a predetermined SAL
greater than or equal to 10−2 used in establishing the sterilization dose”. Dose set-
ting experiments should be carried out in an irradiator calibrated for its performance
according to ISO 11137-1.
5.1 Based on Bioburden Information
This method uses the bioburden data collected from the product to determine the
sterilization dose. A reference table to determine the sterilization dose values for
various products by determining their bioburden and the standard distribution of
resistance of the microorganism corresponding to the bioburden is projected. The
standard distribution of resistance values is described in terms of the decimal reduc-
tion dose (D10) values. D10 values as defined by ISO are the radiation doses (kGy)
required to kill 90% of the total number of microorganisms present on the product
by irradiation. The reference table provides the values for verification and steriliza-
tion dosages required to achieve the sterility assurance level of 10−2, 10−3, 10−4, 10−5
and 10−6 for a given value of Standard Distribution of Resistances (SDR) based on
its bioburden. The dosage value required to achieve a SAL of 10−2 is considered as
the verification dose, and the dosage value required to achieve a SAL of 10−6 is
considered as the sterilization dose.
Bioburden is usually calculated for individual products, and in case the biobur-
den is low per product, multiple products can be pooled to determine the average
bioburden per batch, called the batch average bioburden. Multiple batches can also
be pooled to form overall average bioburden. If batch average bioburden is higher
than overall average bioburden, the highest value for batch average bioburden will
be used to determine verification dose and vice versa if an overall average bioburden
is high. A minimum of 100 products will be subjected to irradiation with the verifi-
cation dose for validation. The highest dose to the product shall not exceed 10 % of
the calculated verification dose. After which, a sterility test is performed on each
irradiated product to determine the presence of microorganisms. If in case more
than three products showed the presence of microorganism on the test of sterility
experiment, then the verification dose has to be recalculated. If in case the verifica-
tion dose is acceptable, then the sterilization dose is calculated from the reference
table, the dose value corresponding to a SAL of 10−6.
5.2 etermination of Dose by Fraction Positive Information

D
from Incremental Dosing
This method provides a more homogenous D10 value based on the bioburden of the
products to be sterilized. In this method, bioburden is evaluated post-exposure of
products to a series of an incremental dose of radiation followed by the test of
sterility. That particular dose in which 99% of the products (99 out of 100) are nega-
tive for the test of sterility or are sterile will be considered as the verification dose.
This dose is expected to achieve a sterility assurance level (SAL) of 10−2 when used
for irradiation of the products. There are two different approaches to determine the
sterilization dose by incremental dosing method. First one is a general method
applied in most cases and the second method is applied in case of products with low
bioburden.
In the first method (method 2A), 20 products from each of the 3 batches will be
subjected to irradiation using 9 incremental doses starting from 2 kGy with an incre-
ment of 2 kGy. The dose at which only 1 out of 20 products was shown negative for
the test of sterility is considered as the first fraction positive (FFP) dose. The median
average of all the FFPs of the three batches is used to calculate the first fraction posi-
tive (FFP) dose. The first immediate dose in the increment series that will provide a
negative test of sterility for all the 20 products in all the 3 batches will be considered
as the dose that will be used for calculating the verification dose and designated as
d*. If the highest value of estimated dose (d*) of any individual batch differs by a
value of less than 5 kGy to the median average of all the three batches, then the
median average d* value is considered as the estimated verification dose (D*) that
will provide a sterility assurance level of 10−2, or else if the difference is equal to or
more than 5 kGy, the d* value of the highest batch is considered the estimated veri-
fication dose (D*).
For evaluation of the verification dose setting, 100 products from the batch that
has almost same d* and D* value are selected. The selected batch is designated as
CD* batch. These products from the selected batch will be irradiated by the esti-
mated verification dose (D*) with a maximum deviation of 1 kGy. D* is the initial
estimate of the dose that will help the product to achieve a SAL of 10−2. Post-
irradiation these products will be subjected to the test of sterility and the number of
positives is counted and is designated as CD*. The highest dose delivered will be
considered as the estimated dose and is designated as DD*. If the CD* values fall
within 1 to 15 and the irradiation dose employed does not exceed the estimated veri-
fication dose by 1 kGy, then the dose values are accepted as verification dose that
will achieve a SAL of 10−2. The first no positive (FNP) dose is then calculated based
on the CD* values which is the number of positives for the test of sterility experi-
ments. An additional 2 kGy dose is added to the highest dose values (DD*) propor-
tional to the increase in the number of positives in sterility test experiments as
mentioned in ISO standards.
To establish the sterilization dose, the estimated D10 dose values (DS) will be
required to achieve inactivation of 90% of a microbial population present on the
product. DS values are calculated from the FFP (first fraction positive) dose and the
first no positive (FNP) dose as follows:
DS 2 0.2 FNP FFP , where FN FFP is lessthan10 kGy
DS 0.4 FNP FFP , where FNP FFP is greater than or equal to10 kGy
Further, the final estimate of the verification dose is calculated as per the equation:

D DD log CD DS
The sterilization dose is then calculated based on the formula
Sterilization dose D log SAL log SIP 2 DS
where:
D** is the final estimate of the dose that will provide a 10−2 SAL
SAL is the preselected sterility assurance level
SIP is the portion of the product (sample item portion) used for determining
D** and DS
DS is an estimate of the dose required to inactivate 90 % of the microorganisms
The second method (method 2B) for sterilization dose estimation using fraction
positive information from incremental dosing uses the first method (2A) with minor
modifications. In method 2B, the entire product is used for the dose determination
process where the SIP is equal to one. In this method, a series of eight doses are
utilized starting from 1 kGy with an increment of 1 kGy. The highest dose delivered
at each increment should not exceed 10% or 0.5 kGy of the estimated increment.
The rest of the protocol remains the same for both the methods. The first no positive
(FNP) dose in the method 2B experiment does not exceed 5.5 kGy.
The sterilization dose is then calculated as follows:
DS 1.6 0.2 FNP FFP
Sterilization dose D log SAL 2 DS
where:
D** is the final estimate of the dose that will provide a 10−2 SAL
SAL is the preselected sterility assurance level
DS is an estimate of the dose required to inactivate 90 % of the microorganisms
surviving DD*
5.3 etermining Sterilization Dose by VDmax: Substantiation

D
of 25 kGy or 15 kGy as the Sterilization Dose
This method of substantiation of sterilization dose is also based on the determina-

tion of bioburden to establish the verification dose and thereby the sterilization
dose. This method is employed to those products whose batch average bioburden is
less than or equal to 1000 CFUs per product. The verification dose experiment is
conducted on ten products or portions of it, and the dose required to attain a SAL of
10−1 is determined. In case of products with an average bioburden of 0.9 and below,
the entire product will be used for verification dose determination, and in case of
products with bioburden above 0.9, SIPs can be used.
To perform the verification dose experiment, bioburden of individual products is
determined along with the overall average bioburden and the batch average biobur-
den. If the highest bioburden value is more than two times the difference between
the batch average bioburden and overall bioburden, the determined highest value for
bioburden is used for further determination of the verification dose. Based on the
bioburden values obtained, a reference table is provided in the ISO standards to
calculate the corresponding values of VDmax25 and SIP dose reduction factors for
levels of average bioburden less than or equal to 1000 CFU.
The formula for calculating VDmax is as follows:

SIPVDmax 25 SIPequal to1.0 VDmax 25 SIPdose reduction factor loogSIP
The estimated verification dose obtained (SIP VDmax25) is used to perform the veri-
fication dose experiment using ten products from each batch that was used to deter-
mine the estimated bioburden. After irradiation of these products by the verification
dose, a test of sterility is carried out on the irradiated product. If only one product
per ten irradiated products is found to be positive for the test of sterility experiment,
the VDmax25 value is accepted, in case of two positive results, a confirmatory veri-
fication dose experiment is conducted, and in case of three, the dose is rejected. For
VDmax25 determination for a single batch, ten products from the batch are used, and
in case the bioburden is low, more products are pooled.
In cases where the batch average bioburden of product is less than or equal to 1.5,
a different substantiated dose of VDmax15 is used. VDmax15 dose substantiation is
usually performed for irradiation of entire product item (SIP = 1). The procedure to
be followed in general is similar to the determination of VDmax25 values. The average
burden estimated will be used to obtain the VDmax15 dose values, from the reference
table provided in ISO standards for determining VDmax15 dose levels for products of
average bioburden less than or equal to 1.5. In both cases of substantiation of 25 kGy
or 15 kGy as the sterilization dose, alternate sterilization methods have to be employed
if more positive test of sterility experiments is reported both in performance of verifi-
cation dose experiment and in the confirmatory verification dose experiment.
6 Sterilization Dose Audits
After establishing the sterilization dose for the products to be irradiated, it has to be
ensured that the performance of the irradiator and the dose delivered meet the
requirements of irradiation. This is ensured by frequent and periodic audits where
the irradiator meets the operational requirements and also the dose delivered is
equivalent to the dose calculated for irradiation of the particular product. In a steril-
ization dose audit, the above-mentioned methods are followed to reverify the proce-
dure and the recorded results. A sterilization dose audit generally contains the
following steps:
• Obtain details of the product.
• Determine the average bioburden.
• Perform the verification dose experiment.
• Interpretation of results.
While performing the test of sterility experiment for the interpretation of results,
if no more than two positive tests of sterility are obtained, the sterilization dose audit
is accepted. If three or more positive tests of sterility are obtained in a sterilization
dose audit and the results cannot be ascribed to the incorrect performance of tests of
sterility or incorrect delivery of the verification dose, then the sterilization dose
might be inadequate, and immediate steps to augment the sterilization dose should
be established.
7 Dosimetry and Dosage Measurement
Dose measurement is another integral part of the validation for radiation steriliza-
tion. Appropriate dosage measurement should be done at all stages of the steriliza-
tion process, such as development, validation and routine observations abiding both
the national and international standards. Measurement of radiation dose can either
be direct or indirect. A direct dose measurement would be from the location of inter-
est, and if the location is remote, the measurement can be done using factors deter-
mined during the operational and performance qualification studies.
7.1 Dosimetry System Selection and Calibration
Dosimetry and dosimetry systems are detailed in ISO 11137-3: 2017, “Sterilization
of health care products—Radiation: Guidance on dosimetric aspects of develop-
ment, validation and routine control”. The dosimetry system used in the develop-
ment, validation and routine observation of the process of radiation sterilization
should provide both accurate and precise measurements over a broad dose range.
This accuracy should sustain under all the conditions of use so far mentioned in the
ISO. It is possible that different dosimetric systems require dose ranges that differ
in the process of either development of radiation sterilization or validation or rou-
tine observation. Dosimeter system should be well-calibrated and the interpretation
of its readout should be well supported by data. Another important aspect is the
presence of competent and trained staff to handle both the calibration and operation
of the dosimetric systems which requires special skill and mandatory training. The
dosimeter build-up cost should be reasonable and non-toxic in nature. Additionally,
the measurements of absorbed dose for sterilization of healthcare products are done
with the placement of water as the background. Thus all calibration of dosage mea-
surement needs to be done using water. The calibration of measurement traceability
for both direct and indirect measurements can be defined as the best estimate of
dose for the respective dose measurements.
7.2 Calibration of Dosimetric Systems
Calibration is the most important part of the dosimetric assessment and should be
done prior to the actual measurement. Dose measurements are dramatically influ-
enced by external factors such as relative humidity, temperature, exposure to light,
rate of irradiation and time between irradiation and measurement. Variations among
different batches of dosimeters with respect to their response to different external
factors are mentioned above. Thus, it is imperative to calibrate the dosimeters in the
actual conditions that the measurements are planned to be taken and every time a
new dosimeter is used. The calibration curve supplied by the dosimeter manufac-
turer is useful to understand the expected response of dosimeter, but it should not be
used as the standard, and its validity should first be verified. The dosimeter should
be calibrated in the presence of the irradiator being used and not from the irradiation
carried out by a different irradiator.
The calibration irradiations and reference standard dosimeters should be sup-
plied by a national authority on standards with a calibration certificate to ensure
traceability of dose measurements. The accurate dose measurement also requires
the calibration and consistent performance of other parts of the dosimetry system.
Thus all the equipment and instruments associated with the dose measurement sys-
tem need to be calibrated, or their performance should be tested. It is also important
that the calibrations remain valid for some specific period, and to maintain this
validity, the calibration is verified using the set reference dosimetry system at peri-
odic intervals. If there is a significant deviation from the set calibration due to
change in the source of the radiation or its reduced performance, this should be
rectified immediately. Variations in the environmental factors such as temperature
and humidity can also affect the dosimeter response which demands its peri-
odic check.
The dosimetric systems are also known to be influenced by the period between
the time of termination of irradiation and the subsequent measurement. The extent
of this influence can depend on the way the dosimetric system is stored. Immense
care should be taken while storing the dosimetric systems, and the effects of the
vagaries of nature should be avoided, or if unavoidable, these uncertainties or devia-
tions should be taken into account.
7.3 Uncertainty in Dose Measurement
As previously discussed, the dose measurements should be traced back to an authen-

tic and credible national or international authority on standards, and the level of
uncertainty should be known. All potential sources of measurement uncertainties or
standard deviations should be noted and their magnitudes should be evaluated. To
make things easier and faster, measurements on the combination of uncertainties
may be accounted than assessing them individually. Both direct and indirect types
of measurements require an estimate of uncertainties or standard deviations. This is
since measurements from a dosimeter on the same instrument would give a scatter
of values as multiple factors affect the response of the dosimeter. These factors can
depend on the dosimeter used, the skill of the operator or the environment. Thus it
is important to know the uncertainties and the parameters under which they exist. As
discussed earlier, the dose measurement is the best estimate of the true value of the
absorbed dose by the products, but due to inherent uncertainties in the measure-
ments, the true value of the absorbed dose would either be less or more of the dose
measurement. The dose measurement follows a normal distribution with a Gaussian
curve, with the peak of the curve being the best estimate value. As with all Gaussian
distributions, the values lying before and after the peak become increasingly less
probable, with the width of the curve being the standard deviation (sigma, σ). As
mentioned above, it is important to identify all potential sources of uncertainty
while measuring dose followed by their individual or combination quantification.
Each component of the uncertainty is then assigned an effective standard deviation,
and all the standard deviations are combined to produce an estimate of overall
uncertainty. Since an overall uncertainty comprising both random and systemic
influences is obtained, it provides a quality of the measurement of dose. An “uncer-
tainty budget” represents the tabulated form of individual forms of uncertainties,
their values and the method of estimation.
In the case of dose measurements in radiation sterilization, the uncertainty is
associated with the direct or the indirect method of measurement. The uncertainty
components of the direct or the indirect ways of dose measurement in an irradiation
container are as follows. Given below is not a checklist but is a guideline to establish
the uncertainty budget:
• The uncertainty reported by the calibration standards laboratory
• The uncertainty that arises due to the mathematical fitting of the calibration
function
• The uncertainty that is related to the effect of environmental factors that influ-
ence dosimeters during calibration and usage
• The uncertainty related to the reproducibility factor of the dosimeter
• The uncertainty for indirect measurements derived from dose mapping
• The uncertainty that arises from variations in the irradiator dose delivery between
the irradiation of the dosimeter and the irradiation of the container where the
dose is measured from
7.4 Establishing the Maximum Acceptable Dose
To conduct tests establishing maximum acceptable dose, products that have been
irradiated to doses that are equal or greater than the highest anticipated dose should
be utilized for the sterilization procedure. Here again, the true estimate of the maxi-
mum dose received during the sterilization procedure is influenced by the features
of the irradiator and the loading pattern of the product. This true value of maximum
dose changes if the irradiator or the loading pattern of the product changes. Further,
the surface properties of the product used should be studied carefully to ensure that
the dose is determined accurately and that the dose distribution is uniform through-
out the surface of the product. Care should be taken about the interpretation of test
results and assignment of the maximum acceptable dose. This is because the prod-
uct used for establishing the irradiation doses is tested for a range of doses and the
maximum acceptable dose is the lowest dose received by the product for which the
properties were found to be acceptable. It is also possible that the maximum accept-
able dose lies out of the calibrated range of the available dosimetry systems. In such
times, the dose can be delivered in increments while monitoring each dosage. The
final, total dose is the sum of these incremental doses. However, incremental doses
would have its side-effects of either being inefficient or changing the performance
of the product.
7.5 Establishing the Sterilization Dose
The method of establishing the sterilization dose depends on the product to be irra-
diated within a dose limit that specifies tolerance. There should be no compromise
on the outcome of the dose establishment method, where the dosimetry system
should be adequately accurate and precise to ensure that the dose measurements are
within the limits of the tolerance specified by this method. The achievement of
doses in the tolerance limit is based on the measurements used to arrive at the mini-
mum and the maximum dose for the product at any given point. It is also important
to configure the product during irradiation to achieve minimum variation in dose,
both individually and between product items. In some cases, it may also be required
to disassemble and repack the product to achieve the acceptable distribution of the
doses on the product. The product bioburden might get affected due to dismantling
and repackaging of the product. Detail mapping of dose for individual products
would be required especially in the case of electron beam irradiation. While dose
mapping, it may not be necessary to have the same doses as those used during ster-
ilization. By using different doses, the dosimetry system gets enabled to be more
accurate in its operating range and thus improving the overall accuracy of the dose
mapping. Simultaneously, it is also important that the different doses do not alter the
dose distribution for the product. Even here, to obtain and reduce measurement
uncertainties of dose to products, multiple rounds of dose mapping exercises need
to be performed on the mentioned product. If not, multiple dosimeters should be

placed in the irradiation container to identify the locations of and measure the limits
of the doses. The measurement uncertainty thus obtained should be taken into
account while performing irradiations for sterilization to ensure that the specified
doses of tolerance are met.
For usage of gamma rays for irradiation, the special irradiator is designed for
irradiation at lower doses than the sterilization dose or a defined location such as on
a turntable or a special irradiation pathway designed for low dose irradiation. For
electrons or X-rays used for irradiation, lower doses can be achieved by reducing
the irradiator beam current, increasing the speed of the conveyor or reducing the
product residence time in the beam. Extreme care should be taken while determin-
ing the beam parameters to obtain low doses for sterilization. For example, in some
electron accelerators, changing the beam current might change the electron energy,
thus affecting the dose distribution. For irradiation using the electrons, the product
can be covered by the material to scatter the electrons and produce a more dose
distribution. The surrounding material should be characterized with its known
nature. X-ray irradiations and their unidirectional beam may produce high doses of
irradiations, which might affect the product performance. In this case, too, the prod-
uct can be surrounded by some material that leads to a uniform distribution of X-ray
irradiation.
7.6 Installation Qualification
This section demonstrates the supply and the installation of the irradiator according
to its specifications. The characteristics of the beam for an electron or X-ray irradia-
tor should also be determined. This includes the respective energies, average beam
current, scan width and scan uniformity. The details of the characterization depend
on the design and the construction of the irradiator. The methods involved in deter-
mining the electron beam features involve dose measurement traceable to a national
or international authority on standards. During the installation qualifications, it is
required to measure either the electron beam energy or the X-ray energy. Wherever
the design of the X-ray irradiator permits, it is normal to measure the electron beam
energy incident on the target in accordance with the standard methods. Whereas for
electron accelerators the beam is scanned and its pulse is taken, there should be suf-
ficient overlap between the pulses and the scans to provide the required dose unifor-
mity on the product surface. The relationship between several parameters of the
electron beam such as the scan frequency, scan width, pulse repetition rate and the
conveyer speed relative to the cross-sectional distribution of the unscanned electron
beam at the surface should be considered. In the case of gamma irradiators, there are
no such dosimetric requirements. Depending on the irradiator specified, it is neces-
sary to carry out the dose measurements and/or dose mapping in the installation
qualifications. This is to verify that the operation is within specifications of dose rate
and dose uniformity.
7.7 Operational Qualification
After successful installation of the irradiator, the purpose of the OQ is to demon-

strate the operational capability and deliverance of appropriate dosage within
defined acceptance criteria. This can be achieved by determining the dose distribu-
tions and dose magnitude by dose mapping exercises and further relating these dose
attributes to process parameters. A crucial part of the OQ is repeated measurements
to show consistent and stable operation and should be performed at specified inter-
vals. Following any change that might affect the dose or dose distribution, such as
source replenishments in the gamma facilities or modifications to conveyor systems,
it is all the more important to have repeated measurements of the dose. The strategy
for OQ should be based on the anticipated methods of operation of the irradiator.
7.8 Dose Mapping for Gamma Irradiators
The irradiator can be characterized with respect to the distribution and reproduc-
ibility of the dose in defined loading configurations. Similarly, to establish the effect
of process interruption on the dose throughout the container, dose mapping should
be done by placing the dosimeters in the irradiation containers filled with a material
of homogeneous density up to their design limits. These materials can be sheets or
plates of expanded polyethylene foam, cardboard or wood. Two such dose mapping
exercises should be carried out, one with a material of lower density, the density at
which the irradiator is planned to be used, and another with a material of higher
density fitting the range. As discussed earlier for PQ, OQ should be done for every
pathway through the irradiation container. The relationship between the irradiation
time and the minimum dose is non-linear in the case of gamma irradiator units. In
such a case, more than two dose mappings over a range of different densities are
required to determine the performance characteristics. At least three irradiation con-
tainers should be used to map the doses for each chosen density to allow determina-
tion of variability of dose and dose distribution within and between containers. For
a new irradiator, a greater number of replicate exercises would be required for dose
mapping.
During dose mapping, separate dosimeters, dosimeter strips or dosimeter sheets
should be placed within the irradiator container in sufficient quantity to determine
dose distribution. The number of dosimeters to be placed depends on the size of the
irradiation container and the design of the irradiator. For requalification purposes,
the data from earlier exercises can be used to optimize the positioning of the dosim-
eter, so that the dosimeters can be focussed in the areas of potential minimum and
maximum dose and high dose gradients. What can be useful in optimizing the posi-
tioning of the dosimeters and reducing the number of dosimeters is mathematical
modelling techniques with appropriate benchmarks. Thus data obtained from OQ
dose mapping exercises can be used to establish materials of different densities, the
relationships between timer settings, conveyor speed and the dose magnitude at a
defined location within the container. Another correlation that can be established
would be between the dose uniformity within the irradiation container and the mate-
rial density. Approximations of these relationships can be supplied by the irradiator
manufacturer or as suggested earlier can be obtained by calculation using mathe-
matical models. These calculations obtained through mathematical modelling can
be used to refine the approximate values provided by the manufacturer.
Process interruption is an important aspect of operational qualification. It causes
a change in magnitudes of the minimum and maximum doses and also the place at
which these extremes occur. Thus, it becomes important to assess the effect of pro-
cess interruption on dose throughout the irradiation container. Here, specific dose
measurements can be carried out using a container having dosimeters located in
areas which are expected to be most influenced by source and are interrupted when
the container is close to the source. This effect of process interruption is assessed by
comparing the results with those where the dose mapping exercises were carried out
under normal process conditions. Here again, mathematical modelling and follow-
up calculations can help in understanding the process interruption.
Dose mapping should be performed for special conveyor systems or fixed loca-
tions in the irradiator designated for manually placing the products. The product
present in the main irradiator pathway may also influence the dose distribution at
the above locations. Considerations should thus be given to the effect on the calibra-
tion and uncertainty associated with the use of such conveyors and locations with
respect to dose rate or temperature. A dosimetry system calibration might be estab-
lished for each irradiator pathway and a fixed location, generating a new calibra-
tion curve.
The dose mapping in performance qualification (PQ) can be reduced by deter-
mining the effects of partially filled irradiation containers and loading of the product
in the centre of the container towards the purpose of achieving desired dose unifor-
mity ratio. The density of the processed product can have effects on the magnitude
and distribution of dose. An acceptable range of densities that can be processed
together based on the results obtained from the dose mapping exercises should be
available. The design of the irradiator and how density changes are introduced in the
irradiator can also affect the dose magnitude and distribution. This density should
fall in the range of densities that are processed routinely. Dose mapping results from
an irradiator which faces changes in densities when compared to those containers
where there has been no change in density.
7.9 Dose Mapping for Electron Beam Irradiators
Dose mapping should be carried out for the energy of the beam irradiator used for
product irradiation. In case more than one energy or scan width is being used, then
the OQ dose mapping should be carried out for each energy and scan width to cover
the operational limits used for product irradiation. Similar to the procedure followed
for gamma radiators, only one density should be used for OQ in the electron beam
irradiators, but more detailed information can be obtained by using more than one
density and single-sided irradiation, with densities being within the limits of the
density range for which the irradiator is intended to be used. By using single-sided
irradiation, maximal information about the consistency and stable operation of the
irradiator can be obtained. Below are the OQ followed for electron beam irradiators.
Electron beam irradiators are designed in such a way that the containers are con-
veyed through the radiation field with or without separation between the containers.
This can be done by:
(a) Designing fixed spacing between containers that results in irradiation of only
one container by the field radiation at a time
(b) When the product batches are changed
(c) When the radiation parameters are changed
The spacing, differences in the densities or material configurations between the con-
tainers play an influential role in the dose distribution within each container.
Therefore, dose mapping carried out to examine such effects gives information that
is useful for PQ dose mapping.
During dose mapping, separate dosimeters, dosimeter strips or dosimeter sheets
should be placed within the irradiator container in a three-dimensional array, includ-
ing the surface. The number of dosimeters to be placed depends on the size of the
irradiation container, the design of the irradiator and the energy of the electron
beam. For requalification purposes, the data from earlier exercises can be used to
optimize the positioning of the dosimeter, so that the dosimeters can be focussed in
the areas of potential minimum and maximum dose and high dose gradients. What
can be useful in optimizing the positioning of the dosimeters and reducing the num-
ber of dosimeters is mathematical modelling techniques with appropriate bench-
marks. Thus data obtained from OQ dose mapping exercises can be used to establish
electron beam irradiators, the relationships between features of the beam, conveyor
speed and the dose magnitude at a defined location within the container. Process
interruption is an important aspect of operational qualification. It causes a change in
the magnitude of the minimum and maximum doses and also the place at which
these extremes occur. This effect can be determined by using dosimeters at the
places where the effect of process interruption is the greatest. The effect of process
interruption should be assessed for different irradiation conditions and different
causes of interruption. The effect can vary at high conveyor speed with high mass
product and low conveyor speed with low mass product, for example. Interruption
occurring from the safety system, from the electron beam and from the conveyor
might have different effects on dose which should be assessed. In routine process-
ing, the allowable number of interruptions that can occur without doses to the prod-
uct falling outside the specification should also be considered.
The above dose mapping practices for electron beam irradiators need to be car-
ried out for operational qualification for the X-ray irradiators.
7.10 Performance Qualification
There are several factors related to the product and irradiator that influence the dis-
tribution of dose on the product. Dose mapping exercise in PQ generates important
data which can be used to identify locations and magnitude of both minimum and
maximum doses to the product. Dose mapping should be carried out scrupulously
to identify the magnitudes and locations of the minimum and maximum doses on or
in the product that is being irradiated. This can be used to calculate the relationship
between these doses and the dose at the routine monitoring positions. This can also
be useful in determining the values for process parameters, such as timer setting or
conveyor speed which calibrated to meet the specified sterilization dose without
going beyond the maximum acceptable dose. As discussed in the earlier section,
information obtained from the OQ dose mapping can provide the initial information
required for the placement of dosimeters for the PQ dose mapping. PQ needs to be
repeated if OQ measurements show that there is some variation with the PQ mea-
surements due to changes in the irradiator or the product. Otherwise, there is no
need to repeat the PQ on a regular basis.
Performance Qualification for Irradiators
During dose mapping, individual product carton is arranged within an irradiation

container in such a way that defines the intended routine loading pattern. Key prod-
uct characteristics such as carton dimensions and weight, allowable variations in
these parameters, the dose specifications for the product and details obtained from
OQ dose mapping should be considered. Products with low density tend to be
homogenous so that the orientation of individual products within the irradiation
container does not have a significant effect on dose distribution when irradiating
with gamma rays. But for non-uniform products with high-density components and
void spaces, a specific orientation of products might be required within each irradia-
tion container. If the product can move within the product carton, then several pos-
sible orientations of the product within the carton should be used for dose mapping,
and a worst-case scenario should be established with respect to dose distribution.
7.11 Dosimetry Placement
Dosimeters should be placed in an irradiated container and should be mapped in

sufficient numbers to determine the minimum and maximum dose locations. Data
obtained from the OQ dose mapping might be used to guide the placement of the
dosimeter, focussing the dosimeter on expected locations. The dosimetry system
should have a high spatial resolution that allows measurement of dose gradients that
might occur at the material interfaces. Some products can cause localized shielding
or scattering; it might get necessary to use thin film dosimeters to obtain the required
spatial resolution. For irradiation of low-density products by gamma rays, it is
appropriate to place the dosimeters outside the sterile barrier system of the product.
For example, products made up from low atomic number elements do not contain
material with densities or masses enough to cause local shielding or scattering to
other areas. Otherwise, for denser materials, it is advised to place the dosimeters
inside the sterile barrier system of product to determine the minimum and maxi-
mum doses. For example, an implant made from titanium has a higher density as
compared to the packing material and therefore would require placement of dosim-
eters inside the sterile barrier system.
7.12 Replicate Dose Mapping Exercises
Variability in measured doses can occur due to irradiator variation, product varia-
tion and dosimeter reproducibility. These variations then require replicate dose
mapping exercises, at least three, to obtain more information. A separate irradiation
container is recommended to be used for dose mapping to obtain statistically valid
data. For such replicate exercises, it could be sufficient to place dosimeters only in
areas of dose extremes.
7.13 Analysis of Dose Mapping Data
Dose mapping data are analysed such that:

(a) A routine monitoring position related to the locations of minimum and maxi-
mum doses to product is defined
(b) The components of uncertainty related to the use of routine monitoring position
to make indirect measurements are defined
7.14 Routine Monitoring and Control
The measurement of dose at the routine monitoring position during processing is

used to verify that the minimum dose is equal to or more than the sterilization dose
and that the maximum dose does not exceed the maximum acceptable dose. These
acceptable doses are given in the process specification. Both types of dose measure-
ments, direct and indirect, represent the best estimate of dose for product confor-
mity. Thus, values from dose measurements should not be corrected by uncertainty
measurements associated with it.
7.15 Frequency of Dose Measurements
The measurement of dose at the routine monitoring position provides process infor-
mation that is independent of any other control or measurement system of the irra-
diator. The frequency of dose measurement should be chosen based on the features
of the irradiator and other processes. The amount of product that might be discarded
following an out-of-specification dose measurement could also be an important
consideration in setting this frequency.
For gamma rays, electron beam or X-rays-mediated irradiation, dosimeters are
typically placed at the beginning and end of each run of a product including a par-
ticular category. Also, the dosimeters should be placed such that at least one dosim-
eter is within the irradiator at all times. Plotting of all routine dosimetry measurements
on a chart provides valuable information on the overall performance of the irradia-
tion process. This enables taking appropriate preventive actions before any out-of-
specification measurements occur. This approach can also be extended to full
statistical process control.
8 Conclusion
This chapter is to provide an overview of recommendations from ISO for installa-

tion and process validation of sterilization of medical devices by employing radia-
tion. However, for any use of the relevant content, it should be referred back to the
ISO standard guidelines 11137. Compliance with these requirements for the process
of radiation sterilization ensures that the process followed is reliable and reproduc-
ible with a reasonable level of confidence. ISO 11137 should be part of the quality
management of all organizations performing radiation sterilization to ensure their
quality of sterilization. These guidelines and regulations will bring in similar stan-
dards for radiation sterilization process across the globe.
References
ISO 11137-1:2006, Sterilization of health care products — Radiation — Part 1: Requirements for
the development, validation and routine control of a sterilization process for medical devices.
ISO 11137-2, Sterilization of health care products — Radiation — Part 2: Establishing the steril-
ization dose.
ISO 11137-3, Sterilization of health care products – Radiation – Part 3: Guidance on dosimetric
aspects of development, validation and routine control.
ISO 11737-1, Sterilization of medical devices — Microbiological methods — Part 1: Determination
of a population of microorganisms on products.
ISO 11737-2, Sterilization of medical devices — Microbiological methods — Part 2: Tests of ste-
rility performed in the definition, validation and maintenance of a sterilization process.
ISO 13485, Medical devices — Quality management systems — Requirements for regulatory
purposes.
ISO 10993-1:2003, Biological evaluation of medical devices — Part 1: Evaluation and testing.
ISO 10012, Measurement management systems — Requirements for measurement processes and
measuring equipment
ISO/ASTM 51608, Practice for dosimetry in an X-ray (Bremsstrahlung) facility for radiation
processing
ISO/ASTM 52303, Guide for absorbed-dose mapping in radiation processing facilities
ISO/ASTM 51261, Practice for calibration of routine dosimetry systems for radiation processing
ISO/ASTM 52701, Guide for performance characterization of dosimeters and dosimetry systems
for use in radiation processing
ISO/ASTM 51707, Standard guide for estimation of measurement uncertainty in dosimetry for
radiation processing
ISO/ASTM 51649, Practice for dosimetry in an electron beam facility for radiation processing at
energies between 300 keV and 25 MeV
ISO/ASTM 52628, Standard practice for dosimetry in radiation processing
Tallentire A. Aspects of microbiological control of radiation sterilization. J. Rad. Ster. 1973,1
pp. 85–103.
Tallentire A., Dwyer J., Ley F.J. Microbiological control of sterilized products. Evaluation of
model relating frequency of contaminated items with increasing radiation treatment. J. Appl.
Bact. 1971, 34 pp. 521–34
Tallentire A., & Khan A.A. The sub-process dose in defining the degree of sterility assurance.
In: Gaughran, E.R.L and Goudie, A.J. (eds.), Sterilization by ionizing radiation, Vol. 2. Montreal:
Multiscience Publications Ltd., 1978, pp. 65-80
Kowalski J. et al. Field evaluations of the VDmax approach for substantiation of a 25 kGy ster-
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67 pp. 137–141
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to establishing verification dose. Radiat. Phys. Chem. 1999, 54 pp. 55–64
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ISO 11135: Sterilization of Health-Care
Products—Ethylene Oxide, Requirements
for Development, Validation and Routine
Control of a Sterilization Process
for Medical Devices
Indumathy Jagadeeswaran and Sunitha Chandran
1 Introduction
Medical devices produced under standard manufacturing conditions might have

microorganisms on them, and these microbiological agents should be decontami-
nated in accordance with quality management systems (ISO 13485) and thereby
transform the non-sterile medical devices into sterile ones suitable for its intended
clinical use. Ethylene oxide (EO) is used as a sterilizing agent for heat and moist-
sensitive medical devices. EO is a colorless gas that is toxic, flammable, and explo-
sive and requires caution during its usage and handling. Sterilization achieved by
EO can be best described by the exponential relationship between the extent of EO
treatment and surviving microorganisms on a medical device. To ensure appropriate
microbicidal activity of EO and sterility of medical devices, compliance with the
requirements of ISO 11135 is recommended, which has been discussed in this chap-
ter. The specifications of this standard vary from country to country (refer EN 556-1
and ANSI/AAMI ST67) by discretion of the regulatory authorities. Though ISO
11135 has grouped together and presented the activities required in sequential man-
ner, ISO 11135 does not require these activities to be performed in the same order
mentioned. It also does not specify the activities to be carried out by individual or
organizations, considering the involvement of number of separate individuals and/
or organizations in the accomplishment of sterilization processes.
I. Jagadeeswaran (*)
Department of Biological Sciences, Southern Methodist University, Dallas, TX, USA
S. Chandran
SCTIMST TIMed, Biomedical Technology Wing, Sree Chitra Tirunal Institute for Medical
146 I. Jagadeeswaran and S. Chandran
2 Selection of Sterilization Process
Selection of a suitable sterilization process and tolerance level is of utmost impor-

tance for the normal functionality of the medical device. Factors such as material
property, design characteristics, packaging, loading configuration and compatibility
with EO, are to be considered for selection of an appropriate sterilization process.
In health-care facilities, efficacy of sterilization process adopted can be influenced
by several factors such as sterilization equipment availability; attainment of specific
conditions by the equipment; sterilant to be used (100% EO or EO mixed with dilu-
ent gases); its concentration; tolerance level of the physical parameters like tem-
perature, humidity, pressure, etc.; residual amount of EO and/or its reaction
products; and outcome of process development.
Sterility assurance level (SAL) is the probability of a single microorganism to
remain viable, post-sterilization. Bioburden is one of the most commonly used
parameters to assess SAL. The location within the medical device, where sterility is
most difficult to achieve, might have reduced sterilant penetration and thereby be
more likely to have significant amount of bioburden. Therefore, the aspects to be
considered for appropriate placement of biological challenge and achievement of
the required SAL include length and inner diameter of lumens, diffusion efficiency
of EO, absorbance of both the product and material, load configuration, and size. To
ensure that sterilization process continues to meet or maintain the required SAL,
any changes to the equipment, process, product, and packing should be evaluated
and noted.
The number and types of microorganism should be monitored as per ISO
11737-1. Selection of appropriate sterilization process is required to achieve the
acceptable SAL. An appropriate sterilization process for a medical device is estab-
lished by use of microbiological testing (cycle lethality tests) and other analytical
tools. The standard also recommends that desired storage conditions for EO with
specifications like concentration, dilution, and shelf life should be specified and fol-
lowed. While establishing an appropriate sterilization process, impact of the steril-
ization process parameters (temperature, time, humidity, pressure changes/rates and
EO concentration) and their tolerance on the functionality of the medical device
should be assessed.
3 Processing Cycle, Temperature, Time and Pressure
EO sterilization process includes phases such as preconditioning, sterilization cycle,

and aeration. Preconditioning the medical devices at a defined temperature and
humidity prior to EO exposure helps in controlling the relative humidity of the prod-
uct and reduces the duration of the sterilization cycle. Sterilization achieved by EO
is affected by the moisture content of microorganisms, and low levels of humidity
may increase microbial resistance. Conditions or parameters that affect the
ISO 11135: Sterilization of Health-Care Products—Ethylene Oxide, Requirements… 147
microbial effectiveness of sterilization process (i.e., process variables) for precondi-

tioning phase include time, temperature, humidity, and transfer time. Precautions
should be taken to maintain temperature and humidity within the desired range
throughout the conditioning phase. A maximal time between the preconditioning
phase and start of sterilization cycle (i.e., transfer time) needs to be established.
Generally, in health-care facilities, optimum transfer time is not more than 60 min.
Sterilization cycle is carried out in a sealed chamber to reduce the viable number
of microorganisms on the medical device. Sterilization process includes air removal,
chamber leak test, inert gas addition (if applicable), conditioning (if applicable), EO
introduction to chamber, specified exposure time to EO, removal of EO, flushing (if
applicable), and air/inert gas admission. The process variables for sterilization
phase include exposure time, temperature, humidity, EO concentration, and
pressure.
Proper aeration is a crucial phase which helps in clearing EO residues from the
sterilized product/package. Residues of EO and its reaction products above the spe-
cific exposure limits are toxic. EO set points and tolerance levels are outlined in ISO
10993-7. The process variables for aeration phase include time and temperature.
Precautions should be taken to maintain a consistent temperature, fresh airflow, and
air recirculation in the aeration chamber for reproducible results. Due to the toxic
nature of EO and chances of residual amounts to be present on the medical device,
it is recommended to maintain material safety data sheet (MSDS) or analogous
safety information for the EO concentration or dilutions used. Also precautions for
personal health and safety should be specified.
The sterilization process parameters to be established for each phase mentioned
earlier include:
(i) Preconditioning room (if used):
(a) Temperature and relative humidity range
(b) Time set point and time range
(ii) Sterilization chamber:
(a) Vacuum and pressure levels and rate of pressure change
(b) Temperature set point and range
(c) Humidity control set point and range
(d) EO and diluent gas (if used) injection pressure set point and range
(e) EO dwell time
(f) In-chamber gas flushing setting (if used)
(iii) Aeration room (if used):
(a) Temperature set point and range
(b) Time set point and range
(c) Airflow/changes parameters
Considering the number of establishing parameters, it is impractical to assess the
tolerance of all possible combinations of variables. Therefore, process variables
with the greatest impact on the safety and functionality of the medical device and/
or its packaging device should be selected and validated. ISO 11135 may be referred
for further details. If concentration of EO used for the sterilization process is outside
the widely accepted range, microbial effectiveness should be validated.
Environmental consequences and measures to be followed to minimize the hazards
of EO sterilization, while releasing the product or exhaust, should be identified and
documented.
4 Routine Control, Efficacy, and Reproducibility
Periodic monitoring helps in validating specific sterilization process to meet the

expected SAL for the sterilized medical device. Routine monitoring ensures that the
process parameters specifications have been met for each sterilization cycle. The
process challenge device (PCD) is designed to constitute a defined resistance to a
sterilization process and is used to assess efficacy of the sterilization process. An
external PCD is used for routine microbiological monitoring of production cycles.
For routine monitoring and control of the sterilization process, use of internal PCD
such as biological indicators (BIs) is commonly preferred. For BIs to be used as part
of sterilization establishment process, it shall comply with ISO 11138-2:2017, resis-
tant to EO exposure and placed at an appropriate place in the medical device to pose
a challenge equivalent or greater than the challenge posed by the natural bioburden
at the most difficult location to be sterilized within the medical device.
Validation includes installation qualification (IQ), operational qualification
(OQ), and performance qualification (PQ), and all these validations need to be done
prior to testing of the sterilization procedure. IQ ensures proper installation of
equipment and its ancillary items as specified for EO sterilization. OQ demonstrates
the ability of the equipment to meet the sterilization process variable requirements,
and PQ ascertains that the product has been subjected to all the process parameters
specified and meets all the requirements to be considered as sterile device. For addi-
tional information on the selection, methods used, incubation time, and interpreta-
tion of the BIs, ISO 14161 may be referred. Health-care facilities recommend
decontamination/cleaning process prior to terminal sterilization for effective and
adequate bioburden reduction. The rate of microbiological inactivation provided
shall be determined by biological indicator/bioburden and/or the overkill approach.
(a) Biological Indicator/Bioburden Approach
Bioburden method combines the knowledge of resistance of biological indicator
and the bioburden population for a given sterilization process to establish the steril-
ization cycle and exposure time. This method is used if the bioburden levels in the
medical device are relatively consistent over time and their resistance is equal to or
less than the resistance of the BI. The resistance of the internal PCD shall be dem-
onstrated either by time-graded exposures or by population-graded BI exposed to
EO. Keeping other parameters constant, lethality of the sterilization process shall be
determined by one of the two commonly used microbiological test methods in

accordance with ISO 11737-1 and 11737-2. The first method (direct enumeration)
consists of enumeration or physical count of the survivors, and the second method
(fraction-negative) uses growth/no growth during fractional cycles.
(b) Overkill Approach
Overkill approach is a widely accepted method based on inactivation of refer-
ence microorganisms. This method is used if the total inactivation time of bioburden
level in the medical device to be sterilized is demonstrated to be less than the total
inactivation time of the BI (internal PCD). The sterilization process achieved using
this manner is often conservative and use a treatment that exceeds the acceptable
criteria to achieve the specified requirements for sterility. Two commonly used
methods in this approach are half cycle and cycle calculation approach. The half
cycle approach demonstrates total inactivation of the 106 challenge BIs at a half
cycle exposure time. Cycle calculation method exposes the internal PCDs to the
experimental cycle, removing the challenge and testing for survivors, which can be
used to calculate the cycle necessary to achieve the required SAL for the medical
device. Among these methods, half cycle is most commonly used by medical
devices manufacturers and health-care facilities due to its relative ease of use and
conservative SAL obtained.
Chemical indicators are also used, but they may not be considered as sole means
of establishing sterility. Internal chemical indicators do not assure sterility; they
allow detection of procedural errors (i.e., incorrect packing, incorrect loading, or
overloading of sterilizer chamber) and equipment malfunctions including inade-
quate pre-conditioning. If chemical indicators are used as part of sterilization pro-
cess, they shall comply with ISO 11140-1 and will be used in conjunction with other
methods such as microbiological and physical monitoring.
Parametric release method gathers information on physical processing parame-
ters such as chamber relative temperature, humidity, and EO concentration during
EO exposure time, to ensure that the sterilization process has been achieved in the
medical device, without the use of BIs.
(a) Temperature Measurement
Minimum of two temperature recordings at different locations are to be mea-
sured within the sterilizer throughout the sterilization cycle, to ensure that the prod-
uct is not released as a result of malfunction in temperature sensor. If either of these
two readings does not meet the specifications of sterilization process, the load is
rejected.
(b) Humidity Measurement
Real-time indication of relative humidity and water vapor concentration of the
chamber is monitored throughout the conditioning phase using electronic sensors,
gas chromatography, infrared, or other spectroscopic methods. They may be used
for product release also.
(c) EO Gas Concentration Measurement

Throughout the exposure time, chamber atmosphere is measured for estimating
EO concentration at frequent intervals using analytical methods. Particular attention
should be given for the direct measurement of EO concentration during the first and
last phase of EO exposure. The reproducibility and accuracy of the results from
direct analysis should be determined during validation of the sterilization process.
Parametric release of sterilized medical devices is not a preferred indicator of steril-
ity in health-care facilities. For this purpose, the most difficult and challenging rep-
resentative of routine load should be used to show the ability of the sterilization
process to achieve the intended SAL. The representative product load used in the
efficacy testing should typically present challenging load size, configuration, char-
acteristics of packaging material, and lethality conditions such as penetration of
heat, humidity, and EO gas diffusion. Medical devices subjected to re-sterilization
shall be aerated between exposures to ensure the EO residues in the product do not
affect the safety of the workers and the next microbiological run. Precautions should
be taken to maintain the normal ambient conditions representative of a routine ster-
ilization process.
In addition to the routine control and monitoring, rigorous microbiological and
physical testing should be performed to demonstrate the efficacy and reproducibil-
ity of the sterilization process.
(a) Microbiological Testing
Microbiological testing shall be performed using defined process parameters
such as temperature, humidity, and/or EO concentrations run at lower set points
than normal sterilization specifications to deliver less lethality than the routine ster-
ilization process. Exposure time is the key parameter varied during microbiological
testing to confirm the effectiveness of the specified sterilization process. The lethal-
ity of this designed test cycle shall be determined by either BI/bioburden approach
or overkill approach for the procurement of SAL.
Data from lethality studies are used to establish the minimum EO gas exposure
time required for efficient sterilization. Lethality is primarily influenced by expo-
sure time, EO concentration, humidity, and temperature. Regardless of the micro-
biological challenge method used, it is assumed that homogeneous population of
microorganism and constant process parameters are maintained from run to run.
(b) Physical Testing
Physical testing shall be performed by running a minimum of three planned ster-
ilization processes with all specified criteria of a routine sterilization process. The
physical testing shall confirm the attainment of minimum temperature and humidity
of product at different phases of the sterilization process, pressure rise and the quan-
tity of EO used, or the concentration of EO in the sterilizer chamber. If these process
parameters are not maintained within the defined limits throughout the sterilization
process, a detailed investigation on performance, determined process parameter set
points, and sensor functioning should be conducted. Upon modifications additional
runs might be necessary. Failure among any of these planned runs to demonstrate
the product sterility or functionality during and/or after sterilization process requires
further corrective measures and if needed rejection of the sterilized product.
The accuracy and reliability of the equipment to control and monitor sterilization
process for achieving the required SAL should be monitored periodically. The
equipment should be maintained and/or calibrated on a routine basis in accordance
with manufacturer’s recommendations, as well as national, regional, or local
requirements. Failure to calibrate or maintain the sterilization equipment shall gen-
erate inaccurate readings of the process parameters during sterilization cycle.
5 Sterility: Post-sterilization Processes
Following a sterilization process, number of functionality tests ranging from a sim-

ple visual inspection to a battery of specialized microbiological or analytical tests
may be used to demonstrate that the sterilization process adopted does not affect the
functionality of the sterilized medical device and its packaging system. For further
details on microbiological tests of sterility, refer 11737-2. Evidences on the assess-
ment of product bioburden or its relative resistance to internal PCD should be vali-
dated. The biological safety of the sterilized medical device and/or its packaging
system by controlling the EO residual levels should comply with ISO 10993-7.
The criteria for confirming the sterility of the medical device and/or its packag-
ing system following sterilization require that all process parameter specifications
(parametric release method) are met during sterilization process; and there is no
growth of test organism from any BI. If any one or more of the conformance criteria
mentioned above are not fulfilled, then the product shall be considered as noncon-
forming and will be handled in compliance with ISO 13485. The cause of failure of
the sterilization process should be investigated, and the decision on product release
should be performed by qualified individuals.
In the event of failure to meet the physical specifications due to a failed control-
ling or monitoring sensor, the run should be rejected, unless there is an assignable
cause and the data from the remaining sensors are within specification. In the event
of observations of growth from BI, it is not recommended to release the product
based on the acceptable/positive results of the product test for sterility. If medical
device needs to be re-sterilized, special care should be taken to minimize the effects
of multiple sterilization processes on the suitability of product and its packaging
system, product functionality, EO residual levels, and/or reaction products.
6 Packaging of Sterilized Product
During sterilization, the minimum package used to prevent the ingress of microor-
ganisms withstands the sterilization conditions and remains intact to ensure the
aseptic presentation of the sterilized medical device until use, defined as sterile bar-
rier system (SBS). When selecting the materials for packaging system for a medical
device that is to be sterilized, the ability of the product to tolerate chemical and
physical changes caused by EO and/or any diluents over the anticipated range of
sterilization conditions shall be confirmed. The permeability of the material to
ensure EO penetration is of utmost importance. The packaging system should also
be able to allow gases to vent into and out of package without damage to or rupture
of seal integrity, as air removal is part of EO sterilization. The ability of SBS to
protect the sterile condition of medical devices during customary handling, EO ster-
ilization process, and distribution should be validated. Effects of exposure to mul-
tiple sterilization processes on packing material properties such as permeability,
physical strength and dimensions may also be evaluated. Further considerations for
packaging are addressed in detail in ISO 11607-1 and ISO 11607-2.
7 Limitations
EO is a highly penetrative toxic gas, and therefore it is important to ensure patient

safety by minimizing residual EO and its by-products such as ethylene chlorohydrin
(ECH; when EO reacts with free chloride ions) and ethylene glycol (EG; when EO
reacts with water) following sterilization. Exposure limits of EO and ECH have
been specified in ISO 10993-7; however, exposure limit for EG has not been set, as
the risk assessment indicates biologically significant residues of EG to be unlikely
when the EO residues are controlled.
Processing of materials contaminated with causative agents such as spongiform
encephalopathies, such as scrapie, bovine spongiform encephalopathy, and
Creutzfeldt-Jakob disease, has not been discussed here. Specific requirements and
validation of the process for inactivating these causative agents have been explored
in some countries. Refer ISO 22442-1, ISO 22442-2, and ISO 22442-3 for further
details. Occupational safety requirements for handling EO, types of EO process
(refer ISO 14937), quantification of residual EO and/or its reaction products (refer
ISO 10993-7), and national or regional regulations on the limits of residual EO
levels in or on the sterilized medical device have not been described in detail, as it
is beyond the scope of the present chapter.
Bibliography
1. ANSI/AAMI ST67:2009, Sterilization medical devices—Requirements for products labeled

‘STERILE.
2. EN 556-1, Sterilization of medical devices—Requirements for medical devices to be designated
3. ISO 10993 (all parts), Biological evaluation of medical devices
4. ISO 10993-7:2008, Biological evaluation of medical devices—Part 7: Ethylene oxide steril-
ization residuals
5. ISO 11135:2014, Sterilization of health care products—Ethylene oxide—Requirements for the
development, validation and routine control of a sterilization process for medical devices
6. ISO 11138-2:2017, Sterilization of health care products—Biological indicators—Part 2:

Biological indicators for ethylene oxide sterilization processes
7. ISO 11140-1:2014, Sterilization of health care products—Chemical indicators—Part 1:
General requirements
8. ISO 11607-1, Packaging for terminally sterilized medical devices—Part 1: Requirements for
materials, sterile barrier systems and packaging systems
9. ISO 11607-2, Packaging for terminally sterilized medical devices—Part 2: Validation require-
ments for forming, sealing and assembly processes
10. ISO 11737-1:2018, Sterilization of health care products - Microbiological methods - Part 1:
Determination of a population of microorganisms on products
11. ISO 11737-2:2009, Sterilization of medical devices - Microbiological methods - Part 2: Tests
of sterility performed in the definition, validation and maintenance of a sterilization process
12. ISO 13485:2016, Medical devices—Quality management systems—Requirements for regula-
tory purposes
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the selection, use and interpretation of results
An Overview on Sterilization of Health
Care Products using Moist Heat:
ISO 17665
Renjith P. Nair and Sunitha Chandran
1 Introduction
Medical devices that come in direct or indirect contact with humans, need to be
sterile for clinical use. Medical devices may get exposed to microorganisms during
its synthesis or its handling by any personnel during packaging or storage. Even if
the medical devices are manufactured according to the standard manufacturing con-
ditions, there will be a chance for the presence of one or more type of microorgan-
ism, at least in very few numbers. Hence, sterilization of medical devices becomes
very important and mandatory. Sterility of any medical device cannot be guaranteed
fully. Probability of survival of microorganisms in a device is determined by its
type, number, and resistance towards any particular sterilization technique. Detailed
description from all or any of the manufacturer or supplier regarding device material
properties, packaging, and sterilizer equipment should be assessed prior to the
selection of sterilization method. Also, sterilization of medical device using one
particular method may not guarantee complete eradication of all the microbial pop-
ulation from the device, and hence sterility assurance level (SAL) shall be devel-
oped for each product type and load configuration. The specifications defining the
probable level of microorganisms and requirements for defining sterility of medical
devices may vary between countries and need to be validated and implemented
accordingly.
R. P. Nair
Division of Thrombosis Research, Department of Applied Biology, Biomedical Technology
Wing, Sree Chitra Tirunal Institute for Medical Science and Technology,
Thiruvananthapuram, Kerala, India
e-mail: [email protected]
S. Chandran (*)
SCTIMST TIMed, Biomedical Technology Wing, Sree Chitra Tirunal Institute for Medical
156 R. P. Nair and S. Chandran
Low cost, being environment-friendly, and simplicity make steam sterilization

most adapted sterilization method. For steam sterilization, medical devices are
exposed to moist heat at specific temperature and pressure inside a sterilization
chamber. Penetration of moisture makes microorganisms more vulnerable to die by
denaturing its protein content, thereby lowering the time and temperature required
normally to kill them. Ensuring attainment of specific temperature for definite time
period is crucial for effective steam sterilization, and reproducibility should be vali-
dated for each process. ISO 17665 defines the specifications and requirements for
the development of a steam sterilization process. The standard also describes the
process validation, followed by implementation, quality control for installation,
operational and performance assessment. ISO 17665 consists of three parts. This
chapter focuses more on ISO 17665-1, discussing the general requirements for the
development, validation, and control of a steam sterilization process for medical
devices. Part 2 of the standard details the technical specifications for the application
of ISO 17665-1, and part 3 provides guidance on the designation of a device to a
product family and processing type.
2 Pre-sterilization
For each medical device or product, minimum level of sterility assurance required
should be known prior to sterilization. For establishment or attainment of SAL,
knowledge of bioburden is also required. Limiting values for temperature, pressure,
dwell time, etc. for each material, load size, and its combination shall be tested
before the steam treatment. If the product requires any pre-treatment, it may be
specified along with product details while supplying the medical device. For packed
devices, effective penetration or contact with the steam throughout the device sur-
face should be ensured. As per ISO 17655, the personnel assigned to carry out
responsibilities or processes should be having proper training and qualification.
Responsibilities and authority of the personal should be well defined and docu-
mented under the quality management systems.
3 Steam Sterilization Process Specifications
To ensure the efficacy of sterilization, descriptions of process, equipment used, and

product to be sterilized are required. Availability of specifications as detailed in ISO
17655 aids in choosing the optimum sterilization process for each device type based
on the raw material, type, maximum withstanding ability, etc. Repeatability of the
sterilization protocol is ensured when any international or national standards are
followed.
An Overview on Sterilization of Health Care Products using Moist Heat: ISO 17665 157
4 Sterilizing Agent
Steam when comes in contact with the microbes, translates thermal energy to
the microorganisms and kill them. Moist heat may be introduced as saturated steam
or by applying heat into the chamber such that the water content already present in
the device generates steam. Saturated steam is preferred over superheated steam due
to its microbial effectiveness. Sterilization load, initial temperature, and product
type determine the energy requirement for each sterilization type. The heat transfer
medium used should be free from pyrogen and exhibit uniform flow within steriliza-
tion chamber. The amount of water suspended in saturated steam entering the cham-
ber should be minimum, such that the water content should not affect the product
integrity and packaging.
Different steam sterilization processes include saturated steam venting, saturated
steam with active air removal, steam mixtures, water spray, and water immersion.
Saturated steam vented process is used for surface contact sterilization. The process
includes a heating phase, wherein sterilizer chamber is filled with saturated steam
until the specific temperature or pressure is attained followed by plateau phase dur-
ing which physical parameters are maintained for particular time and finally during
cooling phase, where air or solution is vented into the chamber until the chamber
pressure normalizes to atmospheric pressure or attains a safe temperature. When
saturated steam processes are used, steam penetration test needs to be done, which
confirms that level of non-condensable gas in the sterilizer chamber does not pre-
vent saturated steam from reaching the device surface. Devices with pores, lumens,
or cavities, or certain packed devices have to forcefully remove air prior to and after
steam exposure. In such processes details of the product and container, support
system within the chamber, temperature profiles to attain lethality, etc. need to be
mentioned.
5 Equipment Specifications
Specifications of equipment used for sterilization need to include the type of mate-
rial used; design, location, and characteristics of sensors used within or outside.
Material type used for making the equipment should resist any chance of corrosion
due to moist heat. ISO standard recommends that material coating with amines like
hydrazine should be avoided. Guidance on installation of the equipment shall
include isolation and details of physical parameters like pressure, temperature, flow,
filtration, voltage, and permissible non-condensable gas level. It has to be ensured
that the equipment will deliver specific exposure conditions throughout the steriliza-
tion cycle, without degrading the product. Adequate reference points may be chosen
to ensure effectiveness by using sensors and regular monitoring. Reproducibility of
the process specification should be verified at specific intervals. EN 285 specifies
guidelines for implementation, validation, and preventive measures to be followed
while using large sterilizers that have a capacity of more than 60 litre or include one
or more sterilizer chamber.
6 Sterilization Process
Microbicidal effectiveness of steam sterilization depends on the temperature and

duration of the sterilization process. Process specifications need to include step by
step operating conditions and parameters to be maintained or attained during the
sterilization cycle so as to achieve SAL. Sterilization load mass and size should be
defined along with the process specifications. The maximum and minimum limit of
these operating parameters also need to be defined for establishing lethality without
affecting product performance. As per ISO 17665-2, the most accepted sterilization
process parameters are 121 °C for 15 min, 126 °C for 10 min, and 134 °C for 3 min.
Usage of temperature higher than the acceptable value creates superheated steam
within the chamber which may affect the medical device properties and function. In
such cases microbicidal effectiveness needs to be validated and documented prior to
implementation of each process. New process specifications need to be tested in a
prototype system prior to implementation in the final equipment.
The process should also include strategies by which any error or inadequacy of
the equipment to attain any of the process parameters is identified and steps to be
followed if any error is found. This will ensure maximum reproducibility of the
process type for a particular product family and loading configuration. Process
detail also need to include the means to ensure personal and environmental safety.
If an existing process specification for a medical device needs to be applied for a
new product family, the challenge identified for the latter should be less than or
equal to the loading conditions of existing medical device. Combination of physical
parameters like pressure, temperature changes, and duration of exposure also should
be validated. ISO 17665-3 may be referred for more details on classification of
product family for a specific steam sterilization process.
7 Product Specifications
Product specifications describe material property, tolerance level to specific param-

eters, packaging (if any), etc. Medical device design and properties influence pen-
etration of steam and sterilization efficacy. Steam sterilization may also affect the
device properties or functioning. Hence material data or product information pro-
vided by manufactures should be carefully studied before validating the sterilization
process. ISO 17665-2 describes more detailed specifications like physical, mechan-
ical, and functional properties.
8 Validation
Validation ensures that the specifications required for each stage of sterilization are
met, so as to meet SAL. Any change in the specifications in equipment, process, or
product needs to be validated and noted. It includes installation qualification (IQ),
operational qualification (OQ), and performance qualification (PQ). Installation
qualification should validate that equipment installed attains/exhibits maximum and
minimum pressure, temperature and allows adequate non-condensable gas flow and
water in saturated steam. OQ helps in validating the installed equipment to function
and deliver all the specifications required for different steam sterilization processes
without any leakage of steam or air. PQ demonstrates that the product has under-
gone all the sterilization process and was exposed to the process variables to obtain
the required sterility assurance level. Measuring holding time, temperature profil-
ing, usage of chemical or biological indicators, or performing test for heat penetra-
tion and/or sterility helps in validating PQ. To ensure compliance and repeatability,
PQ of three consecutive sterilization processes may be considered.
If temperature profiles for the product sterilizer chamber follow the same as that
of a reference material, sterilized product may be released. But for packed devices,
the release is made on the basis of integrity of package and the process indicators on
the package. There should also be clear indication to identify processed and non-
processed items, so as to confirm sterilization process and release the product. Any
change in process parameter, device package or packaging procedure, or load con-
figuration or any replacement of equipment part that may change the process param-
eter may affect the process effectiveness, and such changes need to be documented,
and process needs to be revalidated.
9 Sterilization of Packed Devices
Packed medical devices need to be sterilized with care, as the packaging material
should not prevent the penetration of steam into the device or interfere with the
sterilization process. Pre-existence of moisture within the product or packaging,
may interfere with the sterilization process and affect the vacuum application phase.
In such cases, steam penetration test needs to be carried out specifically in less
accessible areas like lumen, tubing, etc. Along with the penetration efficacy, the
packing material or design should be able to cope up with all the changing param-
eters of temperature, pressure, etc. that the device would be subjected to during the
process of sterilization.
10 Indicators for Assuring the Efficacy of Sterilization
Indicators are needed to make sure that proper and complete sterilization of the
medical device has been achieved. It can be biological or chemical indicators.
Biological indicators used during moist heat sterilization process should comply
with ISO 11138-3 (the standard that specifies the requirements for inoculated carri-
ers, test organisms, etc., determination of its resistance, carrier packaging, and test-
ing methods employed). If chemical indicators are used, it should comply with ISO
11140. The chemical indicators used shall not react with or contaminate the device
at any phase of sterilization and affect device properties or function. Use of indica-
tors also requires that their location and acceptance range need to be clearly defined.
11 Assessment of Effectiveness
In certain cases, to ensure the efficacy of sterilization, devices should be pre-

conditioned; if so, it should be clearly mentioned in the sterilization protocol. Post-
conditioning, medical devices shall be cleaned and disinfected properly prior to
sterilization. Complete removal of moisture from the device surface may be con-
firmed prior to packing of the sterilized material. It should also be ensured that
steam sterilization didn’t affect the device composition or conformation, thereby
affecting its indented use or application. Contaminants get retained in some rare
cases even after sterilization, and the limiting value for maximum level of contami-
nant should be identified for each device.
For assessing effective sterilization, biological or chemical indicators are used as
discussed earlier. Chemical indicators should be tested for the effect of minimum
and maximum temperatures during the sterilization process. It should be specially
mentioned, if post-sterilization medical devices need to be treated separately to
maintain the sterility. ISO standard also recommends having a system to distinguish
processed and the non-processed medical devices. Processed devices should meet
all the criteria to confirm that processing has been done as per the established pro-
cess and equipment requirements for steam sterilization. Quality assessments
should be routinely done for assessing the efficacy of the process, equipment, and
processed device.
12 Sterilization of Used Medical Devices
Used medical devices may carry a wide variety of microbes and other contaminants.
Hence it should be made sure that the used medical devices along with its packaging
are thoroughly cleaned and disinfected prior to the sterilization process.
Re-sterilization of medical devices may need additional validation requirements as
earlier steam sterilization might have increased material thickness and crack could
have formed in some devices. When such devices are to be sterilized, longevity of
the material should be known prior to re-sterilization. Guidelines for the specifica-
tions for treating re-sterilized medical devices are detailed in ISO 17664 and
EN 868-8.
13 Limitations of Steam Sterilization
Steam sterilization cannot be applied to all materials like polymers and metallic
devices due to compatibility issues. It can cause corrosion of some metallic devices,
in particular high carbon steel used for surgical and dental instruments, and cause
unprotected cutting edges to dull. Moisture also can adversely affect electronics in
the device.
Guidelines and protocols have to be developed and validated for the eradication
of pathogens causing diseases like encephalopathy and Creutzfeldt-Jakob disease,
as ISO 17665 does not cover those. Usage of combination agents with biological
agents like steam and formaldehyde is also not specified in the standard. ISO 17665
also does not specify requirements to designate medical devices as sterile and ster-
ilization facility as occupationally safe.
14 Other Standards and Guidelines
Other standards or guidelines related to steam sterilization are EN 285 (specifica-

tion regarding large steam sterilizers – volume of at least 60 L), ISO 25424 (speci-
fications while using low-temperature steam and formaldehyde), EN 868-8
(specifications for reusable containers for steam sterilizers), EN 13060 (specifica-
tion regarding small steam sterilizers), ISO 11138-3 (specification for biological
indicators), ISO 11140-4 (specifications for chemical indicator used in Bowie-
Dick-type steam penetration test), ISO 11140-3 (specifications for chemical indica-
tor used as an alternative to Bowie-Dick-type steam penetration test), ISO 11140-5
(specifications for chemical indicator used in Bowie-Dick-type air removal test),
AS/NZS 4187 (comprehensive guidance for sterilization of reusable devices in
Australia and New Zealand), CDC/HICPAC (guidance on sterilization of patient
care devices in the United States of America), and HTM01-01 Part C (guidance for
designing steam sterilizers and its testing in the United Kingdom).
Bibliography
1. ISO 11138-3, Sterilization of health care products — Biological indicators — Part 3: Biological
indicators for moist heat sterilization processes
2. ISO 11140-1, Sterilization of health care products — Chemical indicators — Part 1: General
requirements
3. ISO 17664, Sterilization of medical devices — Information to be provided by the manufacturer
for the processing of resterilizable medical devices
4. EN 285, Sterilization — Steam sterilizers — Large sterilizers
5. EN 868-8:1999 -Packaging materials and systems for medical devices which are to be steril-
ized —Part 8: Re-usable sterilization containers for steam sterilizers conforming to EN 285 —
Requirements and test methods
6. EN 13060, Small steam sterilizers
7. PFLUG, I.J. and KRISTEN, D.E. Carrying out Biological Qualification, the Control Operation
of Moist-Heat (Steam Sterilization) Processes for Producing Sterile Pharmaceuticals and
Medical Devices PDA, Journal of Pharmaceutical Science and Technology, 54 (2) 2000
8. ISO/TS 17665-3 sterilization of health care products — Moist heat —Part 3: Guidance on
the designation of a medical device to a product family and processing category for steam
sterilization
9. A Practical Guide to Decontamination in Healthcare, Gerald E. McDonnell and Denise Sheard,
John Wiley & Sons, 2012, 460 pages
10. Review of surface steam sterilization for validation purposes, Joost van Doornmalen, Ira and
Klaas Kopinga, American Journal of Infection Control, March 2008, Volume 36, Issue 2,
Pages 86–92
11. ISO 17665-1:2006(en), Sterilization of health care products — Moist heat — Part 1:
Requirements for the development, validation and routine control of a sterilization process for
medical devices
12. ISO/TS 17665-2:2009, Sterilization of health care products — Moist heat — Part 2: Guidance
on the application of ISO 17665-1
13. ISO 25424:2018, Sterilization of health care products — Low temperature steam and form-
aldehyde — Requirements for development, validation and routine control of a sterilization
process for medical devices
14. ISO 11140-3:2007, Sterilization of health care products — Chemical indicators — Part 3:
Class 2 indicator systems for use in the Bowie and Dick-type steam penetration test
Class 2 indicators as an alternative to the Bowie and Dick-type test for detection of steam
penetration
Class 2 indicators for Bowie and Dick-type air removal tests
17. AS / NZS 4187:2014, Reprocessing of Reusable Medical Devices in Health Service
Organisations
18. Health Technical Memorandum 01-01: Management and decontamination of surgical instru-
ments (medical devices) used in acute care Part C: Steam sterilization
ISO 10993: Biological Evaluation
of Medical Devices
Pugazhenthan Thangaraju and Shoban Babu Varthya
1 election and Qualification of Reference Materials

S
for Biological Tests (ISO 10993-8)
Before selection of certified/reference material, a reference material must be avail-

able not less than 5 years from the supplier, and it should publish its source and
method of processing. Certification of reference material is done by interlaboratory
studies. Reference material must be used for screening of biocompatibility of medi-
cal devices and prevention of misuse of certified reference material.
2 Chemical Characterization of Material (ISO 10993-18)
Chemical characterization of material is essential for assessing biological safety of

the device, quantification of material leached due to clinical use, supporting equiva-
lence with existing device/prototype device and suitability of new device for clinical
application. Chemical characterization along with risk assessment increases the bio-
compatibility of device for clinical use. It also plays an important role in the device’s
biological evaluation and toxicological risk assessment.
General Principles of Characterization For chemical characterization of device,
its composition and quantification of extraction material are essential. Chemical
P. Thangaraju (*)
Department of Pharmacology, All India Institute of Medical Sciences (AIIMS),
Raipur, Chhattisgarh, India
S. B. Varthya
Department of Pharmacology, All India Institute of Medical Sciences (AIIMS),
Jodhpur, Rajasthan, India
164 P. Thangaraju and S. B. Varthya
composition enables to compare with pre-existing/standard device and also toxico-

logical risk assessment. The extent of chemical characterization is determined by
nature and duration of the clinical exposure, physical form of the device used clini-
cally and its previous use. Chemical characterization in biological analysis is essen-
tial because potential biological risks are arising from the use of medical devices by
risk assessment. A medical device must undergo extraction test to see the potential
bioavailability of test material or its additive in the process of manufacturing. It
depends on the duration of clinical use and physical characteristics (liquid, gels,
polymers, metals, ceramics, etc.) of material used.
Characterization Procedure To assess the risk of the material, characterization of

material must have information on composition of finished device including its
additives; material must be equivalent to clinically established material. To test the
equivalence, a test material is compared with already used material with respect to
its composition and extractable profile along with duration of contact and invasive-
ness and leachable material, and it must have better toxicological profile or similar
toxicological profile. While establishing composition and configuration of device,
the hypothetical worst-case scenario will be taken from source of material or appro-
priate compositional testing. Quantitate information of material to describe the total
amount of chemical present in the material. Quantitative risk assessment is done
with existing toxicological information.
Chemical characterization parameters and methods are essential for the stepwise
generation of qualitative and chemical quantitative characterization data used in the
risk assessment.
1. For material composition based on material type, analytical test varies. In case of
synthetic polymers, chromatographic (GC, LC), spectrophotometric and fluores-
cence techniques are used. In case of metals and alloys, X-ray fluorescence, elec-
tron microscopy, etc. are used. In case of ceramics, X-ray fluorescence, ion
chromatography, etc. are indicated.
2. For extractable and leachable compounds: In case of organic compounds based
on volatility, headspace sampling for gas chromatography (HS-GC) is typically
used to analyse VOCs, gas chromatography (GC) is typically used to analyse
SVOCs, and LC is used to analyse NVOCs.
3. For structural composition or configuration, spectrophotometric studies are
indicated.
Reporting of analytical tests used chemical characterization done in a format,
which includes description on test material and sample preparation, analytical
method and extraction conditions, stability testing, analytical evaluation threshold
and qualitative and quantitative data, along with clinical exposure to chemical.
Below we will be discussing specific parameters and methods used for character-
ization of materials:
ISO 10993: Biological Evaluation of Medical Devices 165
3 hysicochemical, Morphological and Topographical

P
(PMT) Characterization of Materials (ISO 10993-19)
PMT characterization along with above framework is essential for judging a pro-
posed material to clinical established material or a prototype device to final device.
Few examples to understand the relation between PMT evaluation and clinical
effectiveness are as follows:
1. Porous materials as surfaces on orthopaedic implants can encourage tissue
ingrowth at the surface of the implant for better integration.
2. The use of material scaffolds and meshes aids in healing process.
3. The PMT characterization enables to understand the bacterial adherence to cath-
eters and their role in infections and blockages.
4. Alterations to the microtopography of surfaces, e.g. producing microgrooves or
other defined patterns, have been shown to influence the adhesion and direction
of movement of certain types of cells on that surface.
5. For certain medical devices, e.g. orthopaedic implants and vascular prostheses,
mechanical properties may influence biological responses such as tissue
remodelling.
4 ramework for Identification and Quantification

F
of Potential Degradation Products (ISO 10993-9)
Under this we will be looking at general principles for systemic evaluation of the
potential and observed biodegradation of medical devices and for the design and
performance of biodegradation studies. It depends on nature of material and its
anatomical location during use. Study design depends on chemical and physio-
chemical properties, surface morphology and biochemical properties. In case of
biodegradable material or material implanted for more than 30 days or toxic sub-
stance released from the material, biodegradable studies shall be conducted. But in
case if biodegradable products are similar to parent material or if safety data is
available, then there is no need to conduct further studies. When studies are planned
to study, then in vitro and in vivo studies are to be conducted.
Characterization of potential degradation products: Degradation products can be
particulate or soluble compound or ions; based on type of particulate matter, it must
be characterized (if particulate material, then size, shape, surface area and other
relevant characteristics recorded). Protocol of such study must aim at evaluating the
changes in bulk material and mechanism of change in its characteristics. Bulk mate-
rial undergoes changes during storage, or processing, or sterilization, during implan-
tation or after implantation, or leeching from the site of implantation. Substance
from implant can be released by chemical reaction, leeching, migration, depolymer-
ization or peeling of material.
A study must report nature of material and its intended use, assessment of degra-
dation and its rationale for same, description of degradation products related to test
material and methodologies including analytical test and statement of compliance to
good laboratory practice.
5 I dentification and Quantification of Degradation Products

from Polymeric Medical Devices (ISO 10993-13)
Under this we will be discussing tests in a stimulatory environment for identifying

and quantification of degraded products from polymeric medical devices.
Test Designs Analytical methods designed to test the polymeric materials are solu-
tion viscometry (molecular mass average, branching); swellability (cross-link den-
sity); rheology (melting range, melt viscosity, thermal stability, molecular mass
distribution); chromatographic methods (e.g. gas and/or high-performance liquid
chromatography for residual monomers, additives and leachables; size exclusion/
gel permeation chromatography for molecular mass averages and changes in molec-
ular mass distribution; mass spectrometry for identification); spectroscopic methods
(e.g. ultraviolet spectroscopy, infrared spectroscopy, nuclear magnetic resonance,
mass spectroscopy for identity, composition, distributions; atomic absorption spec-
troscopy for catalyst content, heavy metals); and thermal analysis (e.g. differential
scanning calorimetry for glass transition, melting range or softening point, blends).
Test solution must mimic the biological state in which it is intended for use. For
example, for hydrolytic degradation, grade 2 laboratory water is used along with
buffer. Similarly for oxidative degradation, water and hydrogen peroxide with
Fenton’s reagent will be used.
5.1 The Accelerated Degradation Test
This is a screening method to identify and/or quantify degradation products. This

test is conducted between 37 °C and less than melting point of polymer. Duration of
test depends on intended clinical use of the material. (For devices whose intended
use is longer than 30 d, test periods of 2 d and 60 d shall be used. For devices whose
intended use is less than 30 d, test periods of 2 d and 7 d shall be used.)
5.2 Real-Time Degradation Test in a Simulated Environment
Carry out the test at 37 ± 1 °C.

Test Period For devices whose intended use is longer than 30 d, test periods of
1 month, 3 months, 6 months and 12 months shall be used. For devices whose
intended use is less than 30 d, four alternative test periods shall be used, includ-
ing 30 d.
5.3 Test Report
Description of the test material, batch or lot number, dimensions and number of
samples tested; test solution and conditions; detailed description and justification of
the test methods used, including (where appropriate) specificity, sensitivity, detec-
tion and quantification limits; method used to determine mass loss, including preci-
sion; mass/volume ratio of sample and shape of sample; sample pretreatment and
drying method; selected pH; test temperature; test periods; test results; (1) mass
balance; (2) molecular mass/distribution (cross-link density); (3) results of tests run
on the solution, debris and/or bulk polymer; (4) identified degradation products; (5)
rationale for final decision.

from Ceramics (ISO 10993-14)
There are two tests available.

An Extreme Solution Test This is conducted at low pH, based on a low pH citric
acid buffer solution. This test can be used for screening of all ceramics. Best results
are obtained if specimen run on granulated specimen. Characterization of test sam-
ple shall be done by gas absorption, density, solubility, microstructural and X-ray
diffraction method.
Simulation Solution Test This test is performed at physiological pH (7.4 ± 0.1).

This test is applicable to all ceramics to see that degradation products are generated
under simulated test conditions. Test specimens shall be prepared as coatings on
blank discs for getting finished products. Surface area, microstructure and X-ray
characterization shall be recorded after the procedure.

from Metals and Alloys (ISO 10993-15)
A potentiodynamic test and a potentiostatic test are used to identify and quantify
degradation from metals and alloys.
8 Compatibility Testing
8.1 Biocompatibility (ISO 10993)
8.2 elections of Tests for Interactions with Blood (ISO

S
10993-4)
In this section, we will discuss on devices coming into contact with blood. They
may be externally communicating devices like cannulae, IV catheters, cardiopul-
monary bypass circuit, capillary filters, guiding wires, etc. and implant devices like
AV shunts, IVC filters, ventricular assist devices, vascular stents, etc.
Characterization of Blood Interaction For characterization of devices, they need
to undergo certain test for interaction like haemolysis due to device or mechanical
force and thrombosis.
In Vitro Tests Haematocrit, anticoagulant (type and amount), test sample prepara-
tion, test sample age, blood/blood component age, test sample storage, aeration and
pH, temperature, proper randomization, test sample surface area to blood volume
ratio and, for dynamic studies, fluid flow conditions, especially flow rate, wall shear
rate and pressure(s).
Ex Vivo Tests Platelet adhesion, emboli generation, fibrinogen deposition, throm-

bus mass, white cell adhesion, platelet consumption and platelet activation.
In vivo testing involves implanting the material or device in animals. This pri-
marily tests the patency of a conduit or device. The percent of occlusion and throm-
bus mass are determined after the device is removed. The tendency of thrombi
formed on a device to embolize to distal organs should be assessed by careful gross
as well as microscopic examination of organs downstream from the device. In addi-
tion, histopathological evaluation of the surrounding tissue and organs is useful (e.g.
in case of ventricular assist devices or artificial hearts, the kidney primarily gets
affected by emboli).
Arteriograms or imaging from intravascular ultrasound (IVUS) catheters are
used to determine patency or thrombus deposition on devices. Radioimaging can be
used to monitor platelet deposition at various time periods in vivo; platelet survival
and consumption can be used as indicators of blood/device interactions and passiv-
ation due to neointima formation or protein adsorption.
In vivo test protocols should contain precise and stand-alone sections stating how
each test category identified for testing, i.e. haemolysis, thrombosis, coagulation,
platelets, haematology and complement system, will be evaluated.
Preclinical Evaluation of Cardiovascular Devices and Prostheses
Animal studies are conducted to study interactions or potential interactions, which

are to be prevented to make device suitable. These are adsorption of plasma pro-
teins, lipids, calcium or other substances from the blood onto the surface or into the
device; adhesion of platelets, leukocytes or erythrocytes; formation of pseudointima
or neointima on the blood contacting surface and tissue capsule on the surface of the
device; alterations in mechanical and other properties of the device; activation of
platelets, leukocytes or other cells, or activation of the coagulation, fibrinolytic or
complement pathways; formation of thrombus on the device surface; embolization
of thrombotic or other material from the device’s surface to another site within the
circulation; injury to circulating blood cells resulting in anaemia, haemolysis, leu-
copoenia, thrombocytopenia or altered function of blood cells; injury to cells and
tissues adjacent to the device; intimal hyperplasia or accumulation of other tissue on
or adjacent to the device, resulting in reduced flow or affecting other functions of
the device; and adhesion and growth of bacteria or other infectious agents on or near
the device.
Advantages and Limitations of Animal Models
They help for simulation of test device and continuous monitoring for device, but its
usage was restricted by size of the animal, duration of implantation and cost.
Advantages and Limitations of In Vitro Models
Avoidance of costly animal models; high replication testing of test objects alongside
controls and reference materials using the same batch of blood and, at the same
time, use of human or animal blood where flow, temperature and anticoagulation are
standardized; worst-case scenario testing, where activation products accumulate
without clearance by kidneys or liver or other organs and activation-inhibiting func-
tions of endothelial cells are absent; and isolation from confounding factors associ-
ated with device implantation/tissue injury associated with in vivo usage.
Recommended Laboratory Tests
Thrombosis This is analysed from the distal organ microscopy after autopsy. In
this we look for per cent of occlusion, surface area covered by thrombus and surface
area free from thrombus.
In Vitro Haemocompatibility Haemolysis can be screened by testing plasma hae-

moglobin levels; the higher the value, the higher will be the haemolysis. Coagulation:
Thrombin-antithrombin and fibrin assay using ELISA method indicates reflective of
the level of coagulation activity. Partial thromboplastin time (PTT) is to test the
activation of intrinsic coagulation pathway. The activated partial thromboplastin
time (APTT) must be avoided because the activator used in this test may interfere
with material activation.
Methods to Test the Activity of Platelets Medical devices can cause platelet
depletion due to adhesion, aggregation and/or sequestration. To assess the activity
of platelets, platelet granule-release proteins beta-thromboglobulin (ß-TG) and
platelet factor 4 (PF4), thromboxane B2 (TxB2) and platelet morphological changes
are to be tested.
Methods to Test Haematological Parameters Complete blood count, including

peripheral smear, leukocyte activation by estimation of leukocyte on the surface of
the device or their presence on the thrombi along with platelets.
Estimation Complement Cascade Parameters C3a and SC5b-9 using

ELISA. Complement system plays an important role in innate immunity of the body.
8.3 Tests for In Vitro Cytotoxicity (ISO 10993-5)
Three categories of test are used for in vitro cytotoxicity studies: extract test, direct
contact test and indirect contact test. These are primarily to study the biological
response of mammalian cells to medical devices and/or their extracts.
Endpoints under this test are (1) assessments of cell damage by morphological
means, (2) measurements of cell damage, (3) measurements of cell growth and (4)
measurements of specific aspects of cellular metabolism.
Tests Used Under In Vitro Cytotoxicity
1. The extract test: In this test we simulate or exaggerate the condition intended
for use to assess the potential toxic effects in sample by fusion, melting or any
alteration of the chemical structure, unless this is expected during clinical appli-
cation. In case where two or more substances are mixed in sample, then extrac-
tion test shall be applied before washing the sample to remove residues.
Extraction vehicles in this test can be culture medium with serum, physiological
saline solution or other vehicles.
2. Neutral red uptake (NRU) cytotoxicity test: In this test BALB/c 3T3 cell lines
are used and seeded in 96-well cell plate for 24 h. At different concentrations test
sample will be applied for 24 h. The IC50 (i.e. the concentration producing 50%
reduction of NRU) is calculated from the concentration-response and expressed
as a dilution percentage of the extract.
3. Colony formation cytotoxicity test: V79 cells are seeded into six-well plates
and maintained in culture for 24 h to start growing in a logarithmic phase. They
are then exposed to the test compound over a range of concentrations. They are
incubated for 6 days to make colonies large enough to count. Colonies are fixed
with methanol, stained with Giemsa solution and counted. If the extract exhibits
a cytotoxic effect on the cells, the IC50 (the concentration inhibiting plating
efficiency to 50%) is calculated and expressed as a percentage of the extract.
4. MTT cytotoxicity test (direct contact test): Test protocol is based on the mea-
surement of the viability of cells via metabolic activity. L929 cells are seeded
into 96-well plates and maintained in culture for 24 h (≈1 doubling period) to
form a semi-confluent monolayer (see Reference [5] for more information on
cell maintenance and culture procedures). They are then exposed to the test com-
pound over a range of concentrations. After 24 h exposure, the formazan forma-
tion is determined for each treatment concentration and compared to that
determined in control cultures. For each treatment the percentage inhibition of
growth is calculated.
5. XTT cytotoxicity test (indirect contact test): This is based on the measurement
of the viability of cells via mitochondrial dehydrogenases. L929 cells are seeded
into 96-well plates and maintained in culture for 24 h (≈1 doubling period) to
form a semi-confluent monolayer (see Reference [5] for more information on
cell maintenance and culture procedures). They are then exposed to the test com-
pound over a range of concentrations. After 24 h exposure, the formazan forma-
tion is determined for each treatment concentration and compared to that
determined in control cultures. For each treatment the percentage inhibition of
growth is calculated.
9 Toxicity Screening
9.1 Sample Preparation and Reference Materials
9.2 valuation and Testing Within a Risk Management

E
Process (ISO 10993-1:2009)
To prevent the potential risk arising from the medical devices (from now we called
it as devices) to humans, their biological evaluation is essential. Biological evalua-
tion is done by in vitro and ex vivo tests using animal to identify potential adverse
response.
The primary role of this document is to serve as a framework to plan a biological
evaluation. A secondary role is to utilize scientific advances in our understanding of
basic mechanisms, preferably physical, chemical, morphological and topographical

characterization testing and in vitro models than the in vivo models.
Biological evaluation is done through extensive literature search to know the
existing information on physical and chemical characteristics of device, nonclinical
and clinical safety and toxicological data of the device. Details of this will be dis-
cussed in their respective frameworks. If there is gap in the literature, risk analysis
is performed to complete the data sets needed for the biological evaluation of the
particular medical device.
Re-evaluation of test material is necessary, if there is a change in source of mate-
rial, or change in processing or its transport, or change in its intended use or adverse
events are observed in humans after their use.
Biological evaluation is done by weighing between risks and benefits by devices.
Any acceptable risk after getting expected benefit from the device is considered to
be acceptable. Initially risk assessment is done from the identified and estimated
risk of a device in contact with biological material. After risk analysis, risk estima-
tion is done from the use and hazards of device. Finally risk management is done
after taking risk control measures and improving overall acceptability of the device.
9.3 Animal Welfare Requirements (ISO 10993-2)
Primary aim of ISO is protection of humans from any adverse events or potential
adverse events due to medical devices. In this respect, animal studies are conducted
to study the biological effects of medical devices. These tests are conducted in
humanly approach. Animal welfare primarily focuses on minimization of animal
use, minimizing or eliminating the pain and distress and replacement of animal test,
if alternative tests are available. Animal welfare primarily deals with vertebrate non-
human species.
In this part we will be discussing what essential prerequisites for testing medical
devices in animals are.
Essential Requirement for Minimizing or Eliminating Pain and Distress in
Animals Under this all experiments are conducted in accordance with legal provi-
sions of their jurisdiction and ethical provisions. Number of animals in each group
must be based on literature search, data sharing and replacement of animals wher-
ever possible and appropriate test strategy and study design. All these experiments
are conducted in good laboratory care and presence of competent personnel and
expert veterinarian service to alleviate their suffering.
Justification of Animal Studies Animal studies are useful for characterization of

medical device, when there was no validated test available. But such method must
follow the refinement and reduction of animals in the study. These studies must be
relevant to their endpoints; data must be part of characterization of medical device.
Planning and Performance of Studies Species selection, number of animals per

group, test used in characterization of device and measures taken to minimize or
prevent pain and distress at the discretion of expert but must be in compliance with
local ethical committee prerequisites and their legal provisions.
Reuse Reuse of animals is warranted to reduce the cost of animal welfare and
minimize number of animals used, but in such condition reuse must be based on
scientific objective, because pain and distress in the course of experiment may inter-
fere with other test. Whenever animals are reused, it must be well documented.
Test Strategy Test strategy follows appropriate hierarchical approach to minimize

the number of tests and to reduce pain and distress to the animals. Animal test must
not be performed if adequate data relevant to such test is available.
Animal Care and Accommodation Animal care and accommodation must be

according to the national or international animal care, accommodation and hus-
bandry guidelines. Compliance to such guidelines must be justified and docu-
mented. Animals which are social species must be housed in groups except during
experiment if required. In case single housing is required, it must be documented for
that duration. In case animals require restraint, then such application must be mini-
mum duration and degree of restraint to meet scientific objective. In case of surgical
procedures, surgeries are conducted under adequate anaesthesia and prevent chances
of sepsis along with proper pre-, intra- and post-operative care of the animals.
Humane Endpoints A competent person must supervise animals at least once in a

day, and observation number increased, if number possible adverse welfare out-
comes present. If animals are in severe pain and/or distress and cannot be alleviated,
such animals must be euthanized immediately. Euthanasia of animal is done by
using methods which can cause rapid irreversible loss of consciousness of animal.
Study documentation: Under this all experiments must be documented related to
the test strategy, the rationale for use of specific species, strain and numbers along
with number of animals per group and procedure followed in the study, health status
of animals during study protocol, details of the care and husbandry systems, the
observation schedules and humane endpoints to be implemented, the contact details
for key personnel, the method of euthanasia and the justification for the choice of
method to be used and details of the analytical and statistical methods to be applied.
Validity of Test Results and Mutual Acceptance of Data Mutual acceptance of
test data can significantly reduce animal test requirements and facilitate timely and
ethical regulatory decisions. Whenever possible, test methods shall be based on
internationally recognized protocols and conducted in accordance with recognized
quality assurance systems, for example, in accordance with the principles of good
laboratory practice.
9.4 Tests for Local Effects After Implantation (ISO 10993-6)
In this part we will be discussing about test methods for assessment of local effects
by direct contact samples. This test applies for solid and non-absorbable; non-solid,
such as porous materials, liquids, gels, pastes and particulates; and degradable and/
or absorbable, which may be solid or non-solid.
9.5 Tests for Systemic Toxicity (ISO 10993-11)
In this part we will be discussing procedures followed in evaluating the potential

systemic toxicity associated with medical devices. Generally systemic toxicity stud-
ies are conducted based on mode and duration of use. Tests are conducted on final
or representative product, and it depends on the physical and chemical properties of
device like pH, solubility, osmolality, etc. Dose of the study is determined from
in vitro acute toxicity and in vitro cytotoxicity studies. Animals are selected based
on type of device and their intended route of use (e.g. for acute oral, intravenous,
dermal and inhalation studies of medical devices, the rodent is preferred with the
option of the rabbit in the case of dermal and implantation studies. Other non-rodent
species may also need to be considered for testing, recognizing that a number of
factors might dictate the number or choice of species for study). Preferably single
species is used in this study.
Size and number of animals per group: For systemic toxicity studies, it depends
on number of animals used per dose level and duration of therapy. In the below
table, we will be mentioning minimum number of animals per group required based
on treatment duration. Matching control group to match with test sample prepara-
tion and treatment procedure.
Recommended minimum group sizes:
Study type Rodent Non-rodent

Acute 5 3
Subacute 10 (5 per sex) 6 (3 per sex)
Subchronic 20 (10 per sex) 8 (4 per sex)
Chronic 30 (15 per sex)
As the duration of therapy is increasing, we use more number of animals taking

the possible mortality due to treatment in long-term therapy. Sex-based grouping is
required, if device is used in both sexes.
Single-dose group vs multi-dose group: Single-dose group is used in acute toxicity
studies to get mean lethal dose or hazard dose, but to draw dose response curve,
we need to have multi-dose group.
Route of exposure: The test route of exposure shall be the most clinically relevant to
the use of the device, where possible. If an alternative route of exposure is neces-
sary, it shall be justified.
Dosing: Under this test sample is administered either single dose per day or multiple
doses in a day depending on the volume of administration, and test sample is
administered mostly at physiological temperature of animal.
Clinical observation:
Respiratory system: Dyspnoea (abdominal breathing, gasping), apnoea, cyanosis,
tachypnoea and/or discharge through nostrils
Motor activities: Decrease/increase of somnolence, loss of righting, catalepsy,
ataxia, unusual locomotion, prostration, tremors and fasciculation
CNS: Convulsion, reflexes (corneal, righting, myotactic, light, startle reflex).
Ophthalmological: Lacrimation, pupil size (miosis and mydriasis), extraocular
muscles (exophthalmos, ptosis), lens (opacity), iritis, conjunctivitis, chromodac-
ryorrhea, relaxation of nictitating membrane
Cardiovascular signs: Bradycardia, tachycardia, arrhythmia, vasodilation and
vasoconstriction
Gastrointestinal: Soft stool, diarrhoea, emesis, diuresis, rhinorrhoea, etc.
Dermatological signs: Oedema, erythema, etc.
Other systems if required:
Clinical pathology: To analyse the toxic effects of devices, blood test along with
other analytical tests is performed. Sample collection is done as per protocol.
Haematology (clotting potential (PT, APTT), haemoglobin concentration, haemato-
crit, platelet count, red blood cell count, white blood cell count, WBC
differential)
Clinical chemistry (LFT, RFT, lipid profile, blood glucose, serum electrolytes,
immunoglobulin, etc.)
Urine analysis for appearance, bilirubin, glucose, ketones, occult blood, protein,
sediment, specific gravity or osmolality, volume, etc.
Anatomic Pathology Under this gross morphological changes in the intact body
after euthanasia or death, discharge from all opening, and cranial, thoracic and
abdominal cavities. Gross morphology and histopathology of selected organs done
after harvesting adequate tissue.
Acute Systemic Toxicity This information gives about clinical effects on acute
exposure to device. Dosage regimen is established based on this study and mode of
toxic effects seen. Under this study, data regarding adverse clinical signs, body
weight change, gross pathological findings and death (if any) shall be recorded.
Repeated exposure systemic toxicity (subacute, subchronic and chronic sys-
temic toxicity):
1. Health hazards likely to arise from a prolonged exposure
2. The mode of toxic action of a substance

3. Detailed information on toxic effects, target organs, reversibility or other effects
and may serve as the basis for safety estimation
9.6 Tests for Irritation and Skin Sensitization (ISO 10993-10)
Medical devices or their release chemicals may cause irritation of the skin and
mucous membrane or may cause sensitization leading to delayed type of hypersen-
sitivity reaction. To test such reaction, in vitro test, animal studies and human trials
are to be conducted. These tests are performed in case of devices intended as an
implant and externally communicating device.
Under this we follow stepwise approach:
Characterization of test material: In this part physicochemical characterization of
device shall be done. Details are already discussed.
Literature review: Through literature review essential for extracting information on
device or structurally similar components about physicochemical properties, irri-
tation and/or sensitization.
In vitro tests: In silico methods gaining popularity to identify potentially important
reactions and sensitization.
In vivo animal tests: In this test we will be demonstrating the potential irritation and
sensitization using positive controls. To test the sensitization, we use local lymph
node assay in mice, the occluded patch test in guinea pigs or the guinea pig maxi-
mization test (GPMT).
Non-invasive human tests/clinical trials: If test material is found negative in animal
studies, these are taken for further evaluation.
9.7 rinciples and Methods for Immunotoxicology Testing

P
of Medical Devices (ISO 10993-20)
9.8 ests for Genotoxicity, Carcinogenicity and Reproductive

T
Toxicity (ISO 10993-3)
The assessment of mutagenic, carcinogenic and reproductive hazards (potentially

irreversible biological effects) is an essential component of the control of these
risks. In this part we will be discussing the test methods that are most acceptable and
which will assist for achieving maximum test sensitivity.
Carcinogenicity test: test to determine the carcinogenic potential of medical

devices, materials and/or extracts using multiple exposures for a major portion of
the life span of the test animal
Genotoxicity test: test using mammalian or non-mammalian cells, bacteria, yeasts,
fungi or whole animals to determine whether gene mutations, changes in chro-
mosome structure or other DNA or gene changes are caused by the test samples
Reproductive and developmental toxicity test: test to evaluate the potential
effects of test samples on reproductive function, embryonic morphology (terato-
genicity) and prenatal and early postnatal development
Risk assessment of these tests is done using different tests. Signals for these stud-
ies are drawn from their structure, manufacturing process, degradation products or
metabolites and/or their structure activity relationship. Other important parameters
are route of exposure, patient population, duration of exposure to device, etc.
Apart from above characteristics of device for carcinogenicity studies, other
additional information-related device physical characteristics (particle size and
shape, pore size, surface continuity, surface condition, device thickness) and results
from implantation and genotoxicity studies. In case of reproductive toxicity testing,
direct or indirect cumulative contact duration with reproductive tissue or foetal
development and energy depositing medical devices.
Tests for genotoxicity studies: These are used to test the genetic mutation
screened using gene mutations (point mutations) and chromosomal damage [struc-
tural aberrations such as translocations, small or large deletions and insertions and
numerical chromosomal aberrations (aneuploidy)].
In vitro tests In vivo tests

The test battery shall include: 1. Rodent bone marrow cells chromosomal
1. Gene mutations in bacteria aberrations, micronuclei in bone marrow or peripheral
2. Cytogenetic evaluation of blood erythrocytes
chromosomal damage with mammalian 2. Micronucleus test in rodents
cells 3. Metaphase analysis in rodent bone marrow
3. Mouse lymphoma tk assay 4. Transgenic mutagenicity tests
4. Mammalian cell micronucleus test
for chromosomal damage and
aneugenicity
Carcinogenicity Tests To test this, in general a single study for chronic toxicity
and carcinogenicity studies are conducted in case of where potential risk is associ-
ated with device.
Criteria Materials for which the degradation time is greater than 30 days; materi-
als introduced in the body and/or its cavities with a cumulative contact of greater
than 30 days.
Test Methods Under this test human safety factor of 100 (100 times to the maxi-
mum dose exposed by human). Dose should be physiologically compatible. And all
tests are based on OECD guidelines.
Reproductive and Developmental Toxicity Tests Test procedure followed for F1

and F2 generation based on OECD guidelines with few modification with dose,
route of application, extraction media and exposure time.
9.9 oxicokinetic Study Design for Degradation Products

T
and Leachable (ISO 10993-16)
In this framework we will be discussing principles on designing and performing

toxicokinetic studies (absorption, distribution, metabolism and excretion) relevant
to medical devices. It is essential to understand the fate of medical devices and their
degraded or leachable products. Therefore we will understand the safety and mech-
anism of adverse events associated with products.
Toxicokinetic studies vary from device to device. Physicochemical and surface
morphology of products are essential along with leachable products, if any for
designing the study protocol. All analytical tests to be standardized detect and char-
acterize degradation products, leachable and metabolites in biological fluids and
tissues. Data must be plotted against different time interval to get information on
various kinetic parameters (rate of absorption, bioavailability, bioresorption, clear-
ance, Cmax, tmax, distribution, elimination half-life and volume of distribution).
Test methods: In general study should be conducted on suitable species and sex.
Usually non-radiolabelled substances will be used. If, radiolabelled substances are
being used than there is a need to target metabolically stable positions like 14C or 3H.
Absorption It depends on route of administration; bioavailability studies are con-
ducted in case of non-parenteral route of administration.
Distribution Generally radiolabelled compounds are used. In this quantitative esti-

mation, determining the levels of radiolabelled compound in dissected tissues will
be done, and in qualitative, using whole-body autoradiography (WBA), or semi-
quantitative, using graded WBA reference doses.
Metabolism and Excretion In this test metabolic cages are to be used to collect
urine and faeces. In case of collecting volatile gases like CO2, in such situation
special devices are to be used.
1. Indications for toxicokinetic studies

2. If a device is undergoing bioresorption
3. If an implant is undergoing significant corrosion or biodegradable compounds or
leachable substances are likely to be released from the implant
4. Significant quantity of toxic component or active ingredient or nano-objects

released from the medical device
If toxicological or toxicokinetic data is available or clinical safety data on medi-
cal device or their leachable products available, in such situation there is no need to
conduct toxicokinetic studies.
10 Other Frameworks
10.1 Ethylene Oxide Sterilization Residuals (ISO 10993-7)
In this we will be studying devices which are in contact with patients. For medical
devices sterilized by ethylene oxide (EO), it is important to ensure the levels of
residual EO, ethylene chlorohydrin (ECH) and ethylene glycol (EG) and risks to
patients.
Based on duration medical devices are classified into different categories to
avoid more than permissible limit of exposure.
Classification of medical devices is delivered to patients and their permissible
limit for EO and ECH.
Limited Prolonged Permanent

Categories of exposure exposure exposure exposure
Duration ≤24 h 24 h–30 days >30 days (lifetime)
Permanent contact devices with EO 4 mg 60 mg 2.5 g
Permanent contact with ECH 9 mg 60 mg 10 g
Prolonged exposure devices with 4 mg 60 mg
EO
Prolonged exposure devices with 9 mg 60 mg
ECH
Device category EO ECH

Limited (<24 h) 4 mg 9 mg
Prolonged (>24 h < 30 d) 60 mg/30 d 60 mg/30 d
Permanent (>30 d) 2.5 g/lifetime 10 g/lifetime
Tolerable count limit (TCL) 10 μg/cm2 or negligible 5 μg/cm2 or negligible
irritation irritation
Intraocular lens 0.5 μg/lens/d 4*EO limit suggested
Blood cell separator (apheresis) 10 mg 22 mg
Blood oxygenators 60 mg 22 mg
Cardiopulmonary bypass devices 20 mg 9 mg
Blood purification devices 20 mg 9 mg
(haemodialysers)
Device category EO ECH

Drapes contacting intact skin 10 μg/cm2 or negligible 5 μg/cm2 or negligible
irritation irritation
Adopted from ISO 10933 series
Tolerable contact limits for surface contacting devices and implants (mg/sqcm):
Primary aim is to prevent localized irritation. Tolerable contact limit for EO > 10 μg/
cm2 or negligible irritation. For ECH 5 mg/cm2 or negligible irritation. But in
special situations their exposure limit further changes (e.g. EO in intraocular
lenses shall not exceed 0.5 μg EO per lens per day, or 1.25 μg per lens).
Determination of EO and ECH Residuals
Ethylene oxide: Ethylene oxide is an irritating inflammable gas and mutagenic,

fetogenic and teratogenic.
Ethylene Chlorohydrin This is a flammable liquid that is irritating to body sur-
faces, acutely toxic and readily absorbed through the skin in toxic amounts. It has
weak mutagenic potential, has some potential to produce fetotoxic and teratogenic
changes and can produce injury to several organ systems in the body including
lungs,kidneys, central nervous system and cardiovascular system.
To evaluate their levels, gas chromatographic test can be performed.
Factors Influencing Product Residual
Material Composition Materials that contain a source of free chloride ions exhibit
a wide degree of variation in the concentration of ECH formed; therefore a single
device composed of two dissimilar materials may require a representative sample of
both materials to ensure accurate analysis.
Packaging Packaging material based on their packing density and the density of
the shipping container varies the penetration and dissipation of both EO gas and the
other possible residues, which may in turn affect ECH residue levels.
Ethylene Oxide Sterilization Cycle Gas concentration, exposure time, tempera-

ture, type of cycle (i.e. pure EO or EO mixtures), humidity (including the quality of
the water source), re-evacuations and air washes and the product and load density or
the configuration of the product load in the sterilizer can modify the residual levels.
Aeration Residual EO in devices may vary as a function of aeration temperature,

load density and configuration, air flow, loading pattern, surface area of products
being aerated and aeration time. Some materials demonstrate aeration rates which
can roughly double (aeration time reduced by one half) for each 10 °C increase in
aeration temperature.
Factors such as humidity, temperature and air flow may influence ECH formation
depending on EO content in the product after removal from the sterilizer.
Factors such as humidity, temperature and air flow may influence ECH formation
depending on EO content in the product after removal from the sterilizer.
Analysts should be aware of seasonal variations in aeration rates when samples
are stored under laboratory conditions which differ from the ambient warehouse
conditions. Under certain circumstances, which can best be determined by experi-
ence, it may be necessary to hold samples prior to analysis under conditions that
approximate the lowest temperature at which the product is likely to be stored dur-
ing aeration.
D.1.6 Sample Retrieval
Caution should be exercised when product samples are routinely removed for
analysis from the sterilization load soon after the sterilization process is completed.
Caution should also be exercised when the product sample or an extract thereof is
shipped to an analysis site remote from the sterilization site. In such cases, the errors
associated with attempting to correlate the residue amounts on samples and on the
rest of the load should be recognized and an experiment to establish the relation-
ships between these conditions carried out.
D.2 Controlling variables
Given sufficient experimental evidence on residue diffusion kinetics (e.g. the rate
of EO gas dissipation from the packaging for the range of given devices), it may be
possible to group devices for quality assurance testing based on similarities of mate-
rials, manufacturing processes and use. For such a classification system to work, the
variables discussed above must be controlled. Lack of control may yield data about
residue levels that are applicable only to the samples analysed.
Extraction Conditions for Determination of Residual EO
Below table represents suggested extraction conditions that could facilitate labora-
tory operations.
Device contact duration

Permanent contact (>30 d) Prolonged exposure (24 h to 30 d) Limited exposure (>24 h)
Extensive extraction Simulated use Simulated use

Ethylene Oxide Residue Measuring Methods
EO method Intralaboratory Interlaboratory

Headspace method 3.7% 21.3%
Acetone method 4.1% 16.3%
DMF method 2.9% 8.3%
Aqueous method 2.7% 17.0%
ECH Methods
If devices are classified under more than one category, rigorous testing is performed.
Allowable limits: In general, maximum allowable limit in case of prolonged
exposure and permanent contact are mentioned in the table under heading of 10.1.
10.2 stablishment of Allowable Limits for Leachable

E
Substances (ISO 10993-17)
Risks associated with exposure to hazardous leachable substances are managed by

identifying the leachable substances, quantifying the associated risks and limiting
exposure within tolerable levels. Allowable limits may be based upon health risks
that can be systemic or local, immediate or delayed, and range in severity from
minor localized adverse effects to life-threatening risks. A method for the determi-
nation of allowable limits for substances leachable from medical devices should be
predetermined. It is intended for use in deriving standards and estimating appropri-
ate limits where standards do not exist. It describes a systematic process through
which identified risks arising from toxicologically hazardous substances present in
medical devices can be quantified.
General Principles for Establishing Allowable Limits Evaluating the biological
risk associated with the leachable substance from previous data and critical health-
related endpoints, identification of tolerable limit based on route of administration
and duration of exposure along with tolerable contact limit in case of irritation as an
endpoint. Tolerable exposure depends on patient’s body mass index and device uti-
lization factor. Feasibility of test also evaluated based on general approach or case-
by-case basis.
Establishment of Tolerable Intake (TI) for Specific Leachable Substances From

toxicological data, no observed adverse effect level (NOAEL) is to be established.
Part 22
Guidance on Nanomaterials In this we will be discussing materials which con-

tain or generate nanomaterials. Any structure with 1 nm and 100 nm dimensions is
considered as nanomaterial. In this size materials potentially interact with subcel-
lular components like DNA. Therefore it is essential to evaluate the materials which
are prepared with nanomaterials, or produced during its use.
Biological risk evaluation of nanomaterials depends on type and duration of con-
tact. Initially extract the available information related to the material, and if the
available data suggests acceptable risk, then no further testing is required.
Characterization of nanomaterials: Physiochemical characterization of nanoma-
terials is essential to understand their behaviour in the biological systems.
Physiochemical of material includes their composition, external features and its
activity surrounding environment. Toxicological testing of nanomaterial is based on
its chemical structure, size, distribution, purity, solubility, etc., along with additional
properties like crystallinity, redox potential, radical formation potential, etc.
Chemical composition and purity test, X-ray fluorescence, X-ray photoelectron
spectroscopy, Auger electron spectroscopy, scanning electron microscopy + XRD
or energy-dispersive X-ray spectroscopy (EDS), nuclear magnetic resonance and
single-particle, inductively coupled plasma-mass spectrometry (spICP-MS) can
be used.
Particle size and particle size distribution are assessed by dynamic light scatter-
ing, small-angle X-ray scattering, size exclusion chromatography, analysis of
images of scanning electron microscopy (SEM), transmission electron microscopy
(TEM) or scanning probe microscopy (SPM), differential mobility analysis, cen-
trifugal liquid sedimentation, nanoparticle tracking analysis, Raman spectroscopy,
laser-induced incandescence, confocal laser scanning microscope (CLSM), single-
particle ICP-MS, tangential flow filtration for nanomaterial and separation followed
by appropriate detection, e.g. ICP-MS.
Biological tests for nanomaterial are done by using representative test material
instead of positive and/or negative controls. A representative test material must be
homogenous and stable with respect to one or more specified properties. Currently
available reference materials are titanium dioxide, colloidal silica, gold and single-
walled carbon nanotubes. Reference materials play a very critical role in the risk
assessment of nanomaterials.
Sample Preparation for Testing Nanomaterials Sample preparation for nanoma-
terials is difficult compared to bulk products because of its size and potentially
altered physiochemical properties. Nano-objects have larger surface area leading to
more reactivity, formation of aggregates, transformation due to hydration or other
processes, etc. The surface area of nanomaterials will be higher than the regular
devices and it is important to understand the hazard potential. In case of nanomateri-
als along with the effects of residues, the nanomaterials to be dispersed in a liquid
for direct risk assessment has to be tested. Dispersion test is primarily used for polar
products. Endotoxin considered to be most common confounding factor with stock
solution is therefore properly evaluated for its contamination. Commonly used test
for this test is limulus amoebocyte lysate (LAL) assay. Sterilization is a mandatory
process before preclinical evaluation of nanomaterials.
Release of Nanomaterials from Medical Devices It is necessary to understand

the rate of release of particle, its quantity, movement and accumulation in the differ-
ent parts of the body. This is to be evaluated in special conditions like joint replace-
ment implant because they have potential to bind to cells and their components and
cause their anomaly.
Toxicokinetic of Nanomaterials A toxicokinetic study is only required if the

nanomaterial has the potential to be released from a medical device and become
absorbed, distributed, metabolized and/or excreted. Factors such as route of admin-
istration, size of the nano-object or its aggregates/agglomerates, surface properties
(chemistry and charge), animal species, dose and dosing methods have all been
reported to influence the toxicokinetics in animal models. Toxicological evaluation
is done.
In vitro cytotoxicity testing In vivo testing

In this test, the impairment of cellular functions like the In this part apart from toxicokinetic
disruption of plasma membrane integrity, interference studies, reproductive toxicity,
with organelle function, disruption of the cytoskeleton, genotoxicity and carcinogenicity
etc. tested studies
1. Neutral red uptake Commonly performed tests for
2. Colony formation genotoxicity studies are:
3. MTT [3-(4,5-dimethyl-2-thiazolyl)-2,5- Micronucleus test in rodent
diphenyltetrazolium bromide] erythrocytes or bone marrow
4. XTT {2,3-bis[2-methoxy-4-nitro-5-sulfophenyl]-5- Chromosomal analysis in rodent bone
[(phenylamino)carbonyl]-2H-tetrazolium marrow
hydroxide} DNA strand break analysis (in vivo
For the genotoxicity testing: comet assay)
The mouse lymphoma tk assay Single-cell gel assay
Hypoxanthine-guanine phosphoribosyltransferase Transgenic animal models
(HPRT) mutation assay Commonly performed tests for
Double-strand breaks are neutral comet carcinogenicity studies are: life time
Single-strand breaks are alkaline comet and bioassays; apart from studies explained
oxidative damage earlier transgenic animals like the
murine rasH2 model
Immunotoxicity, Irritation and Sensitization In general, immunotoxicity is

evaluated during repeat dose toxicity testing (e.g. 28 d or 90 d) during which the
first indications for immunosuppression and/or immunostimulation can be detected.
In vitro models provide a reliable and preferred method of studying the immune cell
function. The impact of nanomaterials on immune cell function can be studied by
evaluating signaling pathways, such as the nuclear factor kappa B pathway, in spe-
cific immune cell lines. These are phagocytosis, chemotaxis and nitric oxide
production by macrophages in addition to many other endpoints.
Nano-objects have been used as haptens or hapten carriers, which indicates that
they are capable of exerting an adjuvant activity affecting the immune system. For
silver nanoparticles, the effects on the immune system were found to be the most
sensitive parameter of systemic toxicity after intravenous administration for 28 d.
Sensitization To assess local toxicity, various tests, such as the Buehler test (BT),
guinea pig maximization test (GPMT), local lymph node assay (LLNA), human
patch test (HPT) and a modified GPMT (GPMT with surface application), are used.
In vivo tests like the direct peptide reactivity assay (DPRA), the human cell line
activation test (h-CLAT), etc. are used.
Irritation Irritation tests (including intracutaneous reactivity) should be consid-

ered to estimate the irritation potential of medical devices, materials and/or their
extracts, using an appropriate site for application such as the skin, eye and mucous
membrane in a suitable model. The test(s) performed should be appropriate for the
route (skin, eye, mucosa) and duration of exposure or contact. Various properties of
nano-objects can affect their uptake after skin, eye or mucosa exposure; these prop-
erties include (but are not limited to) size, shape, surface area, surface charge, sur-
face energy/activity, solubility, aggregation state, polydispersity and ion dissolution
kinetics. Chemical composition of the main nanomaterial can also affect potential
irritation caused by nanomaterials.
Ocular Irritation Test The Bovine Corneal Opacity and Permeability (BCOP) test
method and the Isolated Chicken Eye (ICE) test method.
Oral Mucosa Irritation Test After applying test agents in the oral cavity, gross
and histological examination done and results are evaluated based on severity of
local inflammation from changes.
Penile Irritation Test For acute exposure, note the appearance of the penis in 1 h
after the initial application (e.g. immediately prior to the next application) and sub-
sequent treatments. Also observe at 1, 24 and 48 h of post-application.
For prolonged repeated exposure tests, note the appearance of the penis at first
hour after the initial application and immediately prior to the next application.
Grade the skin surface reactions for erythema accordingly.
Rectal Irritation Test It is indicated in case the material contacts with the rectal
tissue during clinical use. In case a test material showed to be skin/eye irritant, those
with a pH < 2.0 or > 11.5, then it is characterized as rectal irritant; in such scenario
it is not essential to perform rectal irritation tests. A short catheter or cannula is
inserted in the rectum and test solution delivered and observed for changes. This test
should be repeated for 5 days. Observe for appearance of the perineum for signs of
discharge, erythema and irritation. Results are evaluated by macro- and microscopic
appearance of rectal tissue by pathologist.
Vaginal irritation test: It is indicated in case the material contacts with the vaginal
tissue during clinical use. In case a test material showed to be skin/eye irritant, those
with a pH < 2.0 or > 11.5, then it is characterized as rectal irritant; in such scenario
it is not essential to perform rectal irritation tests. Healthy young adult female albino
rabbits (n = 3) from a single strain weighing not less than 2 kg shall be used. A short
catheter or cannula is inserted in the vagina and test solution delivered and observed
for changes. This test should be repeated for 5 days. Observe for appearance of the
perineum for signs of discharge, erythema and irritation. Results are evaluated by
macro- and microscopic appearance of rectal tissue by pathologist.
Human Skin Irritation Test At least 30 volunteers shall complete the test, with no
less than one-third of either sex. Apply the test material to intact skin at a suitable
site, e.g. the upper outer arm, by means of an occlusive chamber containing a gauze
pad. The application site shall be the same in all volunteers and shall be recorded.
Generally, the patch shall measure at least 1.8 cm, preferably 2.5 cm in diameter.
The patch shall be held in contact with the skin by means of a suitable non-irritating
dressing, including non-irritating tape, for the duration of the exposure period.
Duration of exposure starts from 15 or 30 min to up to 4 h.
Clinical evaluation is done using observable changes on skin like erythema, dry-
ness and oedema.
In Vitro Tests for Skin Irritation Human skin models can be obtained commer-
cially (e.g. EpiDerm, EPISKIN, Vitrolife-Skin, TESTSKIN, LabCyte EPI-MODEL)
or be developed or constructed in the testing laboratory. The preferred ones are
EpiDerm and EPISKIN tests.
Haemocompatibility These tests are performed in case of nanomaterials contact-

ing with blood or blood products (biological evaluation materials already explained).
References
ISO 10993-1:2018 Biological evaluation of medical devices Part 1: Evaluation and testing within
a risk management process
ISO 10993-2:2006 Biological evaluation of medical devices Part 2: Animal welfare requirements
ISO 10993-3:2014 Biological evaluation of medical devices Part 3: Tests for genotoxicity, carci-
nogenicity and reproductive toxicity
ISO 10993-4:2017 Biological evaluation of medical devices Part 4: Selection of tests for interac-
tions with blood
ISO 10993-5:2009 Biological evaluation of medical devices Part 5: Tests for in vitro cytotoxicity.
ISO 10993-6:2016 Biological evaluation of medical devices Part 6: Tests for local effects after
implantation
ISO 10993-7:2008 Biological evaluation of medical devices Part 7: Ethylene oxide sterilization
residuals
ISO 10993-8:2001 Biological evaluation of medical devices Part 8: Selection of reference materi-
als (withdrawn)
ISO 10993-9:2010 Biological evaluation of medical devices Part 9: Framework for identification
and quantification of potential degradation products
ISO 10993-10:2013 Biological evaluation of medical devices Part 10: Tests for irritation and skin
sensitization
ISO 10993-11:2018 Biological evaluation of medical devices Part 11: Tests for systemic toxicity
ISO 10993-12:2012 Biological evaluation of medical devices Part 12: Sample preparation and
reference materials (available in English only)
ISO 10993-13:2010 Biological evaluation of medical devices Part 13: Identification and quantifi-
cation of degradation products from polymeric medical devices
cation of degradation products from ceramics
cation of degradation products from metals and alloys
ISO 10993-16:2018 Biological evaluation of medical devices Part 16: Toxicokinetic study design
for degradation products and leachables
ISO 10993-17:2009 Biological evaluation of medical devices Part 17: Establishment of allowable
limits for leachable substances
ISO 10993-18:2020 Biological evaluation of medical devices Part 18: Chemical characterization
of medical device materials within a risk management process
ISO/TS 10993-19:2006 Biological evaluation of medical devices Part 19: Physico-chemical, mor-
phological and topographical characterization of materials
ISO/TS 10993-20:2006 Biological evaluation of medical devices Part 20: Principles and methods
for immunotoxicology testing of medical devices
ISO/TR 10993-22:2017 Biological evaluation of medical devices Part 22: Guidance on
nanomaterials
FDA-CFR Title 21-Food and Drugs: Parts
800 to 1299
Indumathy Jagadeeswaran, Nandhini Palani, and Ganesh Lakshmanan
1 Introduction
(a) FDA and FD&C Act

Federal Food, Drug, and Cosmetic Act (FD&C Act) is the legal authority of FDA
that regulates the medical devices along with electronic radiation-emitting products.
FDA’s level of control over these products was provided in the FD&C Act where the
act is comprised of regulatory requirements and provisions for FDA to control the
products. FDA develops, publishes, and implements regulations and provisions of
FD&C Act over medical devices and radiation-emitting products [1].
(b) Federal Register (FR)
The FR is an official standard register of FDA, where official daily publication
for rules, proposed rules, and notices of Federal agencies and organizations are
documented. In addition, executive orders and other crucial presidential documents
are encompassed in the register. Initially, all the rules proposed were made available
in the FR for availing public comments, and the finalized rule will be documented
in the Code of Federal Regulations (CFR). After the respective modifications, if any,
according to public and professional comments, the final regulations will be placed
Department of Biological Sciences, Southern Methodist University,
University Park, TX, USA
N. Palani
National Reference Laboratory, National Institute for Research in Tuberculosis,
Chennai, Tamil Nadu, India
G. Lakshmanan
Department of Anatomy, Asan Memorial Dental College and Hospital,
Chengelpetu, Tamil Nadu, India
190 I. Jagadeeswaran et al.
or codified into the printed edition of the Code of Federal Regulations (CFR) on an
annual basis [1, 2]. Specific website for finding recently published FR’s is
Regulations.gov [3].
(c) Code of Federal Regulations (CFR)
The CFR is a codification where executive departments and agencies of the fed-
eral government publish the general and permanent rules in the FR [4]. The CFR
was categorized into 50 title heads which epitomize broad areas subject to Federal
regulation [5]. The highly important title of CFR is Title 21 Parts 800-1299 in which
most of the FDA’s medical device and radiation-emitting product regulations were
comprised. The CFR codifies final regulations of various aspects of design, clinical
evaluation, manufacturing, packaging, labeling, and postmarketing surveillance of
medical devices. Regulations addressing standards and product reports implicating
radiation-emitting products were addressed in CFR [1]. Various fields of products
are categorized into the parts as mentioned in Table 1.
(d) Electronic Code of Federal Regulations (e-CFR)
The e-CFR is a current updated version of CFR, which is an unofficial editorial
compilation of CFR material and FR amendments produced by the national archives
and Records Administration’s Office of the Federal Register (OFR) and the
Government Printing Office. However, it is an official legal edition of the CFR. On
a daily basis, the new materials will be updated by the OFR in the e-CFR. The cur-
rent update status appears at the top of all e-CFR webpages [6].
2 FDA-CFR Title 21-Food and Drugs: Parts 800 to 1299
Title 21 CFR-FDA Parts 800 to 1299 were comprising of many essential regulations
of medical devices and radiation emitting products [7]. The parts from 800 to 898
related to medical devices and their responsibilities were tabulated [7] in Table 2.
In this chapter, we will discuss in detail all the parts pertinent to medical devices
in FDA-CFR Title 21.
Table 1 Respective parts of CFR dealing with specific products and responsibilities
S.No. CFR parts Products and responsibilities
1 1–99 Product jurisdictions, protection of human subjects, institutional review
boards, etc.
2 100–799 Food, human and animal drugs, biologics, cosmetics
3 800–1299 Medical devices and radiation emitting products
4 1300–1499 Controlled substances
FDA-CFR Title 21-Food and Drugs: Parts 800 to 1299 191
Table 2 Parts of FDA-CFR Title 21 which carry responsibilities of medical devices

CFR Title 21
S.No. part no. Products and responsibilities
1 800 General [8]
2 801 Labeling [9]
3 803 Medical device reporting [10]
4 806 Medical devices; reports of corrections and removals
5 807 Establishment registration and device listing for manufacturers and
initial importers of devices
6 808 Exemptions from federal preemption of state and local medical device
requirements
7 809 In vitro diagnostic products for human use
8 810 Medical device recall authority
9 812 Investigational device exemptions
10 813 [reserved]
11 814 Premarket approval of medical devices
12 820 Quality system regulation
13 821 Medical device tracking requirements
14 822 Postmarket surveillance
15 830 Unique device identification
16 860 Medical device classification procedures
17 861 Procedures for performance standards development
18 862 Clinical chemistry and clinical toxicology devices
19 864 Hematology and pathology devices
20 866 Anesthesiology devices
21 868 Cardiovascular devices
22 870 Dental devices
23 872 Ear, nose, and throat devices
24 874 Gastroenterology-urology devices
25 878 General and plastic surgery devices
26 880 General hospital and personal use devices
27 882 Neurological devices
28 884 Obstetrical and gynecological devices
29 886 Ophthalmic devices
30 888 Orthopedic devices
31 890 Physical medicine devices
32 892 Radiology devices
33 895 Banned devices
34 898 Performance standard for electrode lead wires and patient cables
2.1 art 800: General Requirements for Specific Medical

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Devices [8]
All the preparations that were offered or intended for various ophthalmic purposes
including contact lens solutions should be sterile, as per the informed medical opin-
ion. If the ophthalmic preparations are nonsterile and fall below their avowed stan-
dard of purity or quality, then the preparation was considered as adulterated under
Section 501(c) of the FD&C Act and may also be misbranded according to Section
502(j) of the Act. This ruling is applicable to all ophthalmic preparations which are
considered as medical devices, i.e., contact lens solutions, by this regulation and for
the ophthalmic preparations that are regulated as drugs by the regulation in 200.50
of FDA. The containers or individual carton used should be at the time of filling and
shall be sealed to ensure that the contents cannot be used without destroying the
seal. Multiple-dose ophthalmic preparations should be packed in containers either
comprised of one or more suitable and harmless substances for inhibiting the growth
of microorganisms or proper labelling with duration of use and necessary warnings
to minimize contamination during use.
The FDA has an authority and responsibility under the FD&C Act, to establishment
of a uniform national standard for tamper-resistant packaging and labelling of the over-
the-counter (OTC) healthcare products including contact lens solution and/or tablet or
other dosage form used for preparing ophthalmic solutions in accordance with 800.12
regulation of the FDA. Tamper-resistant packages have an indicator or a barrier to
entry, which if breached or missing gives a visible evidence to the consumers that the
tampering has occurred. This act improves the security of OTC products vulnerable to
malicious adulteration and assure the safety and effectiveness of the product contained
therein. The indicator or barrier is required to be distinctive by design or by using iden-
tification characteristics like pattern, name, registered trademark, logo, or picture in
order to reduce the likelihood of substitution of the tamper-resistant feature. The term
“distinctive by design” indicates that the package cannot be duplicated with commonly
available materials or processes. A statement on the temper-resistant feature of the
package is required to be placed in a way that it will be unaffected if the temper-resis-
tant feature of the package is breached or missing. For example, statement on a bottle
with a shrink band might say “For your protection, this bottle has an imprinted seal
around the neck.” All the ophthalmic solutions intended for retail sale that is not pack-
aged in a tamper-resistant package and not labelled in accordance with this section of
FDA regulation shall be considered adulterated under Section 501 and/or misbranded
under Section 502.
Given the prevalence of human immunodeficiency virus (HIV), which causes
acquired immunodeficiency syndrome (AIDS) and other blood-borne infectious
diseases, FDA had started to regulate the quality of barrier devices such as medical
gloves (i.e., surgeons’ gloves and patient examination gloves) in order to control the
risk of disease transmission in the healthcare context. Healthcare workers are rec-
ommended to wear medical gloves while handling blood or other body fluids,
mucous membranes, or non-intact skin of all patients by the Centers for Disease
Control and Prevention (CDC) to reduce the risk of transmission of blood- and
fluid-borne pathogens. Hence, FDA defined adulteration for patient examination

and surgeons’ gloves, as a means of assurance of the safety and effectiveness of the
devices through this regulation. FDA collects sample from lots of medical gloves
based on sample sizes, sample inspection levels, and acceptable quality levels
(AQLs) as per International Standard Organization (ISO) 2859, “Sampling proce-
dures for inspection by attributes.” The lots of medical gloves that are sampled,
tested, and rejected using the test methods such as general test method, leak test
materials, and visual defects and leak test procedures are considered adulterated as
per the 501(c)act. A lot of medical gloves is considered adulterated by FDA, if the
number of defective gloves found in the tested sample meets or exceeds the appli-
cable rejection number at 1.5 AQL for surgeon’s gloves or the 2.5 AQL for examina-
tion of patient gloves.
Administrative Practices and Procedures
The medical devices intended for human use may be ordered detention in accor-
dance with Section 704 of the FD&C Act by an authorized FDA representative,
during an inspection, if the device is believed to be adulterated or misbranded, as
defined in Section 201(h) of the Act. Administrative detention prevents the distribu-
tion or use of adulterated or misbranded medical devices to ensure public safety,
until the FDA considers the action to be carried out concerning the devices and to
initiate legal action, if appropriate. The medical devices ordered detention by FDA
may not be used, moved, altered, or tampered during the detention period. The
detention period is usually 20 calendar days. However, if the FDA determines that a
greater period is required to seize the device or to evaluate the legal action required,
the total detention period may not exceed 30 calendar days.
2.2 Part 801: General Labeling Provisions [9]
The label of the device in package form shall specify the name and place of business
including city, State, and/or zip code of the manufacturer, packer, or distributor. If
medical devices are manufactured or packed or to be distributed at a place other
than the principal place of business of the manufacturer, packer, or distributor, then
the label may specify the principal place of business, unless such statement would
be misleading. The labelling of a device is considered misbranded, if it represents a
false or misleading representation with respect to another device or food or cos-
metic or a drug. If the label of the medical device includes a printed expiration date,
date of manufacture, or any other date intended to be brought to the attention of the
medical device user, the date should be presented in the following format: year
(YYYY), followed by month (MM) and day (DD), i.e., 2020-11-03. Labelling of a
device should also supply adequate directions for use, which ensures a layman can
use a device safely for its intended purposes. Directions for use may be considered
inadequate because of omission (either in whole or in part) or incorrect specifi-
cation of:
(a) Statements on the conditions, purposes, or uses for the intended common use of
medical device, for which it is prescribed, recommended, or suggested in its
oral, written, printed, or graphic advertising
(b) Quantity of dose for persons of different ages and different physical conditions
(c) Frequency of administration/application
(d) Duration of administration/application
(e) Time of administration/application, in relation to time of meals, time of onset
of symptoms, or other time factors
(f) Route or method of administration or application
(g) Preparation for use, i.e., adjustment of temperature or other manipulation
or process
These statements are required to appear on the label, and no exemption due to
insufficiency of label space will be allowed by the FDA under Section 502(c)act. All
the statements and other information on the label shall appear in English language
or replaced by the predominant language of the territory, where the device is
distributed.
Labeling Requirements for Unique Device Identifier
The label/package of every medical device shall bear a unique device identifier
(UDI) that meets the requirements of Section 801.20 and Part 830 of the FDA. In
addition to the UDI on label, each device must also carry a permanent direct mark-
ing UDI on the device itself, which can be identical to the UDI on the label of the
device or a different UDI that can be used to distinguish the unpacked device from
any device package containing the device. Direct marking of UDI on the device
shall be exempted in conditions such as interference with the safety and effective-
ness of the device, technologically not feasible for direct marking, and in single-use
devices. Every UDI must be presented in both easily readable plain text and auto-
matic identification and data capture (AIDC) technology. The UDI must include
device identifier segment that conveys the information such as a lot or batch num-
ber, a serial number, a manufacturing date, and an expiration date. Stand-alone soft-
ware regulated as a medical device must display its UDI as a readable plain-text
statement either when the software starts or through a menu command or both.
Once the UDI is assigned to a device, then National Health-Related Item Code
(NHRIC) or National Drug Code (NDC) number may no longer be required to be
on the label/package of the medical device. However, medical devices including
class I device with a universal product code (UPC), single-usage devices, combina-
tion product with NDC numbers, and shipping containers are excepted from the
requirement to bear a UDI according to Sections 801.30, 801.45, and 801.128(f)(2)
of this FDA regulation. Section 801.55 provides a means to request an exception or
alternative not provided by those provisions.
Labeling Requirements for Over-the-Counter Devices
The term principal display panel in over-the-counter devices in package form refers
to the part of a label that is usually displayed, presented, shown, or examined under
customary conditions of display for retail sale. The principal display panel should
accommodate and display all the mandatory label information with clarity and con-
spicuousness, and without obscuring designs, or crowding. In medical device pack-
ages with alternate principal display panels, the label information shall be duplicated
on each principal display panel. To ensure uniform font size in declaring the con-
tents of principal display panel for all packages, the term area of the principal dis-
play panel is defined as the area of the side or surface that bears the principal display
panel. For example, in case of rectangular package, one entire side (product of
height times the width of that side) shall be principal display panel side. The princi-
pal display panel shall bear a statement of identity of the commodity, followed by
an accurate statement of the principal intended action(s) of the device. Statement of
identity is one of the principal features of the principal display panel and shall be in
size reasonably related to the most prominent printed information on such panels.
The label of these over-the-counter medical device in package shall bear a declara-
tion of the net quantity of contents expressed in terms of weight, measure, numeri-
cal count, or its combination. All over-the-counter devices containing or
manufactured with chlorofluorocarbons, halons, carbon tetrachloride, methyl chlo-
ride, or any other class I ozone-depleting substance designated by the Environmental
Protection Agency (EPA) shall carry a warning statement. In accordance with the
requirements of 40 CFR part 82, this warning statement should be legible, promi-
nent, and conspicuous on the product, its immediate container, its outer packaging,
or other labeling to be easily read and understood by consumers.
Exemptions from Adequate Directions for Use
Devices with potentiality for harmful effect, or its common method of use known to
ordinary individual or requires collateral measure such as supervision of a practitio-
ner licensed by law for its use, are exempted for the requirement of “adequate direc-
tions for use” in the label. Medical devices used for processing or repacking in the
manufacture of another drug/device or as in vitro diagnostic product (use in diagno-
sis of disease) or shipped or sold to persons regularly and lawfully engaged in teach-
ing, law enforcement, research, and analysis, or any device held by the Strategic
National Stockpile, shall be exempted from Section 502(f)(1) of the FDA Act, if the
device meets the following conditions:
(a) If the device is in the possession of a person or his employees or agents manu-
facture, transportation, storage, or wholesale or retail distribution of such
device; or a practitioner, such as physicians, dentists, and veterinarians, licensed
by law to use or order the use of such device.
(b) Is sold only to or on the prescription or for use by a licensed practitioner in the
course of his professional practice.
(c) Label of the medical device (except surgical instruments) bears symbol “Rx
only” or “℞ only” or caution statement to restrict the sales of the device by or
on the order of a state law licensed practitioner; and a method of its use or
application.
(d) Labeling on or within the package of the dispensed medical device should bear
the information for use, including indications, effects, routes, methods, fre-
quency, and duration of administration, and any relevant hazards, contraindica-
tions, side effects, and precautions for the purpose it’s advertised or
represented.
(e) All the labelling bearing the information for use of the device also bears the
date of issuance or the date of latest revision of such labelling.
2.3 Part 803: Medical Device Reporting [10]
This part delineates the requisites for medical device reporting to the facilities
where the device will be used, to manufacturers, importers, as well as distributors.
The device user facility should register and notify the deaths and serious injuries
contributed and suspected from the device usage. Device malfunctions and adverse
events should be recorded and maintained. These ensures the devices are not adul-
terated or misbranded and are used safely and effectively. The distributor must also
maintain the records of incidents, though they may not report the same. Any report
submitted can be disclosed to the public in accordance with §803.9. It includes FDA
report of telephone records. But trade secrets, confidential commercial and financial
information, personal medical information like serial numbers of implanted devices,
and names and information identifying a third party that voluntarily submitted an
adverse event report can all be deleted before public disclosure.
Reporting Requirements That Applies to Device User Facility
The device user facility must submit individual adverse events within 10 working
days including device-related deaths and serious injuries to the manufacturer and
FDA. The importer should submit annual report on adverse events, device-related
deaths, or serious injuries to FDA and the manufacturer. Any device-related mal-
function should be reported to the manufacture, and the manufacturer should report
about individual adverse events in 30 calendar days. Any reportable event requiring
remedial action or upon a written request over any reportable event and to submit
supplemental reports to a submitted initial report can be submitted within 5 working
days. The manufacturer or importer must report individual adverse events in elec-
tronic format in accordance with §803.11.
The manufacturer or importer must report initial, supplemental, or follow-up
reports in electronic format that FDA can process, review, and archive. User facili-
ties must submit their reports and additional information in electronic format in
English to FDA as “User Facility Report” or “Annual Report.” Confrontations with
public health emergencies can be brought to FDA’s attention at 301-796-8240 or toll
free at 866-300-4374, followed by the submission of an email to emergency.opera-
[email protected]. When further additional information is required, the FDA will
notify in writing about the required additional information if protection of the pub-
lic health requires additional or clarifying information for medical device reports
submitted and in cases when the additional information is beyond the scope of FDA
reporting forms or is not readily accessible to FDA. All such request will state the
reason or purpose for the information request, specify the due date for submitting
the information, and clearly identify the reported event(s) related to our request.
Verbal request for additional information will be followed by request in writing.
Any report or information submitted to FDA following the written request does not
necessarily reflect a conclusion that the device, or manufacturer or their employees,
caused or contributed to the adverse event.
Requirements for Developing, Maintaining, and Implementing Written MDR
Procedures
Any user facility, importer, or manufacturer must develop, maintain, and implement
written MDR procedures for internal systems that provide for identification, com-
munication, and evaluation of events with a standardized review process and timely
transmission of the report to the FDA or manufacturers with evaluation of report-
able event including all medical device reports and information submitted to manu-
facturers or FDA along with evaluated information for annual reports and systems
that ensure access to information that facilitates timely follow-up and inspection by
the FDA.
Requirements for Establishing and Maintaining MDR Files or Records
A user facility, importer, or manufacturer must establish and maintain MDR event
files and keep accessible with all information in possession with copies of report
submitted and copies of all electronic acknowledgements from FDA and permit any
authorized FDA employee to access and verify the same. An MDR file has to be
retained for 2 years from the date of event. A device distributor must maintain a
device complaints records of all incident information related to identity, quality,
durability, reliability, safety, effectiveness, or performance of a device along with
distributor evaluation of the same at least for 2 years even if the distributor no longer
distributes the device.
Exemptions, Variances, or Alternative Forms of Adverse Event Reporting
Requirements
A licensed practitioner is an individual, who manufactures devices intended for use
in humans solely for this person’s use in research or teaching and not for sale.
Dental laboratories or optical laboratories are exempted from adverse event report-
ing. A manufacturer, importer, or user facility, may request an exemption or vari-
ance from any or all of the reporting requirements, with the information necessary
to identify the device and a complete statement of the request for exemption, vari-
ance, or alternative reporting along with proper justification. However, this has to be
granted by FDA and can be revoked at any time.
Applicable Requirements for Individual Adverse Event Reports
A health professional or consumer or any other entity can submit their voluntary
reports to the FDA regarding their devices or products using form FDA 3500A
including a mandatory report in written form. An e-submission from a user facility,
importer, or manufacturer must have information about the patient, the event, the
device, and the “initial reporter” along with information from blocks G and H as
well as including any corrected or missing information. Within 10 days of an adverse
event, the user facility should report to the manufacturer or to the FDA. The
manufacturer should report to the FDA in 30 calendar days. All the adverse report-
ing codes to use with form FDA 3500A can be obtained from The MedWatch
Medical Device Reporting Code Instruction Manual available at https://www.fda.
gov/medical-devices/mandatory-reporting-requirements-manufacturers-importers-
and-device-user-facilities/mdr-adverse-event-codes. Any additions and modifica-
tions to the existing codes will be made available to all reporters from time to time.
Multiple information of the same patient and same event can be submitted as a
single report. If the information received is determined as erroneous, it need not be
reported by user facility, importer, or manufacturer. However, the documentation of
these reports would be mentioned in MDR files for the time periods specified in
§803.18. Any reporting to the wrong manufacturer or importer should be reported
to the FDA by the receiver of such report.
User Facility Reporting Requirements
For a user facility, reports of death and serious injury must be submitted in 10 days
to the manufacturer and the FDA as required by §803.32. Reports sent to the Agency
must be submitted in accordance with the requirements of §803.12 (b). This should
include information found in documents possessed by the user facility and any
information that becomes available as a result of reasonable follow-up within the
facility. An annual report should be submitted on form FDA 3419 by January 1 of
each year and should include CMS provider number used for medical device reports,
reporting year, name and complete address, total number of reports attached, date of
the annual report, and details of the person reporting, and all information of the
reportable events should be noted.
Importer Reporting Requirements
Reports of deaths and serious injuries as well as reports of malfunctions should be
reported to the FDA. Reports should be prepared and submitted in 30 calendar days.
Importer should correspond generally to the format of form FDA 3500A with the
necessary patient information, adverse event or product problem, all necessary
device information, and initial reporter information as well as the importer
information.
Manufacturer Reporting Requirements
In case of a suspected death or grievous injury caused by the device or upon any
malfunction of the device, it should be reported within 30 calendar days. All sorts of
information obtained by contacting a user facility, importer, or other initial reporter
as well as by analysis, testing, or other evaluation of the device should be submitted
to the FDA. It is the responsibility of the manufacturer to get and submit all the
details and also to investigate each event and evaluate the cause of the event. All
patient information, complete adverse event or product malfunction information,
detailed device information, manufacturer details, and initial reporter information
are to be furnished by the manufacturer in the form FDA 3500A from Block A to
Block H. An MDR reportable event necessitates remedial action to prevent an
unreasonable risk of substantial harm to the public health, and upon receiving a
written request for the submission of a 5-day report from the FDA, a manufacturer
should submit a 5-day report within 5 working days. It can be extended upon a writ-
ten interest and is in the interest of the public. Every foreign manufacturer whose
devices are distributed in the United States shall designate a US agent to be respon-
sible for reporting. The US-designated agent accepts responsibility for the duties
that such designation entails. US-designated agents of foreign manufacturers are
required to report to the FDA, conduct and obtain necessary information on investi-
gation and evaluation of the event, forward MDR complaints to the foreign manu-
facturer, and maintain documentation of this requirement and complaint files and
register.
2.4 art 806: Medical Devices, Reports of Corrections

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and Removals [11]
This part implements the provisions of Section 519(g) of the Federal Food, Drug,
and Cosmetic Act that mandates device manufacturers and importers to report on
any of the device corrections and removals as well as to maintain records of those
corrections and removals. However, actions taken by manufacturers to enhance the
performance or quality of a device which do not pose a health threat, market with-
drawal of the device, routine servicing, and stock recovery can be exempted from
reporting requirements.
Reports of Corrections and Removals
For any correction or removal of a device, the device manufacturer or importer
should submit a written report. This can be aimed at reducing a health risk posed by
the device or to remedy a violation of the act caused by the device, and it should be
done within 10 working days of the initiation of the correction or removal. In the
submitted report, the manufacturer or importer should include the 7-digit registra-
tion number of the entity responsible for submission of the report of corrective or
removal action (if applicable); the month, day, and year that the report is made; a
sequence number (i.e., 001 for the first report, 002 for the second report, 003, etc.);
and the report-type designation “C” or “R”. Firms that do not have a 7-digit registra-
tion number may use seven zeros followed by the month, date, year, and sequence
number (i.e., 0000000-6/1/97-001-C for corrections and 0000000-7/1/97-001-R for
removals). Reports received without a 7-digit registration number will be assigned
a 7-digit central file number by the district office reviewing the reports. It should
also include the details of the manufacturer, details of the event giving rise to the
information reported, and the corrective or removal actions that have been done and
are expected to be taken, details of the production including date, no. of devices
produced, details of all consignees of the devices, and how many was distributed by
each of them. A copy of all communications regarding correction or removal should
be added to the report. To amend any submitted report, it should be done within 10
working days of initiating the extension of the correction or removal and amended
by submitting an amendment citing the original report number assigned.
Records of Corrections and Removals Not Required to Be Reported

All correction or removal of a device that is not required to be reported to the FDA
should be maintained as a separate record. Such records shall contain details of the
device including a unique device identifier (UDI) or the device identifier, universal
product code (UPC), model, catalog, or code number of the device and the manu-
facturing lot or serial number of the device or other identification number and
description of reported events and justification for not reporting the event. All com-
munications toward this should be recorded. This should be maintained for a period
of 2 years beyond the expected life of the device. Upon request of an officer or
employee designated by the FDA and under Section 704(e) of the Act, each device
manufacturer or importer should allow them to have access to, and to copy and
verify, such records and reports maintained toward the cause. All reports under this
part are available for public disclosure, but before disclosing, the FDA will remove
any information that constitutes trade secret or confidential commercial or financial
information as well as any personnel, medical, or similar information, including the
serial numbers of implanted devices, which would constitute a clearly unwarranted
invasion of personal privacy. However, if a patient requests all the information in the
report concerning that patient, it will be released by the FDA.
2.5 art 807: Establishment Registration and Device Listing

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for Manufacturers and Initial Importers of Devices [12]
Any distribution of a device intended for human use which is held or offered for sale
is termed as commercial distribution (except of those internally transferred/
exempted/introduced before May 28, 1976), and the place of business/one general
physical location where the device is manufactured/assembled/processed is the
establishment. The designated person for annual registration of the establishment
and contact person with the FDA for device listing, maintenance, and submission of
records and corresponds between FDA and owner/operator is the office
correspondent.
Procedures for Device Establishments
(a) Who Must Register and Submit a Device List?
The term “device” can be used for all in vitro diagnostic products and in vitro
diagnostic biological products. An owner or operator shall register its name, places
of business, all the establishments while listing. In addition, registration shall per-
tain to any person who initiates or develops specifications for a device, makes a
device on behalf of specifications provided, repackages or relabels a device, repro-
cesses a single-use device that has previously been used on a patient, and the initial
importer.
(b) How to Register Establishments and List Devices?
Owners or operators of establishments must electronically register the device of
interest with initial establishment information, updates to registration information,
initial device listing information, and updates to device listing information (includ-
ing updates to reflect the halt of commercial distribution of previously listed device).
If electronic submission is not possible, a waiver may be requested for reasonable
explanations by providing information on name and address of device establish-
ments and information about the company and reason for request.
(c) Times for Establishment Registration and Device Listing
If the owner or operator of an establishment is newly entering the device in list-
ing, they shall register within 30 days after entering into an operation and submit the
device listing information at that time. If already registered, they shall review and
update any changes that were not previously reported. Failure to submit any required
information on time will be noted as “failed to register” or “failed to list,” and the
list of device may not be put on the FDA website till complete submission.
(d) Information Required for Device Establishment Registration and Device Listing
Registration information includes the name, mailing address of the device estab-
lishment, website address, contact details of the owner, establishment, and all trade
names used by the establishment. The listing shall include all officers, directors, and
partners to furnish to FDA upon request. The official correspondent would serve as
a point of contact with FDA on all matters relating to the registration of device
establishments. He/she would be responsible for providing the FDA all required
registration and listing information electronically, receiving all correspondence
from FDA, and supplying the list of officers/directors/partners upon request. The
information required for each device listed includes current registration number,
name of each establishment, product code of each device, proprietary or brand
name(s), FDA-assigned premarket submission number of approved application, and
list of each activity or process that is conducted on or done to the device at each
establishment.
(e) Additional Listing Information
Each owner or operator shall maintain a historical file containing labeling and
advertisements in use on the date of initial listing, location of files including cur-
rently existing records, historical files, copy of certification, and disclosure state-
ments. Upon specific request, each owner or operator shall provide a copy of all
labelling for the device, a copy of all advertisements, label and package insert of the
device, a statement of the basis to determine the device is not a restricted one, and
list of all distributors for whom the device is manufactured.
(f) Updating Device Listing Information
Updating of device listing information is required if an additional establishment
begins to engage or if it begins performing another activity on or to the device or
ceases to perform an activity on or the device that had previously been identified on
the device listing. However, a new device listing is created if device is not currently
listed by the owner or operator, if the device is a non-exempt one with new FDA
premarket submission number, or if the device is imported or offered into United
Sates from a foreign establishment. A device listing is discontinued if all devices
under an exempt product code have been discontinued or all devices associated with
an FDA premarket submission number have been discontinued.
(g) Summary of Requirements for Owners or Operators Granted a Waiver
An owner/operator who has been granted a waiver from electronic filing must
send a letter containing all of the registration and listing information to the Imports
and Registration and Listing Team, FDA, and shall update their establishment reg-
istration and device listings annually during the period between October 1 and
December 31 of each fiscal year. Failure to submit any required information on time
will be noted as “failed to register” or “failed to list,” and the list of devices may not
be put on the FDA website till complete submission.
(h) Notification of Registrant
The FDA will assign each device establishment a registration number after veri-
fying the initial registration information that has been submitted along with an iden-
tifying number for the owner/operator. Both these numbers will be sent to official
correspondent by email or by post. Validation of registration and device listing does
not ensure the legal qualification of registration until further scrutinization.
(i) Public Availability of Establishment Registration and Device Listing Information
Establishment registration and device listing information is made available for
public inspection with exception of certain information including contract manufac-
turers, contract sterilizers, private label manufacturers, proprietary or brand names,
and FDA-assigned listing numbers.
(j) Misbranding by Reference to Establishment Registration or to Registration
Number
Any representation intended to create an impression of official approval because
of registration approval is misleading and may be misbranded.
Procedures for Foreign Device Establishments
(a) Establishment Registration and Device Listing for Foreign Establishments
Any establishment in a foreign country importing or offering the device into the
United States shall undergo electronic device registration, and the official corre-
spondent of the foreign establishment shall facilitate communication with the FDA
on behalf of the owner or operator. Each foreign establishment shall designate only
one agent in the United States to act as an official correspondent who resides in the
United States and shall maintain a place of business. The correspondent shall assist
the FDA by responding to all questions raised, for onsite inspections, and by report-
ing changes within 10 business days of the change.
(b) Identification of Importers and Persons Who Import or Offer for Import
Upon initial registration, annually at time of any changes, each foreign establish-
ment is required to register through FDA electronic device registration and listing
system with details of importers of persons who imports or offers for import.
(c) Exemptions
The following classes of persons are exempted from registration by the
Commissioner of Food and Drugs: a manufacturer of raw materials or components
to be used for the device; a manufacturer of a device solely for veterinary purposes
or chemical reagents; licensed practitioners, pharmacies, or surgical supply outlets;
persons who manufacture, prepare, and propagate devices solely for use in research,
teaching, or analysis; and carriers of devices or who dispense devices to consumers.
Premarket Notification Procedures
(k) When a Premarket Notification Submission Is Required
Each person who has to register their establishment must submit a premarket
notification submission to the FDA at least 90 days before initiating the introduction
of commercial distribution of a device intended for human use. This includes all
devices being introduced into commercial distribution for the first time or reintro-
duced with significant changes or modifications in designs, components, method of
manufacture, or intended use.
(l) Exemption from Premarket Notification
A custom device is exempted from premarket notification requirements if it is
intended for use by a patient named in the order of the physician or dentist or solely
for use by a physician or dentist or if a distributor who places a device into com-
mercial distribution for the first time under his own name and a repackager who
places his own name on a device if the premarket notification submission was filed
by another person or if the device was in commercial distribution before May
28, 1976.
(m) Information Required in a Premarket Notification Submission
The premarket notification submission shall include the device name, estab-
lishment registration number, class of the device, statement of classification,
action taken by the person required to register to comply with the requirements,
proposed labels, labeling, advertisements, a statement indicating the device is
similar or different from other products if any, and a financial certification or dis-
closure statement or both. The submission should be supported by clinical inves-
tigations conducted inside or outside the United States, statement that the
submitter believes to best of his/her knowledge about the truthful, and accurate
information provided. If any information is requested by the Commissioner, the
same has to be submitted promptly, and failure of submission within 30 days will
make the premarket notification withdrawn.
(n) Format of a Premarket Notification Submission
Each premarket notification submission shall be submitted to respective sections
like Center for Devices and Radiological Health or Center for Biologics Evaluation
and Research, and all inquiries should be sent as a single version electronically,
separately for each product with the designated “510|(k) notification in the cover
letter.”
(o) Content and Format of a 510(k) Summary

A 510(k) summary shall contain details to provide an understanding of the basis
for a determination of substantial equivalence, and it shall include the submitter’s
name, address, and contact details; name of the device trade or proprietary name (if
applicable); identification of the legally marketed device to which the submitter
claims equivalence; description of the device, its functioning, scientific concepts,
and physical and performance characteristics; and a statement of the intended use of
the device that is the subject of the premarket notification submission. In addition to
it, it shall also include a brief discussion of clinical and nonclinical tests submitted,
conclusions drawn from these tests, and an exclusive summary with any other infor-
mation necessary to be attached.
(p) Content and Format of a 510(k) Statement
A 510(k) statement signed by the certifier shall state that “I certify that, in my
capacity as (the position held in company by person required to submit the premar-
ket notification, preferably the official correspondent in the firm), of (company
name), I will make available all information included in this premarket notification
on safety and effectiveness within 30 days of request by any person if the device
described in the premarket notification submission is determined to be substantially
equivalent. The information I agree to make available will be a duplicate of the
premarket notification submission, including any adverse safety and effectiveness
information, but excluding all patient identifiers, and trade secret and confidential
commercial information, as defined in 21 CFR 20.61.”
(q) Format of a Class III Certification
A class III certification submitted as a part of a premarket notification signed by
the certifier shall state that “I certify in my my capacity as (position held in com-
pany), of (company name), that I have conducted a reasonable search of all informa-
tion known or otherwise available about the types and causes of safety or
effectiveness problems that have been reported for the (type of device). I further
certify that I am aware of the types of problems to which the (type of device) is
susceptible and that, to the best of my knowledge, the following summary of the
types and causes of safety or effectiveness problems about the (type of device) is
complete and accurate.”
(r) Confidentiality of Information
The FDA will disclose publicly whether the device is on the market and whether
the person submitting the premarket notification submission has disclosed his intent
to market the device, analyses, or not. But FDA shall not disclose the existence of
premarket notification submission for a device that is not in the market or if requested
to hold the intent as confidential commercial information up to 90 days from the
date of the receipt of submission.
(s) Misbranding by Reference to Premarket Notification
Submission of a premarket notification and subsequent determination by the
Commissioner that the device intended is substantially equivalent to a device in the
commercial distribution. However, any representation that creates an impression of

official approval of a device because of complying with the premarket notification
regulation is misleading and can lead to misbranding.
(t) FDA Action on a Premarket Notification
After review of premarket notification, FDA will an issue an order declaring the
device to be substantially equivalent/not equivalent to a legally marketed device,
request more information, withhold decision until certification or disclosure state-
ment is submitted, or inform the applicant that the premarket notification is not
required. FDA will determine whether the device of interest is substantially equiva-
lent to a predicate device if it has the same technological characteristics or if the
device is as safe and as effective as a legally marketed device.
2.6 art 808: Exemptions from Federal Preemption of State

P
and Local Medical Device Requirements [13]
This part sets forth the procedure for submission, review, and approval of applica-
tions for exemptions from Federal preemption of State and local requirements appli-
cable to medical devices under Section 521 of the FDA Act. The FDA is responsible
for determining whether a State or local requirement is equal or substantially identi-
cal or different or in addition to the Federal requirements with respect to a device.
However, if any State or political subdivision whose requirements relating to a
device are preempted in accordance with Section 521(a), they may petition the
Commissioner of the FDA for exemption from preemption.
(a) Section 521(a) of the Act prescribes special provisions that after May 28, 1976,
no State or political subdivision of a State may establish or continue in effect
any requirement with respect to a medical device intended for human use hav-
ing the force and effect of law, which is different from, or in addition to, any
requirement applicable to such device under any provision of the act and which
relates to the safety or effectiveness of the device or to any other matter included
in a requirement applicable to the device under the Act.
(b) In accordance with Section 521(b), the Commissioner of the FDA may, upon
application by a State or political subdivision, allow imposition of a require-
ment which is different from, or in addition to, any requirement applicable
under the Act to the device (and which is thereby preempted) by promulgating
a regulation.
Exemption Procedures
A signed letter from an authorized State or political division in accordance with
§808.20 (if not, they will be returned for corrections) may request exemption to the
Commissioner of the FDA. For each requirement for which an exemption is sought
shall include all the information and explanation to justify the requirement. Upon
receipt of the application meeting the requirements of §808.20, the Commissioner
shall review such application and will issue in the FEDERAL REGISTER a
proposed regulation to either grant or deny an exemption from preemption for each
requirement. An exemption from preemption in accordance with §808.25 shall
remain effective until the Commissioner revokes such exemption.
2.7 art 809: In Vitro Diagnostic Products for Human

P
Use [14]
In vitro diagnostic products are those reagents, instruments, and systems intended
for use in the diagnosis of disease or other conditions, including a determination of
the state of health, in order to cure, mitigate, treat, or prevent disease or its sequelae.
Such products are intended for use in the collection, preparation, and examination
of specimens taken from the human body. Data and information submitted shall be
treated as confidential by the FDA and any person to whom the data and information
are referred.
Labelling for In Vitro Diagnostic Products
The label for an in vitro diagnostic product shall have its proprietary name, estab-
lished name, and its intended use. For reagents, its established name, its source, and
measure of activity should be labelled. A statement of warning and precautions
along with a statement “For In Vitro Diagnostic Use” should be added. Any other
limiting statement can also be added and shall bear the symbol statement “Rx only”
or “℞ only” or the statement “Caution: Federal law restricts this device to sale by or
on the order of a ___”, the blank to be filled with the word “physician,” “dentist,”
“veterinarian,” or the descriptive designation of any other practitioner licensed by
the law of the State in which the practitioner practices to use or order the use of
the device.
Appropriate storage instructions including temperature, light, humidity, and
other factors should be added. For products requiring manipulation, such as recon-
stitution and/or mixing before use, appropriate storage instructions shall be pro-
vided for the reconstituted or mixed product which is to be stored in the original
container. The basis for such instructions shall be determined by reliable, meaning-
ful, and specific test methods. An expiration date, net quantity of contents, and a
statement of an observable indication of an alteration of the product can be added
for a reagent. The details of the manufacturer and lot number with ability to tracing
individual units can be added.
Labelling accompanying each product should also have all the abovementioned
details.
Summary and explanation of the test including a short history of the methodol-
ogy with pertinent references and a balanced statement of the special merits and
limitations of this method or product should also be added. In case of reagents,
established names and a statement indicating the presence of and characterizing any
catalytic or nonreactive ingredients, e.g., buffers, preservatives, and stabilizers, can
be added. A statement of warning and precautions with a statement “For In Vitro
Diagnostic Use” should be added. Adequate instructions for reconstitution, mixing,

dilution, etc. should also be included. In case of instruments, use or function, instal-
lation procedures and special requirements, principles of operation, performance
characteristics and specifications, operating instructions, calibration procedures
including materials and/or equipment to be used, operational precautions and limi-
tations, hazards, and service and maintenance information should be included.
In case of a specimen collection, a description of special precautions regarding
specimen collection including special preparation, additives, preservatives, known
interfering substances, recommended storage, and handling details can all be
included. In the case of a procedure, a step-by-step outline of recommended proce-
dures from reception of the specimen to obtaining results with stressing anything
that may improve the precision and accuracy can be added. List of materials pro-
vided, list of materials required but not provided, description of reagents quantity
needed, and a statement on the stability of the final reaction and other details of cali-
bration and quality control procedures should be stated. The procedure for calculat-
ing the results in a detailed manner along with limitations of the procedure covering
the known extrinsic factors and interfering substances, with the expected values and
a final note on bibliography, should all be included. Apart from this, other standard
labelling norms should be followed.
Exceptions or Alternatives to Labeling Requirements for In Vitro Diagnostic
Products for Human Use Held by the Strategic National Stockpile
The appropriate FDA Center Director may grant an exception or alternative, if a
strategic National Stockpile official posts a written request for an exception or alter-
native. The center director may grant an exception or alternative described in para-
graph (a) of this section on his or her own initiative with the identity of the thing
explaining why compliance with such labeling provision(s) could adversely affect
the safety, effectiveness, or availability of the specified lots, batches, or other units
of the in vitro diagnostic product for human use that are or will be held in the
Strategic National Stockpile with proposed safeguards or conditions. A grant of an
exception or alternative under this section will include any safeguards or conditions
deemed appropriate by the Center Director to ensure that the labeling of the product
subject to the exception or alternative includes the information necessary for the
safe and effective use of the product, given the anticipated circumstances of use. For
a Premarket Approval Application (PMA)-approved in vitro diagnostic product for
human use, the submission and grant of a written request under this section satisfy
the provisions relating to submission of PMA supplements.
Restrictions on the Sale, Distribution, and Use of Analyte Specific Reagents
In vitro diagnostic products shall be manufactured in accordance and compliance
with the good manufacturing practices requirements. Analyte specific reagents
(ASRs) are restricted devices and may be only sold to clinical laboratories regulated
under the Clinical Laboratory Improvement Amendments of 1988 and to
Organizations that use the reagents to make tests for purposes other than providing
diagnostic information to patients and practitioners.
Advertising and promotional materials for ASRs should include the statement
for class I exempt ASRs, “Analyte Specific Reagent. Analytical and performance
characteristics are not established,” and for class II or III ASRs, “Analyte Specific
Reagent. Except as a component of the approved/cleared test (name of approved/
cleared test), analytical and performance characteristics are not established,” and
should not make any statement on its analytical and clinical performance.
The laboratory that develops an in-house test using the ASR shall inform the
ordering person of the test result by appending to the test report the statement: “This
test was developed and its performance characteristics determined by (Laboratory
Name). It has not been cleared or approved by the U.S. Food and Drug
Administration.” This statement would not be applicable or required when test
results are generated using the test that was cleared or approved in conjunction with
review of the class II or III ASR.
Restrictions on the Sale, Distribution, and Use of OTC Test Sample Collection
Systems for Drugs of Abuse Testing
Over-the-counter (OTC) test sample collection systems for drugs of abuse testing
are restricted devices. Sample testing should be performed in a laboratory using
screening tests that have been approved, cleared, or otherwise recognized by the
FDA as accurate and reliable for the testing of such specimens for identifying drugs
of abuse or their metabolites. The laboratory where the tests are performed should
have been a recognized one and proven to have adequate capability to perform
integrity checks for possible adulterations in the biological samples.
2.8 Part 810: Medical Device Recall Authority [15]
This part of the regulation describes the procedures that the FDA will follow in
exercising its medical device recall authority under Section 518(e) of the FDA Act.
If, after providing the appropriate person with an opportunity to consult the agency,
FDA finds that there is reasonable probability that the device intended for human
use would cause serious, adverse health consequences or death, the agency may
issue a notification for immediate order to:
(a) Cease the distribution of the device
(b) Notify and instruct the health professionals and the device user facilities to
cease the use of the device
A written request for regulatory hearing under §810.11 may be submitted to the
FDA for review of cease distribution and notification order. Such requests shall be
addressed to agency employee identified in the order and shall submit within the
stipulated timeframe under §16.22(b) (usually 3 working days from receipt of cease
order) specified by the FDA. Within the 15 working days of receipt of the written
request, the agency shall provide written notification (a statement) on its decision to
affirm, modify, vacate, or amend the order to the requestor. If a regulatory hearing
or agency review of the order is not requested, or within 15 working days of denying
a request for a hearing, or within 15 working days on completion a regulatory hear-
ing under §810.11, or within 15 working days of receipt of a written request for
review of a cease distribution and notification order under §810.12, then the FDA
shall amend the order to require a recall or a mandatory recall of the device within
15 working days of issuance of a cease distribution and notification order. A descrip-
tive listing of each new mandatory recall issued will be available to the public in the
weekly FDA Enforcement Report by the agency.
If cease distribution and notification order or a mandatory recall order is issued,
then the person mentioned in the order should submit a periodic report (as specified
in the order) to the FDA on his progress in complying with the order. On compliance
with order, the person mentioned in the cease distribution and notification order
may submit a written request to the FDA for termination of the order. After assess-
ing the person’s progress in complying with the order, FDA may deny or grant the
termination of device recall order within 30 working days of its receipt.
2.9 Part 812: Investigational Device Exemptions [16]
Discovery and development of useful devices intended for human use is encour-
aged, and optimum freedom is given for scientific investigators for this purpose. In
conduct of clinical investigations of devices, approved investigational device
exemption (IDE) permit is given to such devices which otherwise would be sub-
jected to comply all the performance standard or premarket approval to be shipped
lawfully. An IDE approved under or considered approved exempts a device from the
requirements of the following sections of the Federal Food, Drug, and Cosmetic Act
and the regulations issued from the agency.
Applicability
• General: In this part, all the clinical investigations of devices which determine
safety and effectiveness will be proved except the exempted investigations.
• Abbreviated requirements: The following are categories of investigations to get
approval of applications for IDEs:
(i) An investigation of a device including labelling, IRB approval, a brief expla-
nation of why the device is not a significant risk device, documents proving
the collection of informed consent unless documentation is waived by an
IRB, and maintenance of records
• Exempted investigations: This part does not apply to investigations of the follow-
ing devices:
(a) A device, other than a transitional device, in commercial distribution imme-
diately before May 28, 1976, when used or investigated in accordance with
the indications in labeling in effect at that time
(b) A device, other than a transitional device, introduced into commercial distri-
bution on or after May 28, 1976, the FDA has determined to be substantially
equivalent to a device in commercial distribution immediately before May
28, 1976
(c) A diagnostic device, if the sponsor complies with applicable requirements
and if the testing is noninvasive, which does not require an invasive sampling
procedure that presents significant risk, does not by design or intention intro-
duce energy into a subject, and is not used as a diagnostic procedure without
confirmation of the diagnosis by another, medically established diagnostic
product or procedure
(d) A device undergoing consumer preference testing, testing of a modification,
or testing of a combination of two or more devices in commercial distribu-
tion, if the testing is not the purpose of determining safety or effectiveness
and does not put subjects at risk
(e) A device intended solely for veterinary use
(f) A device shipped solely for research on or with laboratory animals and
labeled in accordance animal research caution labelling format
(g) A custom device as per Federal Food, Drug, and Cosmetic Act unless the
device is being used to determine safety or effectiveness for commercial
distribution
Labeling of Investigational Devices
The contents shall bear label with information including name, place of business of
manufacturer, packer or distributor, and quantity of contents, with CAUTION notice
with following statement if appropriate “CAUTION-Investigational device. Limited
by Federal (or United States) law to investigational use.” Other labels shall also be
displayed for describing relevant contraindications, hazards, adverse effects, inter-
fering substances or devices, warnings, and precautions. Labeling of an investiga-
tional device shall not bear any statement that is false or misleading in any particular
and shall not represent that any device is safe or effective for the purpose for which
it is being investigated. Any device shipped solely for research on or with laboratory
animals shall bear on its appropriate detailed label.
Prohibition of Promotion and Other Practices
A sponsor, investigator, or any person shall not promote or test market an investiga-
tional device, until after FDA has approved the device for commercial distribution.
They shall not commercialize by charging the subjects or investigators for a device
a price larger than that necessary to recover costs of manufacture, research, develop-
ment, and handling. They shall not unduly prolong an investigation or represent it
as safe or effective for the purposes for which it is being investigated.
Waivers
A sponsor shall request the FDA to waive any requirement, and this request with
supporting documentation may be submitted separately or as a part of an applica-
tion. FDA may grant a waiver of any requirement if it is not required by act or is
unnecessary to protect the rights, safety, or welfare of human subjects. Any require-
ment shall continue to apply unless and until FDA waives it.
Import and Export Requirements

A person who imports or offers for importation an investigational device shall be the
agent of the foreign exporter with respect to investigations of the device and shall
act as the sponsor of the clinical investigation or ensure that another person acts as
the agent of the foreign exporter and the sponsor of the investigation. A person
exporting an investigational device shall obtain FDA’s prior approval before
proceeding.
Address for IDE Correspondence
All applications, reports, request for waiver, request for import or export approval,
or any other correspondence must be sent to the appropriate address mentioned in
the official website with a submission title mentioned on the outside wrapper.
Application and Administrative Action
1. Submission: A sponsor shall submit an application to the FDA if the sponsor
intends to use a significant risk device in an investigation or to conduct an inves-
tigation that involves an exception from informed consent or if FDA notifies that
an application is required for an investigation. FDA needs to approve an applica-
tion from the sponsor to conduct an investigation after which sponsor shall sub-
mit a signed “Application for an investigational Device Exemption” (IDE
application), with accompanying materials in electronic format. FDA shall pro-
vide a written determination 30 days after FDA receives the IDE or earlier.
2. The investigational plan shall include purpose, protocol, risk analysis, descrip-
tion of device, monitoring procedures, labeling, consent materials, IRB informa-
tion, and other additional records and reports.
3. The report of prior investigations will include general reports of all prior clinical,
animal, and laboratory testing along with specific contents including bibliogra-
phy of all publications, published or unpublished adverse information, nonclini-
cal laboratory studies, and data from clinical investigations.
4. Acceptance of data from clinical investigations conducted outside the United
States will need additional conditions to be met based on good clinical practice
(GCP) which includes review, independent ethics committee (IEC), and support-
ing information.
5. FDA action on applications: FDA will notify the sponsor in writing of the date it
receives an application. FDA shall provide a written determination 30 days after
FDA receives the IDE or earlier. DA takes 30 days’ time to approve an investiga-
tion as proposed, approve with modifications, or disapprove it or withdraw
approval an application. FDA shall consider the use of an investigational device
under category “treatment IDE” to facilitate the availability of promising new
devices to desperately ill patients as early as possible. FDA will not disclose the
existence of IDE unless its existence has been previously been publicly disclosed
or acknowledged until approval of device. FDA will make a detailed summary of
information concerning the safety and effectiveness of the device after approval
upon request.
6. Supplemental applications: (a) Changes in investigational plan shall include
changes requiring prior approval, changes effected for emergency use, changes
effected with notice to FDA within 5 days (developmental changes, changes to

clinical protocol, definition of credible information, notice of IDE change),
changes submitted in annual report, or IRB approval for new facilities.
7. Treatment use of an investigational device: FDA shall consider the use of an
investigational device under a treatment IDE if the device is intended to treat or
diagnose a serious or immediately life-threatening disease; no comparable or
satisfactory alternative device or other therapy is available to treat or diagnose
the stage of the disease.
8. Confidentiality of data and information will be maintained unless its existence
has previously been publicly disclosed or acknowledged.
Responsibilities of Sponsors
Sponsors shall not begin investigation until both IRB and FDA have approved the
application. The responsibilities of sponsors are the following:
(a) Selecting investigators and monitors
(b) Informing investigators
(c) Monitoring investigations
IRB Review and Approval
An IRB shall review and have authority to approve, require revisions on, or disap-
prove all investigations, and if there is no IRB or FDA finds IRB review is inade-
quate, a sponsor shall submit an application to FDA directly. IRB can demand an
investigation for devices involving a significant risk through the sponsor prior to
approval.
Responsibilities of Investigators
An investigator is responsible for ensuring a proper conduct of investigation as per
the signed agreement. The conduct shall be according to investigational plan and
FDA regulations, after obtaining informed consent, and they also will be liable for
protecting the rights, safety, and welfare of subjects and for control of devices under
investigation. The specific responsibilities of investigators include the following:
(a) Awaiting approval
(b) Compliance
(c) Supervising device use
(d) Financial disclosure
(e) Disposing of device
A clinical investigator can be disqualified if FDA has information that an inves-
tigator has deliberately failed to comply with the requirements or repeatedly sub-
mitted false information in any required report. In such cases, the Centre of Devices
and Radiological Health, the Centre for Biologics Evaluation and Research, or the
Centre for Drug Evaluation and Research will furnish a written notice on matter of
complaint and offer to provide the investigator’s explanation in writing or through
an informal conference. If the explanation provided is accepted, disqualification
proceeding will be discontinued, otherwise will be examined with test articles to

support his explanation.
Records and Reports (a) Records
• Investigator records: A participating investigator shall maintain all the corre-
spondence with another investigator, an IRB, the sponsor, a monitor, or the
FDA. They preserve the records of receipt, the use of device including the type
and quantity of device, batch number or codes, and the name of all persons who
received or used the device and details of units. He/she shall also hold records of
each participant’s case history, date and time of each use, exposure details, signed
and dated consent forms, medical records, hospital charts, and nurses’ notes.
• Sponsor records: A sponsor shall maintain all correspondence with another spon-
sor, a monitor, an investigator, an IRB, or the FDA. They record the shipment and
disposition including the name and address of the consignee; type and quantity
of device; date of shipment; batch number or code mark; details if any devices
were returned to the sponsor, repaired, or disposed; and signed investigator
agreements. They shall preserve records of name and intended use of device,
objectives of the investigation, explanation of non-risky aspects of the device,
statements of good manufacturing practice regulations, and notes of adverse
device effects.
• Retention period: All the records of investigator or sponsor shall be maintained
for a period of 2 years after the date on which the investigation is terminated or
completed or the date that records are no longer required for purpose of support-
ing a premarket approval application.
(b) Inspections
A sponsor or an investigator shall permit authorized FDA employees, at fixed
time and manner, to inspect the establishment where the devices/records are held
(including sites where these are manufactured, packed, installed, used, or implanted).
They shall permit FDA employees to inspect and copy all records related to this
investigation, subjects, and the informed consents.
(c) Reports
• Investigator reports: An investigator shall prepare and submit complete,
accurate, and timely reports including report of any unanticipated adverse
effects, withdrawal of IRB approval, progress reports, deviations from the
investigational plan, informed consents, and the final report.
• Sponsor reports: A sponsor shall prepare and submit complete, accurate, and
timely reports including unanticipated adverse device effects, withdrawal of
IRB approval, withdrawal of FDA approval, current investigator list, prog-
ress reports, recall and device disposition, final report, informed consent, and
significant risk device determinations.
2.10 Part 814: Premarket Approval of Medical Devices [17]
The premarket approval (PMA) of medical devices applies to any class III medical
device that was not on the market before May 28, 1976. The review process of pre-
market approval of medical devices facilitates the approval for those devices that
have been shown to be safe and effective and that meets statutory criteria and
approval and disapprove otherwise.
Confidentiality of Data and Information in a Premarket Approval Application
(PMA) File
A PMA file includes all data and information submitted with or incorporated by
reference in the PMA, any IDE incorporated into the PMA, or any PMA supplement
related to submission. The PMA file may not be disclosed by the FDA before an
approval order unless it previously has been publicly disclosed or acknowledged.
After PMA decision, the following information are immediately available for public
disclosure including safety and effectiveness data and protocol for a test or study
unless the protocol is shown to constitute trade secret or confidential commercial or
financial information, adverse reaction report, product experience report, consumer
complaints, and all the correspondence and written summaries of oral discussions
relating to PMA file. The FDA shall abandon PMA if the applicant fails to respond
to a request for additional information within 180 days after the date FDA issues the
request, or if all legal appeals after the denial of PMA have been exhausted, if PMA
has been voluntarily withdrawn, if the device has been reclassified, or if the device
is found to be equivalent to class I or class II device.
(a) Research conducted outside the United States: A PMA based solely on foreign
clinical data may be approved if the data are applicable to US population and
US medical practice and if the studies have been performed by clinical investi-
gators of recognized competence. Applicants shall meet the FDA officials in a
“presubmission” meeting when approval based solely on foreign data is sought.
(b) Service of orders: The orders issued will be served in person by a designated
officer or employee of FDA on, or by registered mail to, the applicant or the
designated agent at the applicant’s or designated agent’s last known address in
FDA’s records.
(c) Product development protocol (PDP): A class III device for which a product
development protocol has been declared completed by FDA under this chapter
will be considered to have an approved PMA.
A. Premarket Approval Application (PMA)
A. Application
The PMA shall be signed by the applicant residing within the United States or
shall be countersigned by an authorized representative residing or maintaining a
place of business in the United States. The PMA application shall include the name
and address of the applicant, separate sections on nonclinical laboratory studies and
on clinical investigations involving human subjects. The trade secret or confidential
commercial or financial information is provided but identified to be a confidential

information.
(a) Summary: Details of summary shall include indications of use of the device to
diagnose, treat, prevent, cure, or mitigate including a description of target
patient population. The device is described in detail, functionally, physically,
along with the manufacturing process and performance characteristics of the
device. The generic name and the proprietary name or trade name of the device
shall also be included. It should also describe the alternative practices or proce-
dures for diagnosing, treating, preventing, curing, or mitigating the disease or
condition. Summary of studies shall include description of objective of the
study; description of experimental design of study; brief description of data col-
lection; analysis results whether positive, negative, or inconclusive; nonclinical
laboratory studies; clinical investigations involving human subjects submitted
in the application along with the conclusion; and valid scientific evidence drawn
from the study.
(b) Description of device shall include pictorial representations; functional compo-
nents or ingredients of the device; properties of the device relevant to the diag-
nosis, treatment, prevention, cure, or mitigation of a disease or condition;
principles behind operation of the device; and methods used for manufacture,
processing, packing, storage, installation, and quality control.
(c) FDA shall determine whether to approve or deny approval of the application
based on nonclinical and clinical laboratory studies. The results of nonclinical
laboratory studies include microbiological, toxicological, immunological, bio-
compatibility, stress, wear, shelf life, and other laboratory or animal tests as
appropriate. The results of clinical investigations involve human subjects with
clinical protocols, number of investigators, subjects per investigator, subject
inclusion and exclusion criteria, study population, study period, safety and
effectiveness data, adverse reactions and complications, patient discontinua-
tion, complaints, device failures, replacements, tabulations of data from all
individual subject report forms including of those who died during clinical
investigation or who did not complete the investigation, results of statistical
analyses of the clinical investigations, device failures and replacements, and
contraindications and precautions for use of the device.
B. PMA Amendments and Resubmitted PMAs
An applicant may amend a pending PMA or supplement to revise the existing
information or to provide additional supporting information. FDA also may request
the applicant to amend a PMA to provide necessary information to complete the
review. Such PMA amendment shall include the original submission details along
with reason for submitting the amendment, and FDA may extend the time required
for its review up to 180 days, and if not received, it shall consider pending PMA or
PMA supplement to be withdrawn voluntarily by the applicant.
C. PMA Supplements
PMA supplement shall be submitted after FDA’s approval of a PMA for making
a change affecting the safety or effectiveness of the device. A supplement is required
if there are new indications for use of the device; labeling changes; use of a different
facility or establishment to manufacture, process, or package the device; and
changes in sterilization procedures packaging, performance, specifications, circuits,
components, ingredients, principle of operation, or layout. FDA will identify the
information that needs to be included in the report or the supplement, and if change
is required, it shall be made 30 days after FDA files the PMA supplement unless
FDA requires the PMA holder to provide additional information or disapproves a
supplement.
B. FDA Action on a PMA
(a) Time frames for reviewing a PMA
FDA will review the PMA within 180 days after receipt of an application and
send an approval order, an approvable letter, a not approvable letter, or a denying
approval. An applicant has the opportunity to amend or withdraw the application
after receiving approvable letter and the not approvable letter.
(b) Filing a PMA
Within a time period of 45 days, FDA will notify the applicant, in writing,
whether the PMA has been filed. The notice will include the PMA reference number
and date filed. From the date of filing, the 180-day time period for review of a PMA
starts. The filing of an application itself denotes a threshold determination about the
completion of PMA to permit a substantive review. If FDA refuses to file, it will
notify with reasons for refusal after which the applicant can resubmit the PMA with
the necessary additional information. Upon request after resubmission, FDA shall
hold an informal conference within 10 working days and will produce its decision
of filing within 5 working days. If FDA does not reverse its decision, the applicant
may request reconsideration to the directors of appropriate agency as applicable,
and it shall be considered as a final administrative action. The refusal of a PMA is
considered if the application is incomplete, has missing information or omission of
any item, contains false statement of material fact, or is not accompanied by a state-
ment of certification or disclosure.
(c) Procedures for Review of a PMA
FDA refers the PMA to each member of its own panel for review and communi-
cates mediating the applicant and the panel to respond to additional information or
questions raised during the review. The advisory committee shall hold a public
meeting or a telephone conference and submit a report to FDA which will have
recommendations and the basis for the same signed by the chairperson of the com-
mittee. This happens within the later of 180 days from the date of filing of the
PMA. FDA will issue the approval of a PMA if there are no reasons for denying it
and give the public notice of the order, including notice for any interested concerns
to request review. FDA’s homepage displays the notice of approval with a brief
summary of information regarding safety and effectiveness of the device, basis of

approval, and adverse effects if any. The applicant shall receive an approvable letter
if they need a specific additional information or conditions to be agreed by the
applicant or a not approvable letter if it describes the deficiencies in application for
one or more reasons. In response to an approvable or not approvable letter, the
applicant may amend the PMA, file a petition in form for reconsideration, or with-
draw the application. FDA will consider a PMA to have been withdrawn voluntarily
if the applicant fails to submit a written request for an amendment needed within
180 days after FDA issues a request or if the applicant fails to respond in writing to
an approvable or not approvable letter within the same time period or a written
notice of withdrawal is submitted by the applicant.
(d) Denial of Approval of a PMA
FDA shall deny an approval if the applicant fails to meet the requirements in the
application including various reasons: false statement of facts or labeling of the
device without complying the requirements. FDA, if denied permission to inspect at
a reasonable time or manner at the facilities, controls, or to access to verify any
records pertinent to the application, shall propose denial of approval. Similar deci-
sion shall be recommended if conditions prescribed were not conducted in compli-
ance with good laboratory practice regulations, or do not support the validity of the
study. FDA shall deny approval for all the clinical investigations involving human
subjects, if not accompanied by the institutional review board or informed consent
regulations, or found in line with rights or safety of human subjects. The public
notice of an order denying approval of the PMA will be placed on FDA’s homepage
with detailed summary of the reasons.
(e) Withdrawal of Approval of a PMA
An approval of a PMA shall be withdrawn if FDA determines that post-approval
requirement has not met the regulations proposed or if the nonclinical/clinical labo-
ratory investigations are found in compliance with the good laboratory practice
regulations or adequately protected for maintaining the rights or safety of human
subjects. FDA will decide to withdraw approval of a PMA after seeking advice of
an advisory committee and after giving a notice of opportunity to the applicant for
an informal hearing if requested. If still found unsatisfactory, FDA shall give the
public notice of an order withdrawing approval of a PMA with appropriate
explanation.
(f) Temporary Suspension of Approval of a PMA
FDA, if suspects the probability that a device would cause serious, adverse health
consequences, or death, shall issue an order temporarily suspending approval of a
PMA. If FDA issues such an order, within 60 days, the agency holds a hearing on
whether a permanently withdraw an approval of PMA.
C. Post-approval Requirements
(a) General
After the PMA approval of a device, it is mandatory to manufacture, pack, store,

label, distribute, or advertise as specified in the PMA application; hence post-
approval requirements are important to follow.
(b) Post-approval Requirements
Post-approval requirements may include many clauses as conditions to approval
of the device like the following: restrictions of sale; distribution of use of device on
particular conditions; continuing evaluation and periodic reporting on safety, effec-
tiveness, and reliability of the device; prominent display in the labeling of a device
and in the advertising of any restricted device of warnings, hazards, or precautions
regarding the device’s safe and effective use, including patient information; inclu-
sion of identification codes on the device or its labeling on cards to be inserted for
patients; providing the identity of any patient be disclosed in records maintained to
verify a record or a report; submission of periodic reports as specified during the
application; batch testing of the device; and providing the records and reports
required to inspect at a reasonable time or manner at the sites of producing/storing/
shipping the device.
(c) Reports
The holder of an approved PMA shall comply with all the requirements as men-
tioned in the order of device approval. The periodic reports shall submit the changes
if available along with summary and bibliography of unpublished reports of data
from any clinical investigations or nonclinical laboratory studies involving the
device or related devices.
D. Humanitarian Use Devices
(a) Purpose and Scope
The discovery of devices intended to benefit patients in treatment or diagnosis of
diseases or conditions that affect or are manifested in not more than 8000 persons in
the United States per year is encouraged under HUD designation of a medical
device. Obtaining marketing approval for a HUD involves obtaining designation of
the device from FDA’s Office of Orphan Products Development and submitting an
HDE application to respective center as applicable.
(b) Designation and HUD Status
(i) Request for designation: The process starts with submitting a request to FDA’s
Office of Orphan Products Development which shall contain name and address
and contact details of the applicant;
a statement of reason for HUD designation for a rare disease or condition or
a valid subset of a disease or condition which shall be identified with specific-
ity; proposed indications for use of the device, reasons why such therapy is
needed; scientific rationale for the use of the device; and documentation with
appended references to demonstrate the disease or condition and its relation to
the people in the United States.
(ii) FDA action: FDA will take one of the following actions on request for HUD
designation in 45 days: Approve the request and notify the applicant or return
the application for further review or disapprove the request.
(iii) Revocation of designation: If the request for designation contained false state-
ments/facts/omitted material information or if the device is not eligible for
HUD designation based on evidences provided, FDA shall revoke a HUD
designation.
(c) Original Applications
The applicant or an authorized representative shall sign the HDE; if he does not
reside in the United States, it shall be countersigned by an authorized representative
in this country. The application shall include a copy of reference to the determina-
tion of qualification of the device as a HUD made by FDA’s Office of Orphan
Products Development, explanation of why the benefit of health in the device usage
outweighs the risk of injury or illness, summary of all clinical experience or inves-
tigations, and labeling requirements. If the price of the device is more than $250, a
report made in accordance with the Statement on Standards for Attestation estab-
lished by the American Institute of Certified Public Accountants is provided.
(d) HDE Amendments and Resubmitted HDEs
An HDE or HDE supplement may be amended or resubmitted by the applicant
itself or provided at the request of the FDA as similar to PMA but without the time-
frames. If a written response is not received within 75 days of date of the request,
the pending HDE or HDE supplement is proposed for voluntary withdrawal by the
applicant.
(e) Supplemental Applications
Once the original application of HDE is approved by the FDA, an applicant must
submit supplements as similar to PMA’s as per HUD requirements.
(f) New Indications for Use
An applicant seeking a new indication for use of a HUD shall obtain a new des-
ignation of HUD status and submit an original HDE as explained earlier.
(g) Filing an HDE
The filing of an HDE means that FDA has found that the application is suffi-
ciently complete to subject it for further review. Within 30 days, FDA shall notify
the applicant about the filing review result.
(h) Timeframes for Reviewing an HDE
Within 75 days after a filing of an HDE, for which there is no major amendment
pending, FDA shall send the applicant an approval order, an approvable letter, a not
approvable letter, or an order denying approval.
(i) Procedures for Review for an HDE
FDA shall begin a substantive review of an HDE after filing by constituting a

panel for reviewing process, and this advisory committee shall recommend and
report within 75 days from the date of filing of an HDE. An approval order is given
if none of the reasons for denying is pointed after review except for minor deficien-
cies in final draft labeling. The notice of approval will be published in the Federal
Register. An approvable letter will be sent if the agency believes that it can approve
if specific additional information is submitted or specific conditions are agreed by
the applicant. A not approvable letter is provided if the application may not be
approved for one or more reasons due to deficiencies in the application and oppor-
tunity is given for submitting an amendment within 75 days.
(j) Denial of Approval or Withdrawal of Approval of an HDE
FDA may deny the approval or withdraw approval of an application, if the appli-
cation fails to meet the requirements of an HDU or any condition of approval
imposed by an IRB or by the FDA. Denial of approval suggests the following:
(i) Lack of showing a reasonable assurance that the device is safe as prescribed,
recommended, or suggested in the labeling
(ii) Lack of reasonable basis to conclude the probable benefit to health which
should outweigh the risk of injury or illness
(iii) Evidence of untrue statement of material fact, or omission of information
(iv) Clinical or nonclinical laboratory studies not conducted in compliance with the
good laboratory practice or informed consent regulations
(k) Temporary Suspension of Approval of an HDE
An HDE or HDE supplement may be temporarily suspended for the same rea-
sons and the same manner.
(l) Confidentiality of Data and Information
The HDE file includes all the data and information submitted with or referenced
in the HDE including amendments, supplement related to submission. Any record
in the HDE file will be available for public disclosure in accordance with the FDA’s
norms. The disclosure by FDA shall subject to the same rule like that of a PMA.
(m) Institutional Review Board Requirements
Once a HUD is approved, the HDE holder is responsible for attending to require-
ments of the Institutional Review Board (IRB). A HUD shall be administered only
if the use of device is approved by an IRB; however, in an emergency situation, to
prevent serious harm or death of a patient, a HUD may be administered without
prior approval by an IRB, where the physician shall provide a written notification
within 5 days after the use to the chairman of the IRB with the explanation with the
details of the patient involved and date of usage and the reason for its use. A HUD
holder shall notify FDA of any withdrawal of approval for use of HUD by reviewing
IRB within 5 working days after being notified of the withdrawal of approval.
(n) Post-approval Requirements and Reports
All the HUD approved devices shall be subjected to post-approval requirements

and reports in a complete, accurate, and timely manner. The periodic reports shall
include an update of information regarding the device, number of devices shipped
or sold since initial marketing approval, number of devices used per patient, or if a
single device is used for multiple patients. This shall include information describing
clinical experience, safety instructions, statement of contraindications, warnings,
precautions, and adverse reactions in the device’s labeling. In addition to it, an HDE
holder shall maintain records of the names and addresses of the facilities to which
the HUD has been shipped, and such records shall be maintained in accordance with
the HDE approval order.
2.11 Part 820: Quality System Regulation [18]
Quality system regulation is in line with current good manufacturing practice

(CGMP), and these govern the methods, facilities, controls used in design, manu-
facture, packaging, labeling, storage, and servicing of any finished device intended
for human use. This system shall ensure that the device will be safe and effective in
compliance with the FDA and Cosmetic Act. This part shall inform the basic
requirements applicable to manufacturers of the finished device manufactured,
imported, and offered in the United States, and this system also is applied to the
manufacturer from a foreign country. Anyone who wishes to apply for an exemption
or variance from any device quality system requirement has to request to the FDA,
and the agency may initiate and grant the variance in the best interest of the pub-
lic health.
For any device, its manufacturers shall develop and maintain a unique quality
system that is specific for the device and ensure that it meets the requirement as per
the quality system regulations as follows:
(a) Management responsibility: The management with executive responsibility is
responsible for the development of its policy with “quality” as the main compo-
nent. The same management shall ensure that the quality policy is made avail-
able, implemented, and maintained at all levels. The manufacturer shall be
responsible for all the personnel who manage, perform, and assess work quality
through proper training, and they will provide adequate resources for quality
performance including internal quality audits. These shall be managed by a
representative who shall be appointed from the members of the management to
ensure the requirements of the quality system regulations. He/she will head the
review of suitability and effectiveness of the system at defined intervals and
with sufficient frequency, and these dates and results are to be documented. A
quality planning and framework of quality system procedures form the initial
outline of this part.
(b) Quality audit: The manufacturer of the device shall start the process by devel-
oping procedures for the quality audits whereby it is assured that the system is
in compliance with the quality system requirements. These audits shall be con-
ducted by individuals who are not in direct responsibility for the matters being
audited. A report of the audits and the re-audits (if conducted) shall be made
and reviewed by the management.
(c) Personnel: The manufacturer shall ensure the availability of adequate personnel
with qualified education, background, training, and experience to assure the
activity of quality system regulations. The training of all the personnel shall be
conducted to make them aware of all the device defects or errors that may be
encountered during the improper performance.
(d) Design controls: Each manufacturer shall establish and maintain procedures to
control the design of the device of any class (class I–III). The design and devel-
opment is planned with different groups which shall be reviewed, updated, and
approved as it evolves. The basis of the design input is to ensure that it’s appro-
priate for the intended use and needs of the user or the patient. These input
requirements shall be documented and reviewed and approved by appointed
designated individuals, which shall be documented with date and signature.
Based on this input requirements of the device designed, device output proce-
dures shall contain and make reference to acceptance criteria which are essen-
tial for the proper functioning of the device of interest, and again this device
output shall be documented, reviewed, and approved before release. These
designs produced are reviewed by an individual who is not in direct responsibil-
ity for the design state, and the results shall be documented in the design history
file (DHF). Each manufacturer shall also develop and maintain procedures for
validation of the device design. This validation shall include software validation
and risk analysis (if appropriate) and is documented in the DHF file with date
and method. Hence each manufacturer shall establish and maintain a DHF for
each type of device, and each DHF shall contain all the records necessary to
demonstrate that the design was developed in accordance with the approved
design plan.
(e) Document controls: Each manufacturer shall develop and maintain procedures
to control all the documents established to meet the requirements of the quality
system regulations. The approvals including the date and signature shall be
documented, and all the changes in the documents shall be reviewed and
approved by the individuals in the organization in a timely manner. The change
records shall include the description of change, identification of affected docu-
ments, signature of the individual, the approval date, and the effect date.
(f) Purchasing controls: Each manufacturer shall establish and maintain proce-
dures to ensure that all the purchased or received the products are in line with
specific requirements. This involves evaluation and documentation of potential
suppliers, contractors, or consultants. The producing documents shall include
an agreement that the suppliers and contractors agree to notify the manufacturer
in case of any change in the product or service that may affect the quality of the
finished the device.
(g) Identification and traceability: Each manufacturer shall establish and maintain
the procedures for identification and traceability of each product during each
stage including the receipt, production, distribution, and installation. This is

important for the devices used to support or sustain life like surgical implants.
These procedures shall facilitate corrective actions.
A. Production and Process Controls
This part includes the documented instructions or standard operating procedures
(SOPs) and methods to define and control the production system, the monitoring
and control process parameters, and the approval of these parameters. Any change
from the specification shall be verified and approved and validated, and these will
be documented in accordance with the quality system regulations. For some of the
devices, the production will be affected by the different environment conditions,
and hence the environmental control systems shall be in place, and it is periodically
inspected and documented. Each personnel involved in the manufacturing shall
maintain the requirements of health, cleanliness, and personal protective practices
which can affect the product quality adversely. Adequate training of these personnel
is given through our trained professional before involving them into the process.
Steps to prevent any contamination of the equipment should be available in the
buildings of production and storage. The buildings and equipment used in the manu-
facturing process shall meet the design to facilitate the specific requirements, and a
maintenance schedule should be available; the details of inspection and adjustments
made during inspections shall be documented. The source material used for the
manufacturing should be of good quality, and the details of it shall be documented
in DHF. Even though automated data processing system is used for production, the
manufacturer shall validate the software before approval and shall be documented.
(a) Inspection, measuring, and test equipment: Each equipment used in the process
shall be tested by mechanical, automated, or electronic inspection methods, and
it is routinely calibrated, inspected, checked, maintained, and documented. The
calibration procedures of each equipment shall check the accuracy and preci-
sion in accordance with national or international calibration standards. The
equipment identification, calibration dates, and the next calibration date shall
be documented on the equipment.
(b) Process validation: Each manufacturer shall ensure that the validation pro-
cesses is performed by qualified individuals. The monitoring and controlling
methods and the date performed shall be documented. If changes or deviations
are observed, the revalidation can be conducted if appropriate.
B. Acceptance Activities
(a) Receiving, In-process, and Finished device acceptance: Each incoming product
shall be inspected and tested before acceptance or rejection. Documentation of
finished device acceptance ensures each production run and batch or number of
devices as per the design criteria. Hence, finished devices shall be held until all
the data, documentation, and authorization are completed. The records shall
include the acceptance activity, dates, results, and signatures in the DHR.
(b) Acceptance Status: The acceptance identification shall be maintained through-
out manufacturing, packaging, labeling, and installation of each product
produced.
C. Nonconforming Product: If a product doesn’t conform to the specified require-
ments, details procedures to address the identification, documentation, evalua-
tion, segregation, and disposal shall be followed and documented. This shall be
followed by rework, retesting, and reevaluation of the products as per current
approved specifications.
D. Corrective and Preventive Action: Appropriate corrective and preventive actions
shall be in place for analysis of the process, work operations, concessions, qual-
ity audit reports, complaints, and returned product, and all other quality prob-
lems and appropriate statistics shall be employed to detect the recurring quality
problems. The corrective and preventive actions are validated to ensure that the
action is effective and does not affect the finished device in any manner. These
relevant information on identified quality problems are submitted for the review
of the management.
E. Labeling and Packaging Control
(a) Device labeling: Labels of the device shall be printed and displayed legibly and
with appropriate details about processing, storage, handling, and distribution.
Labels are released after inspection for the accurate details, including the unique
device identifier (UDI) or universal product code (UPC), expiry details, control
number, storage instructions, and other processing instructions. Labels are
designed for proper identification and to prevent mix-ups.
(b) Device packaging: The material used for packaging the device and the shipping
containers are designed and developed for protection of the device of interest
from any alteration or damage from the time of production till distribution.
F. Handling, Storage, Distribution, and Installation
The handling of device is critical, and issues like mix-ups, damage, deterioration,
and contamination can occur during handling and should be managed appropriately.
Any product or device deteriorates over a fixed time duration, and hence it shall be
stored to facilitate the safe and proper condition before distribution. The stock
sheets with details of storage areas and stock rooms are maintained with the manu-
facturer. Before the distribution, the purchase orders are approved and checked to
ensure the errors are resolved if any before the devices are released for distribution,
and those devices which have deteriorated beyond acceptable fitness are not distrib-
uted. The distribution details include the location planned, name and address of
initial consignee, quantity of devices shipped, date, and numbers of contact for the
distribution. Once distributed, the manufacturer shall establish and maintain instal-
lation and appropriate test procedures and demonstrate the device to the end user or
the patient.
G. Records
(a) General requirements: All records are maintained by the manufacturer and pro-
vided accessible to the responsible officials or FDA for in-depth inspections.
Therefore, the records are maintained legibly and stored from any damage and
also backed up in automated data processing systems. These records are main-
tained in confidential and are disclosed only when specified by the producers
and the agency.
(b) Device master record: The device master records (DMRs) shall be available
with the manufacturer which shall contain device specifications including
drawings, composition, formulation, and component and software specifica-
tions; production specifications including methods, procedures, and environ-
ment specifications; quality assurance procedures like acceptance criteria and
equipment used for audits; and packaging and labelling specifications and
installation and servicing methods.
(c) Device history record: The device history records (DHRs) shall contain the
batch, lot, or unit, dates of manufacture, and quantity manufactured and distrib-
uted. It shall also contain the primary identification label, unique device identi-
fier (UDI), or universal product code (UPC) specific for the device.
(d) Quality system record: The quality system record (QSR) shall include location
of documents and procedures following for assuring the quality of the device
which shall be in accordance with the quality system regulations.
(e) Complaint files: Complaint files shall contain all documents pertaining to
receipt, review, and evaluation of the complaints. The procedures shall ensure
that all the complaints shall be processed in a uniform and timely manner and
documented upon receipts including oral complaints if any. In case of unat-
tended complaints, the reason for the same and details of the individual respon-
sible for decision shall be noted. Once a complaint is registered, the date of
complaint, unique device identifier (UDI), or universal product code (UPC)
shall be recorded, including the nature and details of complaint, date of results
of the investigation, any corrective action taken, and any reply to the
complainant.
H. Servicing: In case the device supplied needs servicing, the manufacturer shall
establish and maintain the instructions and procedures for performing and veri-
fying it as per specified requirements. All the service reports shall be analyzed
and documented with the name of device, UDI, or UPC, control numbers, date
of service, service personnel details, and method of testing used.
I. Statistical techniques: The manufacturer shall develop procedures for identify-
ing valid statistical techniques required for establishing, controlling, and vali-
dating the processes and device characteristics. Sampling plan can be made
based on a valid statistical understanding, and these shall be documented.
2.12 Part 821: Medical Device Tracking Requirements [19]
A. General Provisions
(a) Scope: As per the Federal Food, Drug, and Cosmetic Act of the FDA, the manu-
facturer shall adopt a method of tracking a class II or III device, if failure of the
device would be reasonably likely to have serious adverse health consequences,
or intended to be implanted in the human body for more than a year, or if the
device is a life-sustaining one, it is referred to as a “tracking device.” In case of
a tracking device, it can be traced from the manufacturing facility through the
distributor networks including distributors, retailers, rental firms, and other
commercial enterprises and device user facilities. The tracking system is the
responsibility of the manufacturer, and any person who permanently closes the
business of the device shall notify the FDA and provide the complete set of its
tracking records and information. In that case, the other person who acquires
the right to manufacture or distribute the tracking devices will be responsible
for continuing the tracking responsibility.
(b) Exemptions and variances: A manufacturer or a distributor shall request exemp-
tion or variance from medical device tracking responsibility by providing a
petition containing the name of device, class type, reasons and justification
explaining why tracking is unnecessary, and alternate steps if available. This
petition shall be approved by the Director, Office of Compliance, CDRH, before
deemed effective.
(c) Imported devices: In case of a device manufactured in a foreign country, the
importer of the tracked device in the United States shall be considered as the
manufacturer and shall comply to all requirements as applicable.
B. Tracking Requirements
(a) Devices subject to tracking: A manufacturer of any class II or III device must
track that device in accordance with FDA requirements if the agency notifies
the need for tracking during the premarket notification submissions and pre-
market approval applications.
(b) Devices tracking system and content requirements: The manufacturer shall
adopt a method of tracking as per each type of device. Upon FDA’s request, the
UDI, lot number, batch number, model number of the device, date of shipment,
contact details of the patient, location of the device, and name and details of the
treating physician who recommended the device are provided within 10 days of
request. A standard operating procedure of device tracking shall be established
and shared to the FDA upon request. This SOP shall include the data collection
and recording procedures, methods for recording all modifications, or changes
to the tracking system if any. A quality assurance program which includes audit
procedures with statistical relevant sampling to ensure the accuracy of data and
functioning of tracking system shall be established.
C. Additional Requirements and Responsibilities
(a) Tracking obligations for persons other than device manufacturers: Apart from
the manufacturers of the device, upon purchasing or acquiring any interest of
the same, the distributor(s) are obliged to provide the following details: name
and address of the distributor (final/multiple distributors), UDI, lot number,
batch number, model number or serial number of the device, date of receipt, end
user, and return date or permanent disposal date (if appropriate). The
distributor(s) shall maintain all records to be made available for the manufac-
turer during audits.
D. Records and Inspections
(a) Availability: Manufacturers or distributor(s) shall make a document of each
information collected and maintained from all the records and related events
and persons identified. This shall be provided to the FDA personnel upon
issuance.
(b) Confidentiality: Any patient receiving a device shall be subjected to tracking
requirements but however may refuse to release or refuse permission to release
the patient’s name, address, telephone number, social security number, or other
information for the tracking purpose. FDA shall protect the records and other
information submitted and shall not be available for public disclosure. However,
patient names and other identifiers shall be disclosed to the manufacturer or to
treating physician to pursue the health aspects of the patient.
(c) Retention of records: The manufacturer or the distributor shall maintain records
about useful life (time when the product is in use) of the tracked device. These
records shall be retired only when the device is no longer used, explanted, or
returned, or when the patient using it is no more existing.
2.13 Part 822: Postmarket Surveillance [20]
Postmarket surveillance as per section 522 of the Federal Food, Drug, and Cosmetic
Act is required for all class II and III devices which upon failure would result in
serious adverse health consequences or are implanted in the human body for more
than 1 year or used to sustain life of the user. The purpose of postmarket surveil-
lance is to collect useful data which can reveal unforeseen and anticipated adverse
events or any information that protects the public health aspect of the device usage.
A. Notification: The FDA shall send a letter called “postmarket surveillance order”
which notifies the requirement to conduct the postmarket surveillance. Before
issuing this order, FDA requests the manufacturer to submit information about
the device to specify the subject of the surveillance order and reason for the
requirement of the surveillance. Once considered necessary, the FDA shall
notify the postmarket surveillance based on the surveillance question. In case
the manufacturer decides not to conduct the postmarket surveillance, a request
shall be submitted with the Director, Office of Surveillance and Biometrics,
seeking internal review of the order and requesting an informal hearing or

review by the Medical Devices Dispute Resolution Panel of the Medical Devices
Advisory Committee.
B. Postmarket surveillance plan: Once the postmarket surveillance order is
received, the manufacturer shall submit the plan to conduct the same within 30
days to the respective agency in-charge. Upon receiving the plan, the agency
shall send an acknowledgement letter with unique document number assigned
for any further correspondence. The initial details to be included in the submis-
sion are the following: organizational information, name, address, generic/trade
names, address of contact person, premarket application/submission, descrip-
tion of device, product codes, and indications for use. The postmarket surveil-
lance plan shall include the following: the objective addressing the question put
forth in the FDA order, study subject details, clinical parameters/outcomes,
methodology of surveillance, sample size and units of observation, sources of
data, data collection plans and forms, consent document (if applicable),
Institutional Review Board information, patient follow-up plan, procedures for
monitoring conduct and progress of the surveillance, estimate of duration of
surveillance, data analyses, and statistical tests planned. The duration allowed
for postmarket surveillance shall be mentioned in the order usually for a period
of up to 36 months, longer if needed. If the prospective period is not agreeable
between the manufacturer and the FDA, the matter shall be resolved through
Medical Devices Dispute Resolution Panel.
C. FDA review and action: FDA shall review the submission if it’s received com-
plete as per the requirements, and after which a designated person with essential
qualifications and experience shall be assigned to conduct the surveillance. The
review shall be completed within 60 days of receipt, and decision or identifica-
tion of actions needed shall be notified. FDA shall send an approval order/
approvable letter/disapproval letter. If the manufacturer fails to submit a revised
or new plan after the review, the device shall be misbranded, and these devices
can be seized. The personnel involved shall pay civil money penalties or prose-
cuted. If changes required in the plan are suggested, resubmission shall be pro-
ceeded; however, the changes should not affect the nature or validity of the data
collected in the initial device approval order. If the manufacturer disagrees to the
review of the FDA, they shall request a meeting with the authority responsible
for the postmarket surveillance, seeking internal review and informal hearing
through Medical Devices Dispute Resolution Panel. The content of the
postmarket surveillance plan submission shall be maintained confidential until
approved; however, the trade secret and commercial information (if any) shall
be protected.
D. Responsibilities of manufacturers: Once notified about the requirement to con-
duct postmarket surveillance, the manufacturer shall submit the plan within 30
days. The manufacturer shall ensure that the surveillance is initiated and con-
ducted diligently, until the submission of reports, required in a timely manner.
In case of any change in the ownership of the device’s company, it shall be noti-
fied, and the new owner shall be obliged to conduct the surveillance. Similarly,
if manufacturers decide to close the business or stop marketing of the device of

interest, it shall be notified, and plans to complete the postmarket surveillance or
terminate it should be discussed.
E. Waivers and exemptions: The manufacturer shall request to waive any specific
requirement under postmarket surveillance with supporting document with
explanation of why it is believed an exempt is applicable for the device, and this
shall be submitted separately or with the postmarket surveillance submission
document.
Records and Reports The manufacturer shall maintain copies of all correspon-
dence with the investigating team or FDA including reports, signed agreements,
plan, approval order, data collected and analyzed for conducting the postmarket
surveillance plan, or any other records involved during the postmarket surveillance.
Similarly, the investigators shall keep all the correspondence between them, the
FDA, and the manufacturer and the plans approved for conducting the surveillance.
All these records are preserved for a period of 2 years after acceptance of final
report. In case of any change in plan, FDA shall be notified within 10 working days;
otherwise once initiated, the program is regularly inspected by authorized FDA
employees in the facility where the device is held. FDA shall be permitted at a rea-
sonable time and manner to inspect the copy of any records related to this surveil-
lance, or it shall be provided upon request within 72 hours of initiation of the
inspection. The records of the individual subjects shall be inspected if the reports
are found incomplete, inaccurate, false, or misleading. The manufacturer shall sub-
mit interim and final reports as per the postmarket surveillance plan and additional
information if found necessary.
2.14 Part 830: Unique Device Identification [21]
A unique device identifier (UDI) means an identifier that adequately identifies a

device through its distribution and use. An UDI is composed:
(a) Device identifier, a mandatory, fixed portion of UDI that identifies the specific
model or version of the device and the device label
(b) Production identifier, a conditional, variable portion of UDI that might include
the lot or batch of manufacture, serial number of specific device, expiration
date, and specific date of device manufactured
It is required that the UDI must:
(a) Be issued under a system operated by the FDA or an FDA-accredited issu-
ing agency
(b) Conform to the following international standards:
(i) ISO/IEC 15459-2:2006, Information technology-Unique identifiers-Part

2: Registration procedures
(ii) ISO/IEC 15459-4:2008, Information technology-Unique identifiers-Part
4: Individual items
(iii) ISO/IEC 15459-6:2007, Information technology-Unique identifiers-Part
6: Unique identifier for product groupings
(c) Only use characters and numbers from the invariant character set of ISO/IEC
646:1991, Information technology-ISO 7-bit coded character set for informa-
tion interchange
Only one device identifier from any particular system for issuance of UDI shall
be used to identify only one particular version or model of a device. When a change
is made to the device, a new UDI must be assigned to distinguish the new version or
model device from its previous one. In case the model or version of the device is
discontinued, its UDI will not be reassigned to another device. On re-introducing
the discontinued version or model of the device with no change, then the same UDI
can be used. For relabeling a device, a new device identifier can be assigned to the
device, but its relationship with previous device identifier should be kept in record.
Responsibilities of FDA-Accredited Issuing Agency
A private organization is eligible to apply for FDA accreditation, or FDA by itself
can act as an issuing agency. For initial accreditation, the applicant shall notify their
desire to be accredited by sending a notification by email or by correspondence to
the FDA. If approved, the initial term of accreditation for an issuing agency shall be
for 3 years and can be periodically renewed for 7 years. To maintain its accreditation
as an issuing agency, they must operate:
(a) To meet the requirements of UDI to adequately identify a device through its
distribution and use.
(b) Conform to international standards: ISO/IEC 15459-2, ISO/IEC 15459-4, ISO/
IEC 15459-6.
(c) Only use characters and numbers from the invariant character set of ISO/
IEC 646.
(d) With single set of consistent, fair, and reasonable terms and conditions to
all users.
(e) To protect against conflicts of interest between the issuing agency (and its offi-
cers, employees, and other agents) and labelers (and its officers, employees, and
other agents).
(f) Make available information concerning its system for UDI assignments.
(g) List of labelers using their system for UDI assignment should be maintained,
and an electronic copy of the same must be submitted to FDA upon request
anytime or at end of each year.
Suspension or Revocation of FDA Accreditation as an Issuing Agency
Accreditation of an issuing agency can be suspended or revoked by the FDA with a
notice and opportunity for informal hearing, if FDA finds an issuing agency or any
officer, employee, or other agent of the issuing agency:
(a) Is guilty of misinterpretation or failed to disclose potential information during

accreditation
(b) Failed to fulfill the responsibilities as an issuing agency
(c) Failed to protect against conflict of interest
(d) Engaged in any anticompetitive activity to restrain trade
(e) Violating or aided and abetted in violation of any regulation under section
510(e) or 519(f) of the FDA Act
2.15 Part 860: Medical Device Classification Procedures [22]
This part of the regulation sets forth the criteria and procedures in accordance with
Sections 513, 514(b), 515(b), and 520(l) of the FDA Act, used for classification and
determination of class of regulatory control (class I, class II, and class III) appropri-
ate to provide assurance for the safety and effectiveness of the medical devices.
Three categories of regulatory control for medical devices are:
(a) Class I (general controls): This class of device is subjected to only general con-
trol authorized by or under Sections 501 (adulteration), 502 (misbranding), 510
(registration), 516 (banned devices), 518 (notification and other remedies), 519
(records and reports), and 520 (general provisions) of the Act. The general con-
trols are adequate to assure the safety and effectiveness of these class I device.
(b) Class II (special controls): This class of device will be or will eventually be
subjected to special controls. The general controls alone are inadequate for
safety and effectiveness assurance in class II devices; therefore, special controls
including promulgation of performance standards, postmarket surveillance,
patient registries, guidance on premarket notification submission (in accor-
dance with section 510(k) of the FDA Act), and other appropriate recommenda-
tions are required for such assurance.
(c) Class III (premarket approval): This class of device will require premarket
approval in accordance with Section 515 of the FDA Act. A device is in class III
if general controls provide insufficient information for safety and effectiveness
assurance or if a need for special control is required or if the device is life-
supporting or life-sustaining or if the device presents a potential unreasonable
risk of illness or injury.
Determination of Safety and Effectiveness
The Commissioner of the FDA refers the device to the appropriate classification
panel, which is one of the advisory committees established by the Commissioner
under Section 513 of the FDA Act for making recommendations on the classifica-
tion and reclassification of devices. The recommendation will include:
(a) Summary of reasons for the recommendation
(b) Summary of data upon which the recommendation is based
(c) Report on the health risks (if any) presented by the device
Manufacturers may submit evidence to FDA to substantiate the safety and effec-
tiveness of device; however, the FDA relies only on the valid scientific evidence
generated from well-controlled investigations, partially controlled studies, and
objective trials conducted by qualified experts. Based on the scientific evidence
using laboratory animals, clinical studies on human subjects, and analytical studies,
FDA ensures the absence of unreasonable risk of illness or injury associated with
intended uses and usage conditions of the device. A device is considered safe and
effective when its intended use of the device, adequate directions for use, and warn-
ings against unsafe use are proven in a significant portion of target population by
clinically significant results. The classification panel reviews the evidence concern-
ing safety and effectiveness and prepares advice to the commissioner, and the com-
missioner will apply rules for determining safety and effectiveness of a device. The
panel recommendation is regarded preliminary until the Commissioner reviews and
publishes it in the FEDERAL REGISTER, together with the proposed regulation
for device classification for comments. The Commissioner reviews the comments
and issues the final regulation for classifying the device and other devices of that
generic type.
Exemptions from Sections 510, 519, and 520(f) of the FDA Act
In case of recommendation for a medical device to be classified as class I, recom-
mendations on the exemption of one or more requirements of the following sections
of the FDA Act can be made: Section 510 (registration, product listing, and premar-
ket notification), section 519 (records and reports), and section 520(f) (good manu-
facturing practice requirements of the quality system regulation). In the case of a
recommendation for classification of a medical device into class II, whether the
device should be exempted from the premarket notification requirement under sec-
tion 510, will be decided in accordance with §860.15. For the purposes of classifica-
tion, establishment of special controls for class II devices, and premarket approval
of class III devices, the Commissioner and the classification panels consider the
following factors:
(a) The person for whose use the device is represented or intended
(b) Conditions of use including prescribed or recommended or advertised or sug-
gested in the labelling for the device
(c) Health benefits from device usage outweigh the probable injury or illness as a
result of such use
(d) Reliability of the device
Reclassification
Under Sections 513(e) and (f), 514(b), 515(b), and 520(l) of the FDA Act, an inter-
ested person or manufacturer or importer may submit a petition for reclassification
of a device. Unless provided in writing by the commissioner, any petition for reclas-
sification of the device shall include:
(a) Specification for the type of device requested for reclassification
(b) A statement on action requested, such as “It is requested that….. device(s) be
reclassified from class III to class II”
(c) A statement on the basis of disagreement with the present device classification
(d) A full statement of reasons supported the reclassification and how the proposed
classification assures the safety and effectiveness of the device
(e) Relevant data and new information with source documents relevant to the
petition
Within 180 days after the filing of a petition for reclassification under this sec-
tion, the Commissioner will either deny the petition by order published in the
Federal Register or give notice of the intent to initiate a change in the classification
of the device. The Commissioner may initiate the reclassification of the device, by
either referring a reclassification petition to the panel under §860.134(b) or consult-
ing with panel regarding the petition under §860.130(d) or received in a proceeding
under §860.133(b), or the Commissioner chooses to consult with a panel with
regard to the reclassification of a device initiated by the Commissioner under
§860.134(c) or §860.136. If a device is reclassified under this section, it may revoke
any special control or premarket approval requirement that was previously applied
to the device. In addition, reclassification of specific device will result in reclassifi-
cation of all devices within the same generic type.
2.16 Part 861: Performance Standards Development [23]
The FDA may determine performance standards of class II devices in accordance to

special controls described in Section §860.7(b) to ensure safety and effectiveness of
the device. This part implements Section 514 of the FDA Act for establishment,
amendment, and revocation of performance standards applicable to medical devices.
Contents of Standards
Such performance standards established by FDA will address, but not be limited to:
(a) Device performance characteristics
(b) Design, components, and properties of device and its compatibility with other
components
(c) Manufacturing and quality control procedures applicable to the device
(d) Testing all the devices by the manufacturer or testing by FDA or a third person
to ensure conformity of the device to standard
(e) Publication of the results of test or tests of the device to show their conformity
to standard
(f) Manufacturers’ certification to purchasers or FDA for device conformity to
standards
(g) Restrictions on the sale and distribution of the device, in accordance to Section
520(e) of the FDA Act
(h) Use of proper form and content of the label for installation, maintenance, opera-
tion, warnings, storage, transportation expiration dates, concerning statements
for appropriate patient population, and for safe usage of devices
Performance Standards Development and Publication

The FDA will publish in the FEDERAL REGISTER a notice of a proposed rule-
making for the establishment, amendment, or revocation of any performance stan-
dards for a device. The FDA might either develop or may accept an existing or
proposed standard to be published in their FEDERAL REGISTER. This notice will
set forth the findings that the performance standards are appropriate and necessary
for the safety and effectiveness of the device and/or for the reduced risk of illness or
injury associated with the device. A notice under this section will be available for
comments from interested persons not less than 60 days. If FDA receives a request
for a change within 60 days of the publication of notice, upon consultation with the
appropriate panel, it will either deny the request or give a notice for its intent to initi-
ate a change in the classification.
Amendment or Revocation of a Standard
The FDA will provide for periodic evaluation of performance standards to deter-
mine their ability to reflect the recent advances in medical, scientific, or other tech-
nologies. FDA may amend or revoke by regulation the standard established, on its
own or upon petition of an interested party. Any petition or proceedings to amend or
revoke a performance standard shall be conducted in accordance with the rulemak-
ing procedures of §10.30. This notice of proposed rulemaking to amend or revoke
the standard, in addition, shall also set forth the proposed evidences for reduced
risks or health benefits or illness to be eliminated from the proposed amendment or
revocation.
Standards Advisory Committees
The FDA will establish advisory committees, to which proposed regulations may be
referred for reports and recommendations. The members of the advisory commit-
tees established under this section shall include:
(a) Members selected in accordance with §14.82 and §14.84, except that no mem-
ber may be a full-time FDA employee
(b) Nonvoting member representative of consumer interests
(c) Nonvoting member representative of interests of device manufacturing industry
The FDA will furnish the advisory committee with the data and information
upon which the referred proposed regulation is based. After independently review-
ing the materials provided, advisory committee shall submit a report and statement
of reason/or basis for the recommendation on the proposed regulation, within 60
days of the referral. In the office of the Division of Docket Management, FDA, a
copy of the report and recommendation will be publicly displayed.
2.17 art 862-898: Medical Device Listing and Premarket

P
Approval [7]
These parts of the Chapter I of Title 21 of FDA regulation sets forth the classifica-
tion of medical devices that are in commercial distribution intended for human
therapeutic or diagnostic use. A premarket notification is required to be submitted
by a manufacturer for a device under Part 807, for establishment registration and
device listing. This notification should identify the device for its description and
section title in this part of the regulation. The classification of devices may not show
precise description of every device that is or will be subjected to the regulation. In
such instances, as required by §807.87, a manufacturer shall state why the device is
substantially equivalent to other devices. To avoid duplicative listing, devices with
more than one type of use (i.e., both as therapeutic and as diagnostic use) shall be
listed only in one subpart. A device included in this part of regulation classified into
class III (premarket approval) shall not be commercially distributed after the date
mentioned in the regulation classifying the device, unless the device has been
approved by FDA Act under Section 515.
Exemption from the Requirements of Premarket Approval
The requirement of premarket notification for a generic type of class I or II device
as per Section 510(k) of the Act is exempted only if applicable to device with exist-
ing or reasonably foreseeable characteristics of commercial distribution within the
generic type or, in the case of in vitro diagnostic devices, only if the misdiagnosis as
a result of using the device would not be associated with morbidity or mortality.
FDA has granted exemption for these class I and II devices from the requirement of
premarket notification. However, the manufactures of these commercially distrib-
uted devices must still submit a premarket notification to FDA before introducing
the device into interstate commerce.
Bibliography
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EU 1907/2006 – Registration, Evaluation,
Authorisation and Restriction of Chemicals
1 Introduction
1.1 Regulation EC 1907/2006
Regulation (EC) no 1907/2006 of the European Parliament and the Council of the
European Union, concerning the registration, evaluation, authorization, and restric-
tion of chemicals (REACH), in regard to the treaty establishing the European
Community, particularly Article 95, in regard to the Commission’s proposal, in
regard to the European Economic and Social Committee’s opinion, execution in
accordance with the procedure laid down in Article 251 of the Treaty, European
Commission (EC), comprises of regulations which work to ensure the safety of the
patient and efficacy of the device [1]. This regulation ensures a high level of protec-
tion of human health and environment as well as the free movement of substances,
with the goal of achieving sustainable development. The European Union, in pursu-
ant to the implantation plan adopted on 4 September 2002 at Johannesburg World
Summit, is aiming to achieve sustainable development where chemicals are pro-
duced and used with minimal adverse effects on human health and the environ-
ment [1].
H. Sriram
National Dental Centre Singapore, Singapore, Singapore
238 I. Jagadeeswaran and H. Sriram
1.2 Establishment of Compliance with REACH Regulation
An important objective for establishing REACH is to encourage and ensure that

substances of high concern are eventually replaced by less dangerous substances or
economical technologies where viable alternatives are available. This regulation
does not affect the application of directives on worker protection and the environ-
ment, and employers are required to eliminate or substitute the dangerous sub-
stances, wherever possible to protect the health and safety of their workers. The key
components of REACH are [1, 2]:
–– Registration.
–– Evaluation.
–– Authorization.
–– Restriction.
–– REACH safety datasheet.
This regulation requires manufacturers and importers to generate information on
substances, to assess their risks, and to develop and recommend appropriate risk
management measures. The European Chemical Agency (Agency) requires manu-
factures and importers to submit this information for registration, and only regis-
tered substance is allowed to circulate on internal market. The Agency and member
states shall evaluate whether the registration is in compliance with the requirements
of this regulation. Such information submitted for registration can also be used by
the Agency to initiate authorization or restriction procedures under this regulation.
Authorization provisions ensure good functioning of internal market and assure that
the very high-risk substances are properly controlled. The EC will provide authori-
zation for a substance to be placed in market and usage. Restriction provisions allow
manufacturing, placing on market, and use of substance with subject to total or
partial ban or other restrictions [1, 2].
1.3 Purpose and Scope [1]
The primary strategy of the regulation is to ensure safety of human health and envi-
ronment, including promotion of alternative methods for hazard assessment and
free circulation of substances, as specified in Article 3. This regulation is based on
principle that it is for manufacturers, importers, and downstream users to ensure that
they manufacture, place on market, or use such substances that do not adversely
affect human health or environment.
1. This regulation does not apply to the following:
(a) Radioactive substances and mixtures that are in the scope of Council
Directive 96/29/Euratom of 13 May 1996 which has laid down the primary
safety standards for the protection of workers’ health. It also takes public
EU 1907/2006 – Registration, Evaluation, Authorisation and Restriction of Chemicals 239
health into account ensuring against the danger arising from ionizing
radiation.
(b) Substances, on their own, in a preparation or in an article, which are in sub-
ject to customs supervision which do not undergo any treatment or process-
ing, which are in temporary storage or in a free zone or free warehouse with
a re-exportation or in transit view.
(c) Non-isolated intermediates.
(d) Dangerous substances and dangerous substance in preparations by air, road,
sea, rail, or inland waterways transportation.
(e) Waste as defined in Directive 2006/12/EC of the European Parliament and
Council of 5 April 2006, which is not a substance, mixture or article within
the meaning of Article 3 of this Regulation.
(f) In specific cases where, the substances on their own or in a preparation or in
an article are interest of to defense, the member states may allow for exemp-
tions from this regulation.
2. This regulation shall apply without prejudice to:
(a) Community workplace and environmental legislation, including Council
Directive 89/391/EEC of 12 June 1989 on the introduction of measures to
encourage improvements in the safety and health of workers at work [3];
Council Directive 96/61/EC of 24 September 1996 concerning integrated
pollution prevention and control [4]; Directive 98/24/EC and Directive
2000/60/EC of the European Parliament and of the Council of 23 October
2000 establishing a framework for Community action in the field of water
policy [5]; and Directive 2004/37/EC.
(b) Directive 76/768/EEC testing involving vertebrate animals.
3. The provisions of Title II, V, VI, and VII of this regulation shall not apply to the
extent that a substance is used:
(a) In medicinal products for human or veterinary use within the scope of
Regulation (EC) No 726/2004, Directive 2001/82/EC on the Community
code relating to veterinary medicinal products [6] and Directive 2001/83/EC
on the Community code relating to medicinal products for human use [7].
(b) Food or feeding stuffs as defined in Regulation (EC) No 178/2002 including
when they are used as a food additive (89/107/EEC), flavoring (Directive
88/388/EEC and Decision 1999/217/EC), additive (Regulation (EC) No
1831/2003), or animal nutrition (Directive 82/471/EEC) in foodstuffs or
feeding stuffs within the scope of these Directives.
4. The provisions of VI of this regulation shall not apply to the following prepara-
tions in the finished state intended for final user:
(a) Medicinal products for human or veterinary use, within the scope of
Regulation (EC) No 726/2004 and Directive 2001/82/EC and as defined in
Directive 2001/83/EC.
(b) Cosmetic products as defined in Directive 76/768/EEC.
(c) Medical devices which are invasive or used in direct physical contact with
the human body in so far as Community measures lay down provisions for
the classification and labelling of dangerous substances and preparations
which ensure the same level of information provision and protection as
Directive 1999/45/EC.
(d) Food or feeding stuffs as defined in Regulation (EC) No 178/2002 including
when they are used as a food additive (89/107/EEC) [8], flavoring (Directive
88/388/EEC [9] and Decision 1999/217/EC [10]), additive (Regulation (EC)
No 1831/2003 [11], or animal nutrition (Directive 82/471/EEC) [12] in
foodstuffs or feeding stuffs within the scope of these Directives.
2 Registration of Substances [1]
2.1 eneral Obligation to Register

G
and Information Requirements
The stakeholders (manufacturers or importers) of a substance on its own, in articles

or in preparations, shall submit a registration to the Agency, if they meet any of the
following conditions:
(a) In quantities of 1 ton or more per year.
(b) If the polymer consists of 2% weight by weight (w/w) or 0.1% weight by weight
(w/w) for the substance present in articles.
These substances shall not be manufactured or placed on market unless they have
been registered subject to articles 6, 7, 21, and 23 of this regulation. Registration of
article is exempted if the substance in the article has already been registered for that
use. Submission for registration shall be accompanied by the fee required by Title
IX of this regulation.
2.2 xemption to Register for Product and Process-Oriented

E
Research or Development (PPORD)
This general obligation to register is exempted for a period of 5 years for the sub-
stances manufactured or imported for the purpose of product and process-oriented
research or development (PPORD). However, the manufacturer or importer or pro-
ducer of articles shall notify the agency regarding their identity, identity of sub-
stance, its classification and labelling, estimated quantity, and list of customers.
This notification shall be accompanied by the fee required in accordance with Title
IX. The agency will check the completeness of the information submitted and shall
assign a notification number and date, which shall be the receipt of notification.
They agency might ask for additional information from the notifier or shall impose
some conditions to ensure safe handling of the substance or the preparation or arti-
cle. The agency shall also communicate this information to the concerned member
state(s) authority. The 5-year period shall begin at receipt of notification at the
Agency. The manufacturer or importer or producer of articles shall request for
extension for the substance justifying their exclusive use in research and develop-
ment of medicinal products for human and veterinary programmed. The Agency
shall make decision on extending the exemption period considering the comments
from Member state(s) authorities, for any 5 years or further up to 10 years for the
substance that are not placed on the market.
2.3 I nformation to Be Submitted for General Registration

Purposes (Article 10)
For the purpose of registration required by article 6 or 7(1) or 5, the manufacturer or

importer or producer of articles shall notify the following information to the Agency:
A. A technical dossier including:
(i) The identity and contact details of the manufacturer or importer or pro-
ducer of articles as specified in section 1 of Annex VI.
(ii) Registration number in article 20(1).
(iii) Identity of the substance (section 2 Annex VI) and classification of sub-
stance (section 4 Annex VI).
(iv) Estimated quantity as specified in section 3.1 of Annex VI.
(v) Brief description on the safe use of the substance or substance in the arti-
cle specified in section 5 of Annex VI and use(s) of the article(s).
(vi) Study summaries of the information derived from the application of
Annexes VII and XI.
(vii) Robust study summaries of the information derived from the application
of Annexes VII to XI, if required under Annex I.
(viii) An indication of information which has been reviewed by an assessor
with appropriate experience.
(ix) Proposals for testing where listed in Annexes IX and X.
(x) For substances in quantities of 1 to 10 tons, exposure information as spec-
ified in section 6 of Annex VI.
(xi) A request by the manufacturer or importer with justification, if any infor-
mation shall not be made available on the Internet in accordance with
article 77(2)(e), given his or other party’s commercial interest.
B. A chemical safety report required under Article 14, with relevant use and
exposure categories
When a substance is intended to be manufactured by one or more manufacturers
and/or imported by one or more importers and/or is subject to registration under
Article 7 of this regulation, the following shall apply:
(i) One registrant shall submit the information in Article 10(a)(iv), (vi), (vii), and
(ix) and any relevant indication under Article 10(a)(viii) to the Agency (herein-
after referred to as “the lead registrant”) acting with the agreement of the other
assenting registrant(s).
(ii) Each registrant shall subsequently submit separately the information specified
in Article 10(a)(i), (ii), (iii), and (x) and any relevant indication under Article
10(a)(viii).
(iii) The registrants may decide themselves whether to submit the information
specified in Article 10(a)(v) and (b) and any relevant indication under Article
10(a)(viii) separately or whether one registrant is to submit this information on
behalf of the others.
But the information specified in Article 10(a)(iv), (vi), (vii), and (ix) for the pur-
poses of registration shall be submitted by each registrant within his tonnage band.
The physicochemical, toxicological, and ecotoxicological information that is rele-
vant and available to the registrant shall be specified in Article 10 under points (vi)
and (vii). As soon as the quantity of a substance per manufacturer or importer
reaches the next tonnage threshold, the Agency must immediately be informed with
necessary information as required by this regulation.
A registrant may also submit the information specified in Article 10(a)(iv), (vi),
(vii), and (ix) separately, along with dossier if:
(i) He disagrees with the selection of this information with the lead registrant.
(ii) Filling jointly would be disproportionately costly for him.
(iii) Joint filling would lead to disclosure of commercially sensitive information.
2.4 eneral Requirements for Generating Information

G
on Intrinsic Property of Substances
The intrinsic properties of substances can be produced with other test methods as
per the conditions set out in Annex XI. The information on human toxicity should
be generated through the alternative methods such as in vitro methods or qualitative
or quantitative structure-activity relationship models, whenever possible to avoid
the use of vertebrate animals for testing. The test methods in vertebrate animals
shall be regularly reviewed and improved to reduce the testing and the number of
animals involved. Commission Regulation shall be adopted in accordance with the
procedure referred to in Article 133(4), and the Annexes of this Regulation, so as to
replace, reduce, or refine animal testing. Ecotoxicological and toxicological tests

and analyses shall comply with the principles of good laboratory practice provided
for in Directive 2004/10/EC or other international standards recognized as being
equivalent by the Commission or the Agency and with the provisions of Directive
86/609/EEC, if applicable.
2.5 hemical Safety Report and Recommended Risk

C
Reduction Measures
A chemical safety assessment shall be performed, and a chemical safety report shall
be completed for all substance (in quantities of 10 tons or more per year per regis-
trant) subject to registration, without prejudice to Article 4 of Directive 98/24/EC. A
chemical safety assessment shall be conducted for either each substance on its own
or in a preparation or in an article in accordance with Annex I of this regulation.
A chemical safety assessment shall be exempted if the concentration of sub-
stance is less than the lowest of any of the following:
(i) Concentration defined in Article 3(3) of Directive 1999/45/EC.
(ii) Concentration limits in Annex I to Directive 67/548/EEC.
(iii) Concentration limits in Part B of Annex II and Annex III to Directive
1999/45/EC.
(iv) Concentration limits in the classification and labelling inventory established
under Title XI of this Regulation.
(v) 0,1% weight by weight (w/w), if the criteria in Annex XIII of this
Regulation is met.
A chemical safety assessment of a substance shall include the following steps:
(i) Human health hazard assessment.
(ii) Physicochemical hazard assessment.
(iii) Environmental hazard assessment.
(iv) Persistent, bioaccumulative, and toxic (PBT) and very persistent and very bio-
accumulative (vPvB) assessment.
Based on the results from the chemical assessment steps, the registrant concludes
that the substance meets the criteria for classification as dangerous in accordance
with Directive 67/548/EEC or is assessed to be as a PBT or vPvB. The exposure
scenarios (where appropriate the use and exposure categories), exposure assess-
ment, and risk characterization for all identified uses of the registrant shall also be
addressed and included in the chemical safety assessment. Any registrant shall iden-
tify and apply the appropriate measures to adequately control the risks identified in
the chemical safety assessment and, where suitable, recommend them in the safety
data sheets which he supplies in accordance with Article 31. Any registrant required
to conduct a chemical safety assessment shall keep his chemical safety report
available and up to date. The chemical safety report need not include consideration
of the risks to human health from the end uses (a) in food contact materials within
the scope of Regulation (EC) No 1935/20041 and (b) in cosmetic products within
the scope of Directive 76/768/EEC.
2.6 Data Sharing and Avoidance of Unnecessary Testing
This regulation tries to avoid animal testing and limits the duplication of other tests.
The sharing and joint submission for the purposes of this regulation enables the
registrants to refrain from exchanging concern technical data and their market
behaviors (such as production or sales volume, production capacity, import volume,
or market shares). If a substance has already been registered at least 12 years (in
accordance to Article 26(3)) previously, a new registrant shall be entitled to refer to
the study summaries or robust study summaries under this regulation, provided that
he can show that the substance that he is now registering is the same as the one
previously registered, including the degree of purity and the nature of impurities. In
this case, if the substance has previously been registered for less than 12 years, the
new registrant might request the previous registrant for information specified in
Article 10 under points (vi) and (vii) in order to register. In such situations, the pre-
vious registrant and the potential registrant shall share the costs of data generation
in accordance with Article 77(2)(g) of this regulation. The new registrant shall
access the full study reports, given that the previous registrant(s) have given permis-
sion to refer for the purpose of registration. However, a new registrant shall not refer
to such studies to provide the required information on substance identity (section 2
of Annex VI).
2.7 Registration Process
• On submission of notification for registration of a substance on its own or in a

preparation or in an article to the Agency, the Agency shall assign a submission
number and submission date (date of receipt) to each registration.
• The Agency shall check the completeness of each registration in order to ascer-
tain that all elements required under this regulation and the appropriate registra-
tion fee referred in this regulation have been provided. But this completeness
check does not include assessment of quality or adequacy of any data or justifica-
tions submitted.
• The Agency shall undertake the completeness check within 3 weeks or within
3 months (for in-phase substances in accordance with Article 23).
• If the registration is incomplete, the Agency shall inform the registrant, regarding
further information required to be submitted for the registration to be complete
within the stipulated time window.
• The registrant shall complete his registration and submit it to the Agency within
the deadline. Failure to complete the registration within the deadline set shall
pose rejection of the registration. The registration fee shall not be reimbursed in
such instances.
• On the registrant completing his registration, the Agency shall perform further
completeness check along the information provided. On completion of registra-
tion, the Agency without delay shall communicate the registration number and
date to the registrant, which shall be used for all subsequent correspondence.
• The registrant may start the manufacture or import of a substance or production
or import of an article if there is no indication to the contrary from the Agency
within 3 weeks after receipt by the Agency, without prejudice to Article 27(8).
• The Agency shall also notify the competent authority of relevant Member State(s)
within 30 days of the submission date, regarding the registration relevant infor-
mation available in the Agency database.
• Following registration, it is the responsibility of the registrant to update his reg-
istration without undue delay with the relevant new information regarding the
substance along the relevant part fee in accordance with this regulation. The
Agency shall intimate relevant competent Member state authority regarding the
update available in the database.
3 Evaluation [1]
3.1 Dossier Evaluation
The agency shall examine testing proposal submitted in a registration or a down-

stream user report for substance-relevant information specified in Annexes IX and
X. Substances which have or may have PBT, vPvB, sensitizing and/or carcinogenic,
mutagenic, or toxic for reproduction (CMR) properties or substances classified as
dangerous according to Directive 67/548/EEC above 100 tons per year with uses
resulting in widespread and diffuse exposure shall be given priority for evaluation.
The name of the substance, hazard end-point of the proposed vertebrate testing
(testing proposal), and the set deadline (usually 45 days) for third party to submit
scientifically valid information shall be published by the Agency on its website.
Such scientifically valid information and studies that address relevant substance and
hazard end-point, submitted by the third party, shall be considered by the Agency in
preparing its decision in accordance to this regulation. In accordance to the proce-
dures laid down in Articles 50 and 51, the Agency shall draft one of the following
decisions:
(a) A decision requiring the concerned registrant(s) or downstream user(s) to per-
form the proposed test and submit the study summary (or the robust study sum-
mary if required by Annex I) within a set deadline.
(b) A decision in accordance with point (a), but modifying the conditions under
which the test is to be carried out.
(c) A decision in accordance with points (a), (b), or (d) but requiring registrant(s)
or downstream user(s) to carry out one or more additional tests in cases of non-
compliance of the testing proposal with Annexes IX, X, and XI.
(d) A decision rejecting the testing proposal.
(e) A decision in accordance with points (a), (b), or (c), if several registrants or
downstream users of the same substance have submitted proposals for the same
test, giving them the opportunity to reach an agreement on who will perform the
test on behalf of all of them and to inform the Agency accordingly within
90 days. If the Agency is not informed of such agreement within such 90 days,
it shall designate one of the registrants or downstream users, as appropriate, to
perform the test on behalf of all of them.
Compliance Check of Registrations
To verify its compliance with the regulation, the Agency may examine any registra-
tion for:
(a) That the requirements of Articles 10, 12, and 13 and with Annexes III and VI to
X are submitted in the technical dossier (in pursuant to Article 10).
(b) That the adaptations of the standard information requirements and the related
justifications submitted in the technical dossier(s) are in compliance with the
rules governing such adaptations set out in Annexes VII to X and with the gen-
eral rules set out in Annex XI.
(c) That any required chemical safety assessment and chemical safety report com-
ply with the requirements of Annex I and that the proposed risk management
measures are adequate.
(d) That any explanation(s) submitted in accordance with Article 11(3) or Article
19(2) have an objective basis.
In accordance to Article 50 and 51 of this regulation, within 12 months of the
start of compliance check, the Agency may prepare a draft decision requiring the
registrants to submit any further information within a stipulated deadline, required
to bring the registration into compliance. To ensure the dossier compliance with this
regulation, the Agency will select no lower than 5% of the total dossier received for
each tonnage band. The list of dossiers checked by the Agency for compliance with
this regulation shall be made available to the Member States competent authorities.
The Agency shall examine any information submitted in consequence of decision
taken under Article 40 or 41. On completion of dossier information, the agency shall
notify the Commission and the competent authorities of the Member States of the
information obtained and any conclusions made.
3.2 Substance Evaluation
To ensure harmonized approach, the Agency in cooperation with the Member states
develops criteria for prioritizing substances grounded on risk-based approach. The
criteria shall consider:
(a) Hazard information, for instance, structural similarity of the substance with
known substances of concern or with substances which are persistent and liable
to bio-accumulate, suggesting that the substance or one or more of its transfor-
mation products has properties of concern or is persistent and liable to
bio-accumulate.
(b) Exposure information.
(c) Tonnage, including aggregated tonnage from the registrations submitted by sev-
eral registrants.
Based on these criteria, the Agency shall compile a draft community rolling plan
which shall cover a period of 3 years and shall specify the substances (based on their
risks to human health or environment) to be evaluated each year. A draft annual
update to the rolling plan will be submitted by the Agency to the Member States by
28 February each year. Based on the opinion from the Member State Committee (set
up under Article 76(1)(e)), the Agency shall adopt the final Community rolling
action plan and publish the plan on its website, identifying the Member State who
will carry out the evaluation of the substances listed therein as determined accord-
ing to Article 45.
Competent Authority
The Agency shall be responsible for coordinating the substance evaluation process
and ensuring that substances on the Community rolling action plan are evaluated. In
doing so, the Agency shall rely on the competent authorities of Member States. The
competent authorities may appoint another body to act on their behalf to carry out
an evaluation of a substance. A Member State may notify the Agency at any time, if
a substance has priority for evaluation, not on the Community rolling action plan.
The Agency shall decide whether to add this substance to the Community rolling
action plan on the basis of an opinion from the Member State Committee. If the
substance is added to the Community rolling action plan, the proposing Member
State, or another Member State who agrees, shall evaluate that substance.
If the competent authority considers that further information is required, it shall
prepare a draft decision, stating reasons, requiring the registrant(s) to submit the
further information within a set deadline for its submission. A draft decision shall
be prepared within 12 months of the publication of the Community rolling action
plan on the Agency’s website for substances to be evaluated that year. The decision
shall be taken in accordance with the procedure laid down in Articles 50 and 52. The
competent authority shall finish its evaluation activities within 12 months of the
start of the evaluation of the substance or within 12 months of the information being
submitted under paragraph 2 and notify the Agency accordingly. If this deadline is
exceeded, the evaluation shall be deemed finished.
Follow-up to Substance Evaluation
Once the substance evaluation has been completed, the competent authority shall
consider how to use the information obtained from this evaluation for the purposes
of Article 59(3), Article 69(4), and Article 115(1). The competent authority shall
inform the Agency of its conclusions as to whether or how to use the information
obtained. The Agency shall in turn inform the Commission, the registrant, and the
competent authorities of the other Member States.
Adoption of Decisions
• The Agency shall notify its draft decision in accordance with Article 40 or 41,
together with the comments of the registrant, to the competent authorities of the
Member States.
• Within 30 days of circulation, the Member States may propose amendments to
the draft decision to the Agency.
• If the Agency does not receive any proposals, it shall take the decision in the ver-
sion notified under paragraph 1.
• If the Agency receives a proposal for amendment, it may modify the draft
decision.
• The Agency shall refer a draft decision, together with any amendments proposed,
to the Member State Committee within 15 days of the end of the 30-day period
referred to in paragraph 2.
• The Agency shall forthwith communicate any proposal for amendment to any
registrants or downstream users concerned and allow them to comment within
30 days.
• The Member State Committee shall take any comments received into account.
• If within 60 days of the referral, the Member State Committee reaches a unani-
mous agreement on the draft decision, the Agency shall take the decision
accordingly.
• If the Member State Committee fails to reach unanimous agreement, the
Commission shall prepare a draft decision to be taken in accordance with the
procedure referred to in Article 133(3).
• In accordance with Articles 91, 92, and 93, an appeal may be brought against
Agency decisions.
Publication of Information on Evaluation
The Agency by 28 February of each year shall publish on its website a report on the
progress made over the previous calendar year toward discharging the obligations
incumbent upon it in relation to evaluation. This report shall include, in particular,
recommendations to potential registrants in order to improve the quality of future
registrations.
4 Authorization [1]
4.1 Requirement and Considerations for Substitution
The purpose of authorization is to properly maintain dangerous substances in the

market with risk controls and finding lesser dangerous substances/technologies to
replace them while considering the economic and technical feasibility and viability.
This responsibility lies for the manufacturers, importers, and downstream users that
apply for and claim authorization.
Article 56 talks about the general provisions for the requirement of authorization
procedure. A substance included under Annex XIV of this regulation is not to be
placed on the market or used by the manufactures, importer, or downstream user
without authorization. The exemptions are made when the substance/mixture’s use
has been authorized, or it has been exempted from authorization considering the
community legislation governs the use of the substance and the risk control mea-
sures. The exemption also holds if the date until which the substance can be placed
and used in the market has not been reached and 18 months from this date once the
extension for the authorization has been submitted. The immediate downstream
user can be authorized to use the regulated substance. This use has to be the same as
given in the authorization application submitted. These exemptions do not apply for
the use of the substance in scientific research and development, and for the product
and process-oriented research, the maximum quantity exempted has to be provided
by Annex XIV. Substances used as plant protection products [13], biocidal products
[14], motor fuels [15], and fuel in mobile or fixed combustion plants of mineral oil
products and use as fuels in closed systems do not follow the exemptions mentioned
above. The substances are to be authorized when classified under Article 57 as haz-
ardous to human health, and the exemptions provided do not apply for their use in
cosmetic products [16] and food contact materials [17]. Persistent, bio-accumulative,
and toxic substances used in preparations containing concentration below 0.1%
weight/weight and along with substances with lowest concentration limits [18, 19]
classified as dangerous are subject to authorization without exemptions.
Article 57 specifies the substances to be included in Annex XIV following the
procedures in Article 58. The substances included are carcinogenic category 1 or 2
[20], mutagenic category 1 or 2 [20], and toxic for reproduction category 1 or 2 [20].
The substances classified under Annex XIII of this regulation as persistent based on
the half-life in marine water (higher than 60 days), fresh- or estuarine water (higher
than 40 days), marine sediment (higher than 180 days), fresh- or estuarine water
sediment (higher than 120 days), or in soil (higher than 120 days) are to be included
in this Annex. The substances bioaccumulating with bioaccumulation factor greater
than 2000 and toxic substances are included as well. A substance with observed
toxicity of long term no-observed effect concentration (Noec) for marine and fresh-
water organisms is less than 0.01 mg/ml and showing chronic toxicity is identified
as T, R48, or Xn and R48 [20]. A substance classified as very persistent when the
half-life of the substance in marine/fresh/estuarine water or in marine/fresh/estua-
rine water sediment or in soil is higher than 60 days, 180 days and 180 days respec-
tively. The very bioaccumulative substances with bioaccumulation factor more than
5000 are included in Annex XIV. Annex XIV also includes substances that have
endocrine-disrupting properties and are persistent, bioaccumulative, and toxic in
nature and do not follow the criteria laid out above but are scientifically proven to
have adverse effects on human health and environment.
The inclusion of a substance in Annex XIV (Article 58) shall follow the regula-
tory procedure laid out by the Commission along with the Scrutiny Committee
formed by the representatives of the Member States chaired by representative of the
Commission [21]. Annex XIV must contain the identity of the substance such as
name or other identifier, molecular and structural information, composition, degree
of purity, impurities, additives, etc. [22]. The intrinsic property of the substance
given by Article 57 has to be included in the Annex. The date (sunset date) from
which the substance is placed on the market and its use is authorized. The date or
dates before the sunset date by which the authorization application must be received
for the continued use of the substance in the market after the sunset date is reached.
The review period for the use of the substance wherever appropriate also has to be
included. The exemptions from authorization for use/category of use for the sub-
stance also have to be mentioned with the basis of these exemptions. The substances
to be included are prioritized by the Agency along with the Member State Committee
based on their persistent, bioaccumulative, and toxic properties, wide dispersive
use, or high volume. The number of substances and the dates mentioned above have
to account for the Agency’s ability to handle the applications. The first set of priority
substances to be included in the Annex recommended by the Agency was included
by 1 June 2009, and further inclusions are done every second year. The Agency has
to publish the substances to be included in the Annex with public access at free of
cost over the Internet with comments enabled before recommending to the
Committee. With the comments received from interested parties within 3 months of
the publication, the Agency can update its recommendation. The substances
included in the Annex shall not be subjected to new restrictions under Title VIII
when used on its own or in a preparation can possess risk to human health and envi-
ronment. The substances can be subjected to new restrictions when its presence in
an article proves as risk. The substances prohibited from all uses as per Title VII or
by Community legislation shall not be included in the Annex or shall be removed.
The substances which do not fulfill the criteria mentioned in Article 57 resulting
from a new information are to be removed.
The procedure for identification of substances referred to in Article 57 is laid out
under Article 59 together with the candidate list for inclusion in Annex XIV. The
Committee can ask the Agency to prepare dossier with the information on harmo-
nized classification, identification, and restrictions (Annex XV) and make it avail-
able to the Member States. Any Member State can prepare and forward the dossier
to the Agency, and the Agency has to make it available within 30 days of receipt.
The Agency has to communicate the preparation of the dossier and invite other
Member States and all other interested parties to comment within a deadline which
is ideally within 60 days. If no comment is received, the Agency can recommend the
inclusion of the substance in the list. When comments are received, the Agency has
to refer the dossier to the Member State Committee within 15 days before the 60-day
deadline. The Member State Committee reaches a unanimous agreement within
30 days, and the Agency shall include the substance in its recommendation list.
When a unanimous agreement is not arrived, the Commission shall prepare a draft
proposal on identification of substance to be submitted to the European Parliament
and the Council for review. If no opposition is offered within 3 months of the draft
submission, then the draft shall be adopted by the Commission and published on its
website without delay.
4.2 Granting of Authorizations
Article 60 advices on granting of authorizations. The Commission is held respon-

sible for taking decisions on applications and authorizations. The authorization is
granted to the use of substance possessing risk to human health or environment in
Annex XIV provided these risks are controlled and documented in chemical safety
report with the opinion of the Committee of Risk Assessment [23]. It shall note the
discharges, emissions, and losses, including risks arising from diffusion and disper-
sive uses while granting authorization. The risks to human health from use of a
substance in medical device, active implantable medical devices, or in vitro diag-
nostic medical devices shall not be considered by the Commission [24–26]. This
lenience is not given for substances listed in Article 57 for which the threshold
exposure levels and likelihood and severity of the event occurring due to the physi-
cochemical properties of the substance cannot be determined. The persistent, very
persistent, bioaccumulative, very bioaccumulative, endocrine disrupting, and toxic
substances cannot be given any exceptions with respect to controlled risk measures
stated above. In this case, an authorization can only be granted if the socioeconomic
benefits of the use of the substance are greater than the risk to human health or envi-
ronment and no alternative substance or technologies are available. The decision is
made considering the opinions of the Committee for Risk Assessment and
Socioeconomic Analysis along with the appropriateness and effectiveness of the
risk management measures proposed, socioeconomic benefits, socioeconomic
implications arising from refusal of authorization, analysis of alternatives or substi-

tution plans submitted, and information on the risks to human health or environment
from alternative substances or technologies. The Commission shall look into all
relevant aspects of the suitable alternative substances or technologies including
whether this transfer could reduce overall risks given the appropriateness and effec-
tiveness of risk management measures and technical and economic feasibility of
these alternatives. The use of the substance shall not be authorized if it involves
relaxation of restriction set in Annex XVII. The grant of authorization is only pos-
sible when the application is confirming with the application requirement set in
Article 62 of this regulation. The authorizations can be dependent on time-limited
review with monitoring with the duration determined on a case-by-case basis. The
authorization shall include the person to whom the authorization is granted, identity
of the substance, the use for which the authorization is granted, any conditions
under which authorization is granted, time-limited review period, and monitoring
arrangement. The holder of authorization shall always ensure the exposure is
reduced to as low technically and practically as possible.
Review of Authorizations
The review process for these authorizations is done according to Article 61 of this
regulation.
• The validity of the authorization is granted until the Commission decides to
amend or withdraw it for review unless the holder of authorization submits a
review report 18 months before the expiry of time-limited review period.
• The holder shall submit an update of alternatives analysis, relevant research, and
development activities done by the applicant and substitution plan.
• A substitution plan shall be submitted when a suitable alternative is available
with timetable for proposed actions.
• When the holder can control the risk, then a chemical safety report is needed, and
when risks cannot be controlled, an update to the socioeconomic analysis in the
original application shall be given.
• Any updates to the elements of the original application have to be communicated
in this review. The authorizations can be reviewed whenever the circumstances
of the original authorization have changed affecting the risk to human health or
environment or socioeconomic impact and suitable substitutes are available.
• The Commission sets a deadline by which the holder can submit further informa-
tion required for review. The Commission can amend or withdraw the authoriza-
tion under the changed circumstances with all the necessary information about
these changes submitted by the holder of authorization.
• The Commission can decide to suspend the authorization pending review when
there is serious and immediate risk for human health or environment.
• When the environmental quality standards and environmental objectives [27, 28]
are not met, the authorization for the use of the substance can be reviewed, and
also if use of a substance is subsequently restricted/prohibited as persistent

organic pollutant, then the authorization can be withdrawn by the commit-
tee [29].
Applications for Authorizations
The information regarding the application of authorization is given under Article 62

of this regulation. The application shall be submitted to the Agency. The application
can be submitted by the manufacturer(s), importer(s), and/or downstream user(s) of
the substance. An application can be submitted by more than one person. The appli-
cation can include one or a group of substance with similar physicochemical, toxi-
cological, and ecotoxicological properties for one or more uses. The applicant can
submit application for own use and for uses for which the substance is placed on the
market. The application shall include the identity of the substance(s), the name and
contact detail of the person(s) submitting the application, a request for authorization
for the specific use of the substance and use of preparation in which the substance
is incorporated, a chemical safety report (unless submitted before as part of registra-
tion) mentioning the risks to human health or environment arising due to the intrin-
sic properties of the substance, analysis for the alternative substance or technology
with information on research and development activities by the applicant, and a
substitution plan with timetable when suitable alternatives are available for the sub-
stance in question. Additionally, the substance can include socioeconomic analysis
and a justification for not considering risks to human health and environment
through emissions of substance from a permitted installation [15] and discharges of
the substance from point source [30]. The application shall not include risks to
human health arising from use of the substance in medical device [24–26]. The
application shall include the appropriate fee required as given under Title IX of this
regulation. The subsequent applications are submitted as per Article 63. A subse-
quent application is filed for parts of the existing application such as chemical safety
report, analysis of alternative to the applied substance, and substitution plan for the
suitable alternatives proposed and socioeconomic analysis. This subsequent appli-
cations provision applies for already granted authorization. The subsequent applica-
tion shall also update the information in the original application.
Procedure for Authorization Decisions
The procedure for decisions on authorization is listed in Article 64. Firstly, the
Agency shall acknowledge the receipt of application with date. The Agency’s
Committees for Risk Assessment and Socioeconomic analysis shall give their opin-
ions on the draft within 10 months of receipt of application. The Agency shall make
information on use of the substance publicly accessible at free of cost as soon as the
application is received with the deadline for alternative substances or technologies
submissions. The Committees shall check that the application shall include all
information asked for as per Article 62. The Committees shall consult with each
other and request for additional information from the applicant and consider all
information submitted by third parties. The Socioeconomic Analysis Committee
requires for the applicant or third parties to submit additional information on pos-
sible alternative substance or technologies within a specified time period. The draft
opinions shall contain Committee for Risk Assessment and Committer for
Socioeconomic Analysis. The Agency shall communicate the draft opinions to the
applicant by end of deadline and considered to be received by the applicant within
7 days of sending. The applicant shall give in writing if he/she wishes to comment
within 1 month of receipt of draft opinion. When no comment is made, the Agency
shall send the opinions to the Commission, the Member States, and the applicant
within 15 days of end of period for applicant’s comment or within 15 days of receipt
of notice of “no comment” from applicant. The applicant shall send his written
arguments/comments to the Agency within 2 months of receipt of draft opinion, and
the Committee shall consider the comments and make their final opinions within
2 months of receipt of applicant’s arguments. The Agency shall send the opinions
with written argumentations to the Commission, the Member States, and applicant
in further 15 days. The Agency decides which part of opinions and attachments to
be published for public access on its website. When subsequent applications are
submitted to the original application, the Agency can consider the application
together within the deadlines for the original application. The Commission shall
decide on the draft authorization within 3 months after receiving the Agency’s opin-
ion. The final decision on granting or refusal of the authorization is within a time
limit determined by urgency by the advice of the Commission or sometimes by vot-
ing. The Commission decisions with the authorization number and reason for the
decision shall be published in the Official Journal of the European Union and made
available publicly database which is kept up to date by the Agency. For subsequent
application, the deadline is shortened by 5 months.
4.3 Obligation of Holders of Authorizations
The obligations of holders of authorization are described in Article 65. The holders
of authorization and the downstream users shall include the authorization number of
the substance on the label before placing the substance or preparation including the
substance on the market for its authorized use as soon as the authorization number
is published. The downstream users shall notify the Agency within 3 months of start
of the supply of the substance. The Agency shall document the downstream users
through a register and maintain it up to date. This register has to be accessible for
competent authorities of the Member States.
5 estrictions on the Manufacturing, Placing on the Market,

R
and Use of Certain Dangerous Substances, Preparations,
and Articles [1]
5.1 eneral Provisions for Introducing New and Amending

G
Current Restrictions
The provisions for the restrictions for the substances to be placed on the market and
be used are given under Article 67 of this regulation. Annex XVII specifies the
restrictions and conditions under which the restrictions can be relaxed for product
and process-related research and development along with the maximum exemption
quantity. The substance or the preparation of the substance included in the Annex
XVII with a restriction shall not be placed on the market or used beyond the condi-
tions mentioned in the Annex. For example, chloroform shall not be used in concen-
trations equal to 0.1% or more by weight for public sale and/or in diffusive purposes
such as surface cleaners or fabric cleaners. This restriction does not be considered
for use of the substance in scientific research and development. The restrictions do
not cover the use of the substances in cosmetic products as it is already defined by
a different directive [16]. The Commission is responsible for compiling and pub-
lishing the inventory of the restrictions by 1 June 2009. A Member State shall main-
tain record of existing and stringent restrictions in Annex XVII after having notified
till 1 June 2013.
The restriction process is detailed under Article 68. An unacceptable risk to
human health or environment occurs from manufacture, placing on the market, or
use of a substance. Annex XVII has to be amended with new restrictions altering the
current restrictions [21]. These restrictions shall be made considering socioeco-
nomic impact and availability of alternatives. The use of substance as onsite isolated
intermediate can be exempted from the amendment. For substances or preparations
classified as carcinogenic, mutagenic, or toxic to reproduction category 1 or 2 and
used by consumers, the Commission proposes the restrictions and amended by the
regulatory procedure laid out by Commission along with the Scrutiny Committee
formed by the representatives of the Member States chaired by representative of the
Commission [21], and the following Article does not apply.
5.2 Restriction Process
Preparation of Restriction Proposal
• When the manufacture, placing on the market, or use of a substance or its prepa-
ration proves as risk to human health or environment and these risks are not
adequately controlled, then the Commission and the Member States can request
the Agency to prepare Dossier with restriction proposal, information on
a lternatives, justification for the restriction, and socioeconomic assessment fol-

lowing Annex XV of this regulation.
• The Agency can also prepare the dossier after the sunset date when it considers
the use of substance or its preparation generates risk which is not adequately
controlled. The Agency has to suggest restrictions to initiate the restriction pro-
cess if the dossier proves more actions are needed within 12 months of the
Commission’s request.
• The Member State is responsible for preparing and submitting the dossier for
restrictions when the substance is not included in the list maintained by the
Agency within 12 months after notifying the Agency to initiate the restrictions.
The Agency or Member States can refer to any dossiers, chemical safety reports,
and risk assessments submitted for other purposes and also can request other
agencies under the Community law for this information.
gency Opinion: Committee for Risk Assessment

A
and Socioeconomic Analysis
• The Committee for Risk Assessment and Socioeconomic Analysis shall oversee
if the dossiers submitted by the Agency or the Member State conform with the
requirements within 30 days of submission. Any conform problems shall be
communicated to the Agency or the Member States within 45 days of receipt of
the dossier with reasons and corrected within 60 days of receiving the reasons
from the Committee.
• The Agency shall publish the opinion of the Commission of Member State to
initiate the restriction procedure and inform the registrant of the same. The
Agency is responsible for maintaining the list of substances for which dossiers
are planned or underway. A substance included in this list shall not have any
other dossier.
• If an existing restriction has to be re-examined, it has to be decided by the
Commission assisted by an advisory committee composed of the representatives
of the Member States and chaired by the representative of the Commission. This
representative has to submit a draft of measures to be taken to the Committee,
and the decision has to be taken within a time limit based on the urgency based
on the evidence presented and may be through a voting system [21].
• The Agency shall make the dossiers publicly accessible on its website with the
restrictions suggested and the date of publication.
• The interested parties can submit their comments on the dossiers and suggested
restriction together with socioeconomic analysis or any other information study-
ing the advantages and drawback of these restrictions within 6 months of the date
of publication.
• The Committee for Risk Assessment shall check and render its opinion if the
suggested restrictions are necessary to reduce the risk to human health or envi-
ronment within 9 months considering the Member State dossier, the dossier pre-
pared by the Agency, and the views of the interested parties (Article 70).
• The Committee for Socioeconomic Analysis shall come to an opinion on the sug-
gested restrictions after studying the dossier and the socioeconomic impact
within 12 months of publication. This opinion has to be published on the website
by the Agency and invite comments from interested parties within 60 days of the
opinion publication.
• The Committee shall adopt its opinion considering comments received. If the
opinion of the Committee for Risk Assessment deviates from the restrictions
suggested, the deadline for delivering opinion of the Socioeconomic Analysis
Committee can be postponed by 90 days (Article 71).
Submission of an Opinion to the Commission
• The submission of an opinion to the Commission is as per Article 72 of this regu-

lation. The opinions of the Committees of Risk Assessment and Socioeconomic
Analysis shall be submitted to the Commission by the Agency on the restriction
suggestions with documents and evidence submitted upon request. If either of
the Committee is not able to come to an opinion by the deadline, then the Agency
shall inform the Commission with proper reasons. The opinions of the Committees
shall be published on the website by the Agency without delay.
Commission Decision
• Article 73 covers the decision made by the Commission. The Commission shall
prepare a draft amendment to Annex XVII once Article 68 conditions. It shall be
fulfilled either 3 months after obtaining the opinion or before the deadline set in
Article 71 if the Committee has not come to an opinion.
• The Commission shall provide a detailed report with explanation for the differ-
ence when the amendment differs from the original proposal or the opinion of the
Agency is boycotted. The Commission is assisted by an advisory committee
composed of the representatives of the Member States and chaired by the repre-
sentative of the Commission. This representative has to submit a draft of mea-
sures to be taken to the Committee, and the decision has to be taken within a time
limit based on the urgency based on the evidence presented and may be through
a voting system [21]. The draft amendment shall be submitted to the Member
States by the Commission 45 days before the voting.
6 Reach Safety Data Sheet [1]
The supplier of a substance or a preparation shall provide the recipient of the sub-
stance or preparation with a safety data sheet complied in accordance with Annex II
where (i) a substance or preparation meets the criteria for classification as
dangerous (Directives 67/548/EEC or 1999/45/EC) or (ii) substance is persistent,

bioaccumulative, and toxic or very persistent and very bioaccumulative in accor-
dance with the criteria set out in Annex XIII or (c) a substance is included in the list
established in accordance with Article 59(1) for other reasons. The safety data sheet
might not be supplied for dangerous substances or preparations sold to general pub-
lic if sufficient information and measures necessary for protection of human health,
safety, and environment are available to users. However, the supplier shall provide
the safety data sheet (electronic copy or free of cost) at request by the recipient in
accordance with Annex II.
The safety data sheet shall be supplied in an official language of the Member
State(s), where the substance or preparation is placed on market, and shall contain
the following information:
(i) Identification of the substance/preparation and of the company/undertaking.
(ii) Hazards identification.
(iii) Composition/information on ingredients.
(iv) First-aid measures.
(v) Fire-fighting measures.
(vi) Accidental release measures.
(vii) Handling and storage.
(viii) Exposure controls/personal protection.
(ix) Physical and chemical properties.
(x) Stability and reactivity.
(xi) Toxicological information.
(xii) Ecological information.
(xiii) Disposal considerations.
(xiv) Transport information.
(xv) Regulatory information.
(xvi) Other information.
Any downstream user shall include relevant exposure scenarios and use other
relevant information, from the safety data sheet supplied to him when compiling his
own safety data sheet for identified uses. The suppliers shall update the safety data
sheet without delay if:
(i) New information which may affect the risk management measures or new
information on hazards becomes available.
(ii) Once an authorization has been granted or refused.
(iii) Once a restriction has been imposed.
The new, dated version of the information, identified as “Revision: (date),” shall be
provided by the supplier to all former recipients, who have been supplied with the
substance or preparations within the preceding 12 months.
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of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction
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(EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives
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October 2000 establishing a framework for Community action in the field of water policy and
legislation adopted under Article 16 of the same Directive.
EU 1272/2008 – Classification, Labelling
and Packaging of Substances and Mixtures
1 Introduction
I. EU and EC 1272/2008
The European Parliament and the Council of the European Union with respect to
the treaty establishing the European Community, Article 95, the Commission’s pro-
posal, the European Economic and Social Committee’s opinion, procedures laid
down in Article 251 of the Treaty and European Commission (EC) lays down regu-
lations for ensuring the safety of the patient. These regulations were split into differ-
ent sections in order to provide a detailed description about the specific categories
and chemical used in the medical devices.
One such regulation is EU CLP Regulation (EC) No 1272/2008. CLP stands for
Classification, Labelling, and Packaging of substances and mixtures. For appropri-
ate classification and labelling of chemicals, CLP introduced the United Nations
Globally Harmonized Systems (UN GHS) into Europe on 20 January 2009. Initially,
there exist different systems for classification and labelling of chemicals around the
world, which led to a huge confusion, misunderstandings among workers, potential
errors, and dissatisfaction of consumers. The major cause of the insufficiency is dif-
ferent countries using differing forms of labeling and safety data sheets. Hence, UN
has come forward to develop a globally harmonized system of classification and
labeling of chemicals, known as GHS. In the initial stage, GHS bound to Europe
non-legally as an international agreement; later CLP introduced GHS into
Europe [1].
H. Sriram
II. Establishment of Compliance with CLP Regulation

The Article 46 of the CLP Regulation on Enforcement and Reporting circum-
stances that the “Member States shall take all necessary measures, including main-
taining a system of official controls, to ensure that substances and mixtures are not
placed on the market, unless they have been classified, labelled, notified and pack-
aged in accordance with this Regulation.” Companies need to classify the substances
or mixtures, and C&L notifications will be submitted to ECHA (European Chemical
Agency). Subsequently labelling and packaging of their products was done in
accordance with the CLP regulation. Information about CLP classification and
labelling will be located in the CLP complaint Safety Data Sheet. The following
information was prepared and communicated with the downstream users for the
compliance [2]:
–– Classification
–– Labelling and packaging
–– C&L notification
–– Safety data sheet
III. Purpose and Scope [3]
The primary strategy of the regulation is to ensure safety of human health and
environment and movement of substances, mixtures, and articles as specified in
Article 4(8):
(a) Harmonizing the criteria and/or strategy of substances and mixtures classifica-
tion and the establishment of rules on labelling and packaging for hazardous
substances and mixtures.
(b) Providing an obligation for:
–– Classification of substances and mixtures placed on the market by manufac-
turers, importers, and downstream users
–– Labelling and packaging of substances and mixtures placed on the market by
suppliers
–– Classification of those substances not placed on the market which must
undergo registration or notification under Regulation (EC) No 1907/2006 by
manufacturers, producers of articles, and importers
(c) An obligation will be ascertained to the manufacturers and importers of sub-
stances for notifying the agency of such specific classifications and label ele-
ments, if they have not been submitted to the agency as part of a registration
under Regulation (EC) No 1907/2006.
(d) Establishment of a list of substances with their harmonized classifications and
labeling elements at community level in Part 3 of Annex VI.
(e) Inventory substances classification and labelling made up of all notifications,
submissions, and harmonized classifications and labeling elements as referred
to in points (c) and (d).
EU 1272/2008 – Classification, Labelling and Packaging of Substances and Mixtures 263
This regulation does not apply to the following:

(a) Radioactive substances and mixtures that are in the scope of Council Directive
96/29/Euratom of 13 May 1996 which has laid down the primary safety stan-
dards for the protection of workers’ health. It also takes public health into
account ensuring against danger arising from ionizing radiation.
(b) Substances and mixtures that are in subject to customs supervision which do
not undergo any treatment or processing, which are in temporary storage or in
a free zone or free warehouse with a re-exportation or in transit view.
(c) Non-isolated intermediates.
(d) Substances and mixtures that are used in scientific research and development,
which are not placed in the market and provided to be used under specific and
controlled conditions in accordance with Community workplace and environ-
mental legislation.
–– As defined in Directive 2006/12/EC of the European Parliament and Council
of 5 April 2006 on waste, it is not a substance, mixture, or article within the
meaning of Article 2 of this Regulation.
–– In specific cases where, the substances or mixtures are of interest to the
defense, the member states may allow for exemptions from this regulation.
–– The regulation is not applicable to substances and mixtures in the following
form which are in finished state intended for the final user.
–– Medicinal products as defined in Directive 2001/83/EC.
–– Veterinary medicinal products as defined in Directive 2001/82/EC.
–– Cosmetic products as defined in Directive 76/768/EEC.
–– Medical devices as defined in Directives 90/385/EEC and 93/42/EEC, which
are invasive or used in direct physical contact with the human body and in
Directive 98/79/EC.
–– Food or feeding stuffs as defined in Regulation (EC) No 178/2002 including
when they are used as a food additive (89/107/EEC), flavoring (Directive
88/388/EEC and Decision 1999/217/EC), additive (Regulation (EC) No
1831/2003), or animal nutrition (Directive 82/471/EEC) in foodstuffs or
feeding stuffs within the scope of these Directives.
–– The regulation shall not apply to dangerous goods by air, road, sea, rail, or
inland waterways transportation.
IV. Hazardous Substances and Mixtures and Specification of Hazard Classes [4]
A hazardous substance is a mixture which can fulfill the criteria relating to physi-
cal hazards, health hazards, or environmental hazards which has been laid down in
Parts 2 to 5 of Annex I [5]. It can be classified in relation to the respective hazard
classes specified in Annex I. The substances or mixtures were classified based on
the route of exposure or nature of effects.
V. General Obligations to Classify Label and Package
Substances placed on market shall be classified based on various stakeholders
(manufacturers, producers of articles, and importers) involved, and users shall
classify substances or mixtures in accordance with Title II (discussed in Sect. 2 of

this chapter). Without prejudice to the requirements of paragraph 1 (discussed in
paragraph I, Sect. 2 of this chapter), manufacturers, producers of articles and import-
ers shall classify those substances not placed on the market in accordance with Title
II. In cases where substances are subject to harmonized classification and labelling
in accordance with Title V (discussed in Sect. 2 of this chapter) through an entry in
Part 3 of Annex VI, Title II shall not be performed in that entry. However, where the
substance also falls within one or more hazard classes or differentiations, Title II
shall be carried out for those hazard classes or differentiation with packaging in
accordance with Titles III (discussed in Sect. 3 of this chapter) and IV (discussed in
Sect. 4 of this chapter). The regulation also states that distributors may use the clas-
sification for a substance or mixture derived in accordance with Title II. A mixture
referred to in Part 2 of Annex II that contains any substance classified as hazardous
shall not be placed on the market, unless it is labelled in accordance with Title III.
2 Classification
I. Identification and Examination of Available Information [4–6]

The stakeholders (manufacturers, importers, and downstream users) of a sub-
stance or a mixture shall identify whether the substance or a mixture entails a physi-
cal, health, or environmental hazard, based on the relevant criteria laid down in Parts
2 to 5 of Annex I [5] of EU 1272-2008, in particular:
(a) The data generated with any of the test methods referred to in Article 13(3) of
Regulation (EC) No 1907/2006
(b) Internationally recognized sound scientific principles or procedures
(c) Data from epidemiological, occupational, or accident databases
(d) Any other information in Section 1 of Annex XI to Regulation (EC) No
1907/2006
(e) Any new scientific or any other information generated under internationally
recognized chemical programs
The information shall relate to forms or physical states in which the substance or
mixture is placed on market or expected to be used. If there is no information or no
adequate data in the existing database, then the stakeholder shall use other available
information on individual substance or similar tested mixtures to determine their
hazardousness. However, the manufacturer, importer, or downstream user should
ascertain that information is adequate and reliable for the purpose of the evaluation
pursuant to Article 9(4) of this regulation.
A. Generating New Information for Substances and Mixtures [7]
If the information on the substance or mixture in not available in Annex I of EU
1272-2008 regulation and the manufacturer, importer, or downstream user has
exhausted all other means of generating information including by applying the rules
provided for in Section 1 of Annex XI to Regulation (EC) No 1907/ 2006, new tests
may be performed in accordance to Article 9 of this regulation, to determine whether
the substance or a mixture entails a physical, health, or environmental hazard. The
tests shall be conducted in accordance with article 8(3) of this regulation [3] with
one of the following methods:
(a) The data generated with any of the test methods referred to in Article 13(3) of
Regulation (EC) No 1907/2006
(b) Internationally recognized sound scientific principles or procedures
Tests on animals for generating new data for this regulation, within the meaning
of Directive 86/ 609/EEC, shall be undertaken only where no other alternatives are
possible [8]. Furthermore, tests on non-human primates and humans shall also be
prohibited for the purposes of this Regulation. However, data obtained from other
sources including clinical studies can be used. The new tests shall be carried out in
the forms or physical states in which the substance or mixture is placed on market
or expected to be used. For example, possible methods for determining flash point
of flammable liquids are cited below:
Methods for determining the flash point of flammable liquids [6]

European standards: EN ISO 1516 as amended
Determination of flash/no flash – Closed cup
equilibrium method
EN ISO 1523 as amended
Determination of flash point – Closed cup equilibrium
method
Determination of flash point – Pensky-Martens closed
cup method
Determination of flash point – Rapid equilibrium closed
cup method
Determination of flash/no flash – Rapid equilibrium
closed cup method
Petroleum products and other liquids – Determination of
flash point –
Abel closed cup method
National standards:
Association française de NF M07-036 as amended
normalisation, AFNOR: Détermination du point d'éclair – Vase clos Abel-Pensky
(identical to DIN 51755)
British Standards Institute BS 2000 Part 170 as amended
(identical to EN ISO 13736)
Methods for determining the flash point of flammable liquids [6]

Deutsches Institut für Normung DIN 51755 (flash points below 65 C) as amended
Prüfung von Mineralölen
und anderen brennbaren Flüssigkeiten; Bestimmung des
Flammpunktes im
geschlossenen Tiegel, nach Abel-Pensky
(identical to NF M07-036)
Source: Table 2.6.3, Annex I [5]; Methods for determining the flash point of flam-
mable liquids; CLP regulation (EC) no 1272/2008 of the European Parliament and
of the Council of 16 December 2008
II. Evaluation of Hazard Information and Decision on Classification

A. Evaluation of Hazard Information [9]
The stakeholder users of a substance or a mixture shall evaluate the information
identified in accordance with Sect. 2 of this chapter by each hazard class or differ-
entiation in Parts 2 to 5 of Annex I [5], to ascertain the hazards. In evaluating avail-
able test data for a substance or a mixture, other than those referred to in Article
8(3), the stakeholder users shall compare the test methods employed with that
Article in order to determine whether those test methods affect the evaluation
referred to in paragraph I, Sect. 2 of this Article. When the criteria cannot be applied
directly to available identified information then the stakeholders shall carry out an
evaluation by applying a weight of evidence determination using expert judgement
in accordance with section 1.1.1 of Annex I [5] to this Regulation, weighing all
available information having a bearing on the determination of the hazards of the
substance or the mixture, and in accordance with section 1.2 of Annex XI to
Regulation (EC) No 1907/2006 [10].
When Article 6(5) is available, stakeholders shall apply the bridging principles
referred to in Section 1.1.3 and in each section of Parts 3 and 4 of Annex I [5] for
the purpose of evaluation. However, where information permits the application nei-
ther of the bridging principles nor the principles for using expert judgement as
described in Part 1 of Annex I, stakeholders shall evaluate the information by each
section of Parts 3 and 4 of Annex I [5]. While evaluating the information, physical
states in which the substances or mixtures are marketed shall be used by the
stakeholders.
B. Concentration Limits and M-Factors for Classification of Substances and
Mixtures [11]
Specific concentration limits and generic concentration limits are limits assigned
to a substance indicting a threshold at or above which the presence of that substance
in another substance or mixture is identified as impurity, additive, or individual
constituent leading to classification of the substance or mixture as hazardous [4].
Stakeholders shall set specific concentration limits where adequate, and reliable
scientific information shows that the hazard of a substance is evident at a level

below concentrations set for any hazard class in either specific concentration limits
(part 2 of Annex I) or generic concentration limits (Parts 3, 4 and 5 of that Annex I).
In exceptional circumstances, stakeholders shall set specific concentration limits
where a hazard of a substance classified as hazardous is not evident at a level above
the concentrations set for the relevant hazard class in Part 2 of Annex I or above the
generic concentration limits set for the relevant hazard class in Parts 3, 4, and 5 of
that Annex I.
M-factors for substances classified as hazardous to the aquatic environment
acute category 1 or chronic category shall be established by stakeholders. M-factors
and specific concentration limits shall not be set for harmonized hazard classes or
differentiations for substances included in Part 3 of Annex VI, for which an M-factor
is given in Part 3. However, where an M-factor is not given in Part 3 for hazardous
substances to the aquatic environment, an M-factor based on available data for the
substance shall be set by the stakeholder. When a mixture including the substance is
classified by the stakeholder using the summation method, this M-factor shall be
used. In setting the specific concentration limit or M-factor, stakeholders shall con-
sider any specific concentration limits or M-factor limits for that substance which
have been included in the classification and labelling inventory. Such specific con-
centration limits set shall take precedence over the concentrations in the relevant
sections of Part 2 of Annex I or the generic concentration limits for classification
sections of Parts 3, 4, and 5 of Annex I.
C. Cutoff Values [12]
Cutoff values indicate when the presence of a substance needs to be taken into
account for the purposes of classification of a substance or a mixture containing that
hazardous substance, whether as an identified impurity, additive, or individual con-
stituent. When a substance or a mixture inherently classified as hazardous, either in
the form of an identified impurity, additive, or individual constituent, this shall also
be taken for classification, if the concentration of identified impurity, additive or
individual constituent is equal to, or greater than, the applicable cut-off value in
accordance with section 1.1.2.2 of Annex I.
Hazard class Generic cutoff values to be taken into account

Acute toxicity:
Category 1–3 0.1%
Category 4 1%
Skin corrosion/irritation 1%
Serious damage to eyes/eye irritation 1%
Hazardous to aquatic environment
Acute Category 1 0.1%
Chronic Category 1 0.1%
Chronic Category 2–4 1%
Source: Table 1.1.2.2, Annex I [5]; Cut-off values; CLP regulation (EC) no
1272/2008 of the European Parliament and of the Council of 16 December 2008
D. Specific Cases Requiring Further Evaluation [13]

As a result of the evaluation as per Article 9 of this regulation, the following
properties or effects are identified in accordance to Article 12 of this regulation,
which the stakeholder users shall take them into account for the purpose of
classification:
(a) Adequate and reliable information shows that in practice the physical hazards
of a substance or a mixture differ from those shown by tests.
(b) Conclusive scientific experimental data show that the substance or mixture is
not biologically available and those data have been ascertained to be adequate
and reliable.
(c) Adequate and reliable scientific information demonstrates the potential occur-
rence of synergistic or antagonistic effects among the substances in a mixture.
E. Decision to Classify Substances and Mixtures [14]
If the evaluation as per Article 9 and Article 12 shows that the hazards associated
with the substance or mixture meet the criteria for classification in one or more
hazard classes or differentiations in Parts 2 to 5 of Annex I, stakeholders shall clas-
sify the substance or mixture in relation to the relevant hazard class or classes or
differentiations by assigning the following:
(a) One or more hazard categories for each hazard class or differentiation
(b) Subject to Article 21, one or more hazard statements corresponding to each
hazard category assigned in accordance with (a)
For example, a flammable liquid shall be classified in one of the three categories
for this class in accordance with Annex I.
Category Criteria for flammable liquids

1 Flash point < 23 °C and initial boiling point ≤ 35 °C
2 Flash point < 23 °C and initial boiling point > 35 °C
3 Flash point ≥ 23 °C and ≤ 60 °C (1)
(1) For the purpose of this Regulation, gas oils, diesel, and light heating oils having a flash
point between ≥ 55 °C and ≤ 75 °C may be regarded as Category 3
Source: Table 2.6.1, Part 2 of Annex I [5]; Criteria for flammable liquids; CLP regu-
lation (EC) no 1272/2008 of the European Parliament and of the Council of 16
December 2008
F. Specific Rules for the Classification of Mixtures [15]

The classification of a mixture shall not be affected where the evaluation of the
information indicates any of the following:
(a) Substances in the mixture react slowly with oxygen, carbon dioxide, water
vapor and other substances in the mixture to form different substances at low
concentration.
(b) Substances in the mixture may self-polymerize to form oligomers or polymers,
at low concentration.
A mixture need not be classified for explosive, oxidizing, or flammable proper-
ties as referred to in Part 2 of Annex I if any of the following requirements are met:
(a) None of the substances in the mixture possess any of those properties, and the
mixture is unlikely to present hazards of such kind.
(b) In the event of a change in the composition of a mixture, scientific evidence
indicates that it will not lead to a change in classification.
(c) Where a mixture is placed on the market in the form of an aerosol dispenser, it
satisfies Article 8(1a) of Council Directive 75/324/EEC of 20 May 1975 on the
approximation of the laws of the Member States relating to aerosol dispensers.
G. Review of Classification for Substances and Mixtures [16]
The stakeholders shall take all reasonable steps available to them to make them-
selves aware of new scientific or technical information that may affect the classifica-
tion. When stakeholder becomes aware of such information which he considers to
be adequate and reliable, that stakeholder shall carry out evaluation in accordance
with this chapter. The stakeholder manufacturer, importer, or downstream user
introduces a change to a mixture that has been classified as hazardous, and that
stakeholder shall carry out a new evaluation in accordance with this chapter where
the change is as follows:
–– A change in the composition of the initial concentration of one or more of the
hazardous constituents in concentrations at or above the limits in Table 1.2 of
Part 1 of Annex I.
–– A change in the composition involving the substitution or addition of one or
more constituents in concentrations at or above the cutoff value referred to in
Article 11(3).
–– A new evaluation in accordance with paragraphs 1 and 2 shall not be required if
there is valid scientific justification that this will not result in a change of
classification.
The stakeholder shall adapt the classification with the results of the new evalua-
tion except where there are harmonized hazard classes or differentiations for sub-
stances included in Part 3 of Annex VI. 5. For paragraphs 1 to 4 of Article 15 of this
regulation, when the substance or mixture concerned is within the scope of Directive
91/414/EEC or Directive 98/8/EC, the requirements of those Directives shall
also apply.
H. Classification of Substances Included in the Classification and Labelling
Inventory [17]
Manufacturers and importers may classify a substance differently from the clas-
sification already included in the classification and labelling inventory, provided
they submit the reasons for the classification to the Agency together with the notifi-
cation in accordance with Article 40. 2. Paragraph 1 shall not apply if the classifica-
tion included in the classification and labelling inventory is a harmonized
classification included in Part 3 of Annex VI [18].
3 Labelling
In accordance with Article 17 of the CLP regulation [19], a hazardous substance

contained in a packaging is required to bear a label with the name, address, and
telephone number of the supplier(s), the nominal quantity of the substance/mixture
in the package unless specified elsewhere other than the label, product identifiers
(Article 18), hazard pictograms (Article 19), signal words (Article 20), hazard state-
ments (Article 21), precautionary statements (Article 22), and supplemental infor-
mation (Article 25). Each of these elements follows the guidelines given under
Articles 18–25 which will be discussed in brief here. The labels are written in the
official language(s) of the Member of State where the substance/mixture is mar-
keted. The labels can bear more languages than those required provided all the lan-
guages hold the same details.
A. Product identifiers [20] are defined as the term used for the identification of the
substance/mixture as given in Article 31 of the Regulation (EC) No 1907/2006
(also known as the safety data sheet) without any prejudice with Article 17(2).
Substances and mixtures are identified in the label by different guidelines. Each
substance is given an index number, EC number, CAS number, and International
Chemical Identifications. Impurities and additives are not usually mentioned
unless they contribute significantly to the classification. The substances are
named and designated identification number as included in Table 3.1 in Part 3 of
Annex VI, and for those not included, name and identification number are given
as per classification and labelling inventory. A substance neither in Part 3 of
Annex VI nor the classification and labelling inventory is identified by number
provided by the Chemical Abstracts Service (CAS no.) along with its IUPAC
nomenclature or international chemical name(s). In case of non-availability of
CAS no., only the IUPAC nomenclature or international chemical name(s) is
used. When the given IUPAC nomenclature exceeds 100 characters, then usu-
ally the name, trade name, or abbreviation is used as referred to in Section 2.1.2
of Annex VI in accordance with Article 40. A product identifier for ethanol is
cited for example as below:
Index no International chemical identification EC no CAS no

603-002-00-5 Ethanol; ethyl alcohol 200-578-6 64-17-5
Source: Table 3.1, Part 3 of Annex VI [18]; Product identifier for ethanol; CLP regu-
lation (EC) no 1272/2008 of the European Parliament and of the Council of 16
December 2008
The product identifier for mixtures must include trade name or the designation of
the mixture along with identity of all the substances in the mixture that are respon-
sible for major health hazards such as acute toxicity, skin corrosion/irritation, seri-
ous eye damage/irritation, respiratory or skin sensitization, germ cell mutagenicity,
carcinogenicity, reproductive toxicity, and specific target organ toxicity with single
and repeated exposure and aspiration hazard. A maximum of four chemical names
can be given considering the major health hazards associated unless more are
needed depending on the severity of the hazards.
B. Hazard pictogram(s) [21] convey a very important and specific information
about the hazard involved in a pictorial form. With the help of Table 1 in Annex
I, the pictograms are provided with the label elements for each hazard class with
rules for labelling of packaging (Article 33) which will be discussed in the pack-
aging section of the chapter. Hazard pictograms are square in shape set at a point
and have a black symbol in a white background framed with a red frame. They
must be 1/15th of the surface area of the harmonized label with a minimum area
not less than 1cm [2]. The dimensions of the pictogram on labels depend on the
capacity of the package. For packages not exceeding 3 L, the pictogram must be
at least 52mm × 74mm, greater than 3 L and less than 50 L holds a pictogram of
at least 74mm × 105mm, greater than 50 L and less than 500 L holds a pictogram
of at least 105mm × 148mm, and for packages more than 500 L, the pictogram
must be 148mm × 210mm. An example of a pictogram assigned for flammable
substances/mixtures from Annex V is given below:
Pictogram Hazard class and hazard category

(1) (2)
Section 2.2
Flammable gases, hazard category 1
Section 2.3
Flammable aerosols, hazard categories 1, 2
GHS02 Section 2.6
Flammable liquids, hazard categories 1, 2, 3
Section 2.7
Flammable solids, hazard categories 1, 2
Section 2.8
Self-reactive substances and mixtures, Types B, C, D, E, F
Section 2.9
Pyrophoric liquids, hazard category 1
Section 2.10
Pyrophoric solids, hazard category 1
Section 2.11
Self-heating substances and mixtures, hazard categories 1, 2
Section 2.12
Substances and mixtures, which in contact with water, emit flammable gases,
hazard categories 1, 2, 3
Section 2.15
Organic peroxides, Types B, C, D, E, F
Source: Table 1.2, Annex V [22]; Hazard pictogram for symbol: Flame; CLP regula-
tion (EC) no 1272/2008 of the European Parliament and of the Council of 16
December 2008
Most of the time, more than one pictogram may be needed to be used. Article 26
provides the principles of precedence of hazard pictograms. When required to use
more than one pictogram for the same hazard class, the hazard pictogram corre-
sponding to the most severe hazard category for each hazard class is to be included.
Where “GHS01: exploding bomb” for explosives applies “GHS02: flame” for flam-
mable and “GHS03: flame over circle” for oxidizing substances is optional unless it
is compulsory to use more than one pictogram. Similarly, if “GHS06: skull and
cross bones” for acute toxicity applies, then “GHS07: exclamation mark” for skin
and eye irritation need not be given. If the pictogram “GHS05: corrosion” for skin
corrosion or eye damage is applicable, “GHS07” need not be included. Wherever
“GHS08: health hazard” applies for respiratory sensitization, the hazard pictogram
“GHS07” shall not apply.
C. Signal word [23] refers to the level of severity of the potential hazard of the
substance/mixture included in the package. The signal words are “Danger” or
“Warning.” The signal words are assigned for each specific classification and for
each hazard class as included in Parts 2–5 of Annex I. This holds information
such as definition, hazard classification criteria, hazard category, hazard com-
munication, and additional classification consideration for all the hazard classes.
The signal word appropriate for the particular substance/mixture categorized by

the classification criteria is to be used. For example, for flammable liquids, the
criteria for assigning signal word are based on the flash point of the liquid. For
liquids whose flash point is < 23 °C and initial boiling point ≤ 35 °C comes
under Category 1, Category 2 consists of liquids with flash point < 23 °C and
initial boiling point > 35 °C and under Category 3 liquids of flash point ≥ 23 °C
and ≤ 60 °C. The signal word for Category 1 and 2 is “Danger” and for Category
3 is “Warning.” It should be noted that both the signal words cannot be used on
the same label.
D. Hazard statements [24] are assigned to describe the nature of the hazards associ-
ated with the substance/mixture including the degree of hazard often indicated
by H followed by a 3-digit code like “H224.” The hazard statements are given in
Annex III [25] in all the official European languages for all the physical, health,
and environmental hazards. Like the other label elements, hazard statements are
included in Parts 2–5 of Annex I provided based on the hazard classification
criteria of the substance/mixture. To quote an example, flammable liquids of
Category 1 (described in previous section), the hazard statement “H224:
Extremely flammable liquid and vapor” is given. Category 2 and Category 3
flammable liquids have to bear “H225: Highly flammable liquid and vapor” and
“H226: Flammable liquid and vapor” in the label, respectively. In addition to the
hazard statements included in Annex III, new set of 3-digit codes are designated
to certain hazard statements for substances included in Part 3 of Annex VI [26]
and to be used together with hazard statements mentioned previously. As per
“Article 27: Principles of precedence of hazard statements,” if a substance/mix-
ture has several hazards associated with it, then all hazard statements pertaining
to all the different hazards classes should appear on the label unless the state-
ments are repetitive. Propan-1-ol belongs to category 2 flammable liquid which
causes serious eye damage/eye irritation and specific organ toxicity after single
exposure. Hence, the package of propan-1-ol will hold a label with all three
hazard statements “H225: Highly flammable liquid and vapor,” “H318: Causes
serious eye damage,” and “H336: May cause drowsiness or dizziness.”
E. Precautionary statements [27] are phrases that recommend measure(s) to miti-
gate/avoid adverse effects after exposure to hazardous substance/mixture
through usage or disposal. Similar to hazard statements, precautionary state-
ments have letter “P” followed by 3-digit code assigned for different hazard
class and category. The criteria for selection of precautionary statements are
given in Part 1 of Annex IV [26]. The actual statements are given under Part 2
of Annex IV in all the official European languages. The statements are provided
in tables in Parts 2–5 of Annex I [5] along with other label elements. There are
different precautionary statements for general usage, prevention, response, stor-
age, and disposal. For flammable liquids, prevention precautionary statement
will state “P210: Keep away from heat/ sparks/open flames/hot surfaces. No
smoking.” Response precautionary statement will state “P303: If on skin (or
hair),” “P353: Rinse skin with water/shower,” “P361: Remove/Take off immedi-
ately all contaminated clothing,” and “P370+378: In case of fire: Use for
e xtinction.” Storage precautionary statement will state “P403+235: Store in a

well-ventilated place. Keep Cool.” Disposal precautionary statement will state
“P501: Dispose of contents/container to.” As per Article 28 [28] of principles of
precedence of precautionary statements, not more than six precautionary state-
ments should appear on the label unless necessary to communicate the severity
of the hazard. When a substance/mixture is supplied to the general public, a
precautionary statement for the disposal of the substance/mixture as well as the
packaging should appear on the label. In cases where disposal of the substance/
mixture and the package does not produce any hazard to human health or the
environment, no disposal precautionary statement is required. Some statements
shall be omitted if they are redundant or unnecessary for the substance/mixture
or packaging.
Classification Category 1 Category 2 Category 3

GHS pictograms
Signal word Danger Danger Warning

Hazard H224: Extremely H225: Highly H226: Flammable liquid
statement flammable liquid and flammable liquid and and vapor
vapor vapor
Precautionary P210 P210 P210
statement P233 P233 P233
prevention P240 P240 P240
P241 P241 P241
P242 P242 P242
P243 P243 P243
P280 P280 P280
Precautionary P303 + P361 + P353 P303 + P361 + P353 P303 + P361 + P353
statement P370 + P378 P370 + P378 P370 + P378
response
Precautionary P403 + P235 P403 + P235 P403 + P235
statement
storage
Precautionary P501 P501 P501
statement
disposal
Source: Table 2.6.2, Annex I [5]; label elements for flammable liquids; CLP regula-
tion (EC) no 1272/2008 of the European Parliament and of the Council of 16
December 2008
F. Supplemental information [29] should be included in the label for substances/

mixtures for their physical, health, or environmental hazards involved. Statements
to be included are given in Sections 1.1 and 1.2 of Annex II [30] and Part 2 of
Annex III [25]. For substances/mixtures not classified as flammable but may
form flammable/explosive vapor-air mixtures such as halogenated hydrocarbons
and mixtures containing volatile flammable component or mixtures that lose
volatile non-flammable component, a supplemental hazard statement should say
“EUH018: In use, may form flammable/explosive vapor-air mixture.” For sub-
stances in Part 3 of Annex VI [31], supplemental hazard statements are given as
in Table 3.1. Lithium is given with “EUH014: ‘Reacts violently with water”
supplemental hazard statement. Special supplemental statement is to be included
for plant protection products in accordance with Annex V [32] of Directive
91/414/EEC, “EUH401: To avoid risks to human health and the environment,
comply with instructions for use.” The suppliers can include supplemental state-
ments apart from those mentioned above provided it does not contradict or cast
doubt on and make it more difficult to identify the label elements. Statements
that are inconsistent with the classification of substance/mixture such as “non-
toxic,” “non-harmful,” and “ecological” should not appear on the label or the
packaging of substance/mixture. The hazard pictograms of the substances/mix-
tures classified as hazard to ozone layer shall not be included in the label. Signal
words, hazard statements, and precautionary statements are to be included in the
supplemental information section of the label. Mixtures containing lead, cyano-
acrylates, cements, isocyanates, epoxy constituents with an average molecular
weight ≤ 700, active chlorine, cadmium (alloys) used in brazing/soldering, at
least one sensitizing substance, halogenated hydrocarbons, and mixtures not
intended for general public use have supplemental statements derived from Part
3 of Annex III along with the product identifier and the name and address of the
supplier. To quote an example, mixtures containing lead will have supplemental
information “EUH201/201A: Contains lead. Should not be used on surfaces lia-
ble to be chewed or sucked by children. Warning! Contains lead” given in the
label. A sample labeling (core labelling elements) for flammable liquid ethanol
is cited below:
G. Derogations from labelling requirements for special cases [33] are laid down
under Section 1.3 of Annex I [5] which apply for transportable gas cylinders;
gas containers intended for propane, butane, or liquefied petroleum gas; aero-
sols and containers fitted with a sealed spray attachment and with substances or
mixtures classified as presenting an aspiration hazard, metals in massive form,
alloys, mixtures containing polymers, mixtures containing elastomers, and
explosives on the market or those with pyrotechnic effect. A model derogation
for gas cylinders with a water capacity of less than or equal to 150 L would be
that the label can bear the generic name or industrial or commercial name of the
substance/mixture provided the hazardous substances/mixtures are shown in the
body of the cylinder in a legible way.
H. Exemptions from labelling and packaging requirements [34] apply to few pack-
aging of smaller sizes. Article 29 provides the guidelines to follow in such cases.
In packages of substances/mixtures that are so small to meet the requirements of
the label in languages of Member of the State where they are to be marketed, the
label elements can be provided in fold-out labels, on tie-on tags, or on an outer
packaging. The label should bear at least hazard pictograms, product identifier,
and name and telephone number of the supplier. According to Section 1.5.2 of
Annex I [5], in packages whose contents do not exceed 125 ml, the hazard state-
ments and precautionary statements can be omitted provided the contents of the
packaging are classified under one of the following categories: Oxidizing gases
of category 1; Gases under pressure; Flammable liquids of category 2 or 3;
Flammable solids of category 1 or 2; Self-reactive substances or mixtures Types
C to F; Self-heating substances or mixtures of category 2; Substances and mix-
tures which, in contact with water, emit flammable gases of categories 1, 2, or 3;
Oxidizing liquids of category 2 or 3; Oxidizing solids of category 2 or 3; Organic
peroxides types C to F; Acute toxicity of category 4 (if the substances or m
ixtures
are not supplied to the general public); Skin irritation of category 2; Eye irrita-
tion of category 2; Specific target organ toxicity, single exposure of category 2
or 3 (if the substance or mixture is not supplied to the general public); Specific
target organ toxicity, repeated exposure of category 2 (if the substance or mix-
ture is not supplied to the general public); Hazardous to the aquatic environ-
ment, Acute category 1; or Hazardous to the aquatic environment, Chronic
category 1 or 2. Small packages of aerosols dispensers can bear a label attached
to it with the name and address or trademark of the supplier, the symbol “3”
(inverted epsilon) certifying conformity, code markings enabling the filling
batch, inscriptions containing the hazard statement and precautionary statement,
and the net contents by weight and by volume (as per Directive 75/324/EEC).
Precautionary statements can be omitted for substances/mixtures belonging to
Flammable gases of category 2, Reproductive toxicity: effects on or via lacta-
tion, Hazardous to the aquatic environment – Chronic of category 3 or 4 when
they are contained in packages less than 125 ml. The pictogram, hazard state-
ments, and the precautionary statement can be omitted for “corrosive to metal”
substance/mixture when the package does not exceed 125 ml. Soluble packag-
ing intended for single use whose volume do not exceed 25 ml is exempted from
printing the label elements only if they are classified under the hazard categories
mentioned above (Section 1.5.2.1.1 of Annex I [5]). The outer packaging con-
taining the soluble packaging must bear the necessary label elements as cited by
Article 17 [19]. When ready mixed cement and concrete in the wet state is sup-
plied to general public without packaging, it must be accompanied with a copy
of the label elements. Exemptions and provisions for certain mixtures that are
classified as hazardous to the environment are defined under Part 2 of Annex II
[30]. These exemptions are to be determined as per Article 53 [35] once it can
be proven that there would be reduction in the environmental impact. The label
on the packaging of paints and varnishes that contain lead in quantities exceed-
ing 0,15% (weight of lead) to weight of the mixture should have “EUH201:
Contains lead. Should not be used on surfaces liable to be chewed or sucked by
children.” Packages of volume less than 125 ml use “EUH201A – ‘Warning!
Contains lead.”
The label for a substance/mixture has to be updated by the suppliers without
undue delay when any change to the classification and labelling occurs with regard
to the protection of human health and environment. All other changes apart from
those referred before should be updated to the label by the supplier within 18 months.
Plant protective products and adjuvants suppliers shall follow Directives 91/414/
EEC or 98/8/EC.
I. Application of Labels: General Rules for Application of Labels [36]
The label should be attached to one or more surfaces of the package of the sub-
stance/mixture in a horizontally readable manner when set down. The hazard picto-
gram should stand out against the color and presentation of the label. All the label
elements should be clear and indelibly marked and legible and easy to read from the
background of the package. The shape, color, and the size of the pictogram are to be
as set out in previous “Hazard pictogram” section. A separate label is not required
if all the label elements required by Article 17 [19] are shown on the packaging itself.
There are guidelines for location of information on the label [37]. The hazard
pictograms, signal word, hazard statements, precautionary statements, and supple-
mental information are to be located in the same location in the label. The order of
the hazard statements and precautionary statements shall be decided by the supplier,
grouped by language, and placed together on the label. Apart from hazard picto-
grams, colors shall be used in other areas for special labelling requirements. Label
elements provided for in other communities should be placed in the supplemental
information section.
J. Specific Rules for Labelling of Outer Packaging, Inner Packaging, and Single
Packaging [38]: A package containing an outer packaging, an intermediate pack-
aging, and an inner packaging shall be labelled through different regulations. The
outer packaging labels follow the rules on the transport of dangerous goods.
Hazard pictograms required by this regulation and same as in the rules for the
transport of dangerous goods need not be put on the outer packaging. The outer
packaging is not required to be labelled if the intermediate or the inner packaging
is visible through it. Single packages should be labelled with the rules of trans-
port of dangerous goods as well by the labelling and packaging regulations in this
chapter. When the hazard pictograms relate to the same hazard by both regula-
tions, then only the transport of dangerous goods rules apply.
4 Packaging [39]
Packaging should be designed and constructed such that its content cannot leak and
also include specific safety devices prescribed. The packaging and fastening mate-
rial should not be susceptible to damage or form hazardous compounds by its con-
tents. The packaging and fastening must be solid and strong to withhold all the
stresses and strains of handling. The packaging should be solid to ensure it will not
loosen and fitted with replaceable fastenings to refasten to avoid spilling of its con-
tents. The hazardous substances/mixtures supplied to the public should not be
designed in the shape or form that attracts children or mislead customers. They also
should not be in the same form or shape as that of packages containing food, animal
feed, or medicinal or cosmetic product. These packaging should also satisfy with
the requirements of transport of dangerous goods by air, sea, road, rail, or inland
waterways. Packaging containing substances/mixture classified for acute toxicity
(category 1–3), specific target organ toxicity (single and repeated exposure category
1), and skin corrosion (category 1) being supplied to the general public should be
fitted with child-resistant packaging. Packaging of substances/mixtures which pos-
sess aspiration hazard with an exception of aerosols or sealed spray attachment
container should bear child-resistant fastenings. Substances/mixtures containing
either ≥3% methanol or ≥ 1% dichloromethane supplied to the public must be fitted

with child-resistant fastenings. Reclosable packages with child-resistant packaging
should follow guidelines of EN ISO standard 8317 adopted by the European
Committee for standardization (CEN) and the International Standard
Organization (ISO).
Child-resistant fastenings on non-reclosable packages follow CEN standard EN
862. Conformity to these standards should be certified only by laboratories comply-
ing with Standard EN ISO/IEC 17025. If the packaging is sufficiently safe that the
children cannot access its contents, then the tests assigned by the ISO standards
need not be performed. In other cases, a certificate from the ISO-certified laboratory
is needed stating the closure does not require a test to be performed or the closure
has been tested and found to be efficient. Packaging of any capacity have to be fitted
with tactile warning “Danger” when supplied to the general public for containing
substances classified for acute toxicity, skin corrosion, germ cell mutagenicity cat-
egory 2, carcinogenicity category 2, reproductive toxicity category 2, respiratory
sensitization, or specific target organ toxicity categories 1 and 2, aspiration hazard,
or flammable gases, liquids, and solids in categories 1 and 2. This does not apply to
aerosols classified as “extremely flammable aerosols” or “flammable aerosols.” The
technical specifications for tactical devices should conform with EN ISO standard
11683 “Packaging – Tactile warnings of danger – Requirements.”
5 C&L Notification and Inventory
Scope [40] The substances subject to registration according to Regulation (EC) No

1907/2006 [10] and substances classified in Part 3 of Annex VI [31] and to be placed
on the market either on its own or as a mixture above the specified concentrations
are in scope of this regulation.
Manufacturers or importers (notifier(s) and registrant(s)) who place the sub-
stances on the market are obligated to notify the European Chemical Agency (from
here on Agency) for the following information to be included in the classification
and labelling inventory [41]:
(a) The identity of the notifier who places substances/mixtures on the market such
as name, address, telephone number, fax number, e-mail address, contact per-
son, and location of the production site. In case of more than one notifier, the
lead notifier’s name, address, telephone number, fax number, and e-mail address
along with the registration of the other notifiers. The lead notifier should be
identified by another notifier by providing his name, address, telephone num-
ber, fax number, and e-mail address together with the registration submitted by
the lead notifier. When a third party is assigned to notify the Agency, then the
name, address, telephone number, fax number, e-mail address, and contact per-
son of the third party have to provided.
(b) The identity of the substance with one or more information on name or other
identifier of each substance, name(s) in the IUPAC nomenclature or other inter-
national chemical name(s), other names (usual name, trade name, abbrevia-
tion), EINECS or ELINCs number, CAS name and CAS number, other identity
code, molecular and structural formula of each substance, information on opti-
cal activity and typical ratio of (stereo) isomers, molecular weight or molecular
weight range, composition of each substance, degree of purity (%), nature of
impurities (including isomers and by-products), and % of main impurities with
the nature and order of magnitude (ppm, %) of any additives (e.g., stabilizing
agents or inhibitors).
(c) The classification of substance(s) as per Parts 2–5 of Annex I [5].
(d) When a substance is classified in some but not in all hazard classes or differen-
tiations, the reason being lack of data, inconclusive data, or insufficient data has
to be indicated.
(e) Specific concentration limits or M-factors together with hazard assessment (as
per Sections 1, 2, and 3 of Annex I [5] to Regulation (EC) No 1907/2006) [10].
(f) Label elements for the substance(s) with supplemental hazard statements. The
information 1-6 shall not be notified if submitted as part of registration to
Regulation (EC) No 1907/2006 [10], or if already notified by that notifier.
This information should be updated and notified to the Agency when there is a
change to the classification and labelling of the substance in terms of change in the
composition of the initial concentration of one or more of the hazardous constitu-
ents in concentrations at or above the limits or by the substitution or addition of one
or more constituents in concentrations at or above the cutoff value (per Article 15)
[16]. The substances placed on the market on or after 1 December 2010 should be
notified to be included in the inventory within 1 month after placing on the market
and substances placed on the market before this date should be notified to the
Agency before that date. When the same substance gets different entries on the
inventory, the notifiers and registrants must come to an agreement to make a single
entry to the inventory and inform the Agency accordingly.
The classification and labelling inventory is a database established and main-
tained by the Agency. The information is submitted as part of the registration of the
substance (Regulation (EC) No 1907/2006) [10] and is included in the inventory.
The inventory information such as IUPAC nomenclature, name of the substance as
given in EINECS, classification and labelling of the substance, physicochemical
data of the substance together with pathways and environmental fate, results of the
toxicological and ecotoxicological studies, derived no-effect level (DNEL) or pre-
dicted no-effect concentration (PNEC) of the substance, guidance of the safe use of
the substance, and analytical methods to detect a dangerous substance upon expo-
sure to humans and environment is made accessible to the public at free of cost over
the Internet (Article 77(2)€ of Regulation (EC) No 1907/2006) [10]. The exception
is provided where publication of information on the substance can potentially harm
commercial interests of the notifier or registrant (Article 118 of Regulation (EC)
1906/2006) [10].
Apart from the information given above, additional information are made avail-
able free of access to the public over the Internet. These include the degree of purity
of the substance and the identity of impurities and/or additives classified to be dan-
gerous, the total tonnage band (i.e., 1–10 tons, 10–100 tons, 100–1000 tons, or over
1000 tons) within which a particular substance has been registered, study summa-
ries on physicochemical data, toxicological data and ecotoxicological data, trade
name(s) of the substance, IUPAC nomenclature of non-phase-in dangerous sub-
stances, and the IUPAC nomenclature of dangerous substances used as intermedi-
ate, in scientific research and development, and in product and process-related
research. The Agency is obligated to update the information to the inventory as
received. The Agency will have to include the following information on each entry
wherever applicable: harmonized classification and labelling of the substance at
Community level when entered in Part 3 of Annex VI [31], the joint entry between
registrants for the same substance, agreed entry of two or more notifiers or regis-
trants, entry differing from another entry on the inventory for the same substance.
6 Safety Data Sheet
The safety data sheet is a tool for communicating safety information on classified
substances and preparations with relevant chemical safety reports from supply chain
to the downstream user(s). Safety data sheet enables the users to take necessary
measures for human health and safety measures at the workplace and protection of
the environment. It also enables the employer to determine hazardous chemical
agents at the workplace and to assess risk to health and safety of workers using
them. The guidance for compiling safety data sheet is provided in Article 31 and
Annex II of Regulation (EC) No. 1907/2006 [10].
The safety data sheet should be written in a clear and concise manner, and to
achieve that, it has to be prepared by a competent person considering the needs of
the users. Manufactures and importers who place the substances/mixtures on the
market have the responsibility to place a person with appropriate training. The
information can differ with wide range of properties of substances and mixtures.
The information on some properties of no significance or technically impossible to
provide should be stated so with reasons under each heading. The information on
each hazardous property is to be given, and when particular hazard does not apply,
then it should be given with negative results differentiating those with no informa-
tion available. The date of issue of the safety data sheet should be given on the first
page. When it is being revised, the changes shall be indicated as “Revision: (date).”
Safety data sheets are required for substances or its preparations (e.g., metals in
massive form, alloys, compressed gases, etc.) even when there are derogations in
their labelling.
Safety data sheet should be given by the supplier of the substance to its recipient
when the substance is classified as dangerous, persistent, bioaccumulative, toxic,
and those subjected to authorization in accordance with Article 59 of Regulation
(EC) No. 1907/2006 [10]. The supplier should make sure that the chemical safety
assessment information is consistent with what has been provided in the safety data
sheet. The supplier should provide the recipient with safety data sheet on request
when the preparation does not come under dangerous classification but contains ≥
1% individual concentration by weight for non-gaseous preparations and ≥ 0.2% by
volume for gaseous preparations where at least one substance is hazardous to human
health or environmental, individual concentration ≥ 0.1% by weight for non-gas-
eous preparations with at least one substance that is persistent, bioaccumulative and
toxic and when community workplace exposure limits are given for the substance.
The safety data sheet need not be provided for substances/preparations sold or
given to the general public so long as sufficient measures with regard to health and
environmental safety are provided, but this should be provided on request to down-
stream user or distributor. The safety data sheet should be printed in the official
language of the Member of State in which the substance/preparation is on the mar-
ket. All the relevant exposure scenarios obtained from doing the Chemical Safety
report should be placed in the annex of the safety data sheet. The distributor and the
downstream user can include and pass on possible exposure scenarios and use rel-
evant information from the safety data sheet while compiling his/her own. The
safety data sheet is provided free of charge in paper or electronically. The suppliers
should update the safety data sheet without delay when new information affecting
risk management measures and hazards are available, once authorization has been
granted or refused, and once a restriction has been imposed. The new revised data
sheet identified “Revision: (date)” should be provided free of cost on paper or elec-
tronically to formerly supplied end users within the preceding 12 months. Any
update after registration should include the registration number.
Safety data sheet will include the following elements:
(a) Identification of the substance/preparation and of the company/undertaking:
The identity of the substance should be the same as that provided in the label
and consistent with the information given during registration (name and regis-
tration no.). All the uses of the substance or the preparation have to be indi-
cated. When there are many uses, the most important or common uses need to
be indicated with description of the use (e.g., flame retardant, antioxidant, etc.).
In cases where chemical safety reports are required, then all the identified use
is to be provided. The identity of the manufacturer, importer, or distributor who
places the substance or the preparation on the market should be provided
through address, phone number, and e-mail address. This person’s identity
should be in consistent with the details provided during registration. If the per-
son is not located in the Member State where it is placed on market, then the
person responsible in that Member State should provide their full address and
telephone number. An emergency telephone number of the manufacturer,
importer, or distributor and/or relevant advisory body (in case of health infor-
mation) along with notification if this number is only available during office
hours is warranted.
(b) Hazard identification: The substance or its preparation identified as hazardous

to human and environment consistent with classification and labelling inven-
tory should be clearly indicated. Distinction between dangerous and non-
dangerous preparation should be clearly indicated (Directive 1999/45/EC). The
most adverse physicochemical, health, and environmental effects and symp-
toms upon use and misuse of the substance/preparations should be described.
Other hazards which may not be included for classification but contribute to the
hazard like dustiness, cross-sensitization, suffocation, freezing, high potency
for odor or taste, or environmental effects such as hazards to soil-dwelling
organisms, ozone depletion, photochemical ozone creation potential, etc.
should be given.
(c) Composition/information on ingredients: The information on composition and
ingredients helps the end user to identify the hazard. It is not essential to pro-
vide the entire composition, but it is highly encouraged. Substances possessing
hazard to human health and environment should be indicated with their con-
centration, concentration range in preparation, and community workplace
exposure limits. The substances that are persistent and bioaccumulative are
provided with concentration of an individual substance when equal to or greater
than 0,1%. The preparations not classified as dangerous should be indicated
when substances in the preparation are present in ≥ 1% by weight for non-
gaseous preparations and ≥ 0,2% by volume for gaseous preparations of sub-
stances considered hazardous or ≥0,1% by weight of substances which are
persistent, bioaccumulative, and toxic (PBT substance). A substance which
does not meet the classification criteria of hazardous substance can still be
included here if described as “PBT-substance” or “substance with community
workplace exposure limits.” The name, registration no., EINECS or ELINC
no., CAS number, and IUPAC name shall be provided to be helpful. For sub-
stances with generic name, a precise chemical identifier is not necessary. When
the person placing a preparation on the market should feel that the disclosure
of the chemical identity of substance in safety data sheet can compromise the
confidentiality of his/her intellectual property, then he/she may refer to that
substance by the most important functional chemical groups or by an alterna-
tive name. Nevertheless, the chemical nature of the preparation should be com-
municated to ensure safe handling.
(d) First aid measures: Firstly, whether immediate medical attention is required
has to be specified. The information given should be brief and easy to under-
stand by victim, bystanders, and first-aiders. The symptoms and effects have to
summarized. The instructions on what to be done on spot in case of accident
and delayed effects to be expected upon exposure should be indicated. The
information is divided as per the different routes of exposure (inhalation, skin
and eye contact, ingestion). If professional assistance by a doctor is needed or
advised, it should be communicated under this section. It is important to
emphasize on provisions of immediate treatment at workplace to be available
for some substances/preparations.
(e) Firefighting measures: The requirements for fighting a fire due to substance/
preparation should be indicated with suitable extinguishing media, extinguish-
ing media to be avoided, exposure hazards coming from substance/preparation
through combustion and resulting gases, and special protective equipment for
firefighters.
(f) Accidental release measures: Accidental release measures such as some per-
sonal precautions such as removal of ignition sources; provision of sufficient
ventilation/respiratory protection; control of dust; prevention of skin and eye
contact; environmental precautions such as keeping away from drains, surface,
and groundwater and soil; possible need to alert neighborhood; methods for
cleaning up such as use of absorbent material (sand, diatomaceous earth, acid
binder, universal binder, sawdust); reduction of gases/fumes with water; and
dilution are to be included in this section of safety data sheet along with indica-
tors such as “never use, neutralize with, etc.”.
(g) Handling and storage: The information in this section relates to the protection
of health, safety, and environment together with assisting in devising suitable
working procedures and organizational measures. Precautions and advice on
safe handling like containment, local and general ventilation, measures to pre-
vent aerosol and dust generation and fire, measures required to protect the envi-
ronment (e.g., use of filters or scrubbers on exhaust ventilation, bunded area,
measures for collection and disposal of spillages, etc.), and specific require-
ments like procedures or equipment which are prohibited or recommended
relating to the substance or preparation with a brief description are given under
this section. Storage conditions relating to type of material to be used in pack-
aging of substance/preparation, design for storage rooms or vessels with reten-
tion walls and ventilation, quantity limits under storage, incompatible materials,
storage temperature and humidity limit/range, light, inert gas, special electrical
equipment, and prevention of static electricity should be advised. Products
designed for specific use should have detailed and operational instructions and
referenced by the industry.
(h) Exposure controls/personal protection: The occupational exposure limit values
and/or biological limit values as given by the Member of the State where the
substance/preparation are placed on the market are provided with information
on recommended monitoring procedures. The derived no-effect level (DNEL)
or predicted no-effect concentration for substances and all the constituents of
substances used in the preparation should be given for exposure scenarios.
Exposure controls, meaning the full range of specific risk management mea-
sures to be taken in order to minimize worker and environmental exposure, are
provided under this section of the safety data sheet. Occupational exposure
controls are used for carrying out risk to health and safety of workers for the
substance/preparation. The hierarchy is such that first comes design of appro-
priate work processes and engineering controls with the use of adequate equip-
ment and materials; second, the application of collective protection measures
at source, such as adequate ventilation and appropriate organizational mea-
sures; and last, where exposure cannot be prevented, the use of individual
p rotection with personal protection equipment should be recommended. A risk

assessment must be carried out to provide suitable information on control mea-
sures to be effective (Article 4 of Directive 98/24/EC). Specification on equip-
ment to provide adequate protection in case of individual protection measures
is required. Council Directive 89/686/EEC of 21 December 1989 accounts on
laws relating to personal protective equipment: respiratory protection such as
self-contained breathing apparatus, adequate masks, and filters to be used for
dangerous gases, vapors, or dust; hand protection using gloves when handling
substances/preparations together with type of material of the gloves and amount
and duration of dermal exposure; safety glasses, goggles, and face shield in
terms of eye protection; and aprons, boots, and full protective suit with specify-
ing type and quality for skin protection. Environmental exposure control mea-
sures are a commitment to be fulfilled by the employer under Community
environmental protection legislation.
(i) Physical and chemical properties: All information on substance/preparation
regarding the appearance, odor, pH, boiling point/range, flash point, flamma-
bility, explosive properties, oxidizing properties, vapor pressure, relative den-
sity, solubility, water solubility, partition coefficient (n-octanol/water),
viscosity, vapor density, and evaporation rate should be provided in order to
install and enable proper control measures. Other safety parameters such as
miscibility, fat solubility (solvent, oil to be specified), conductivity, melting
point/melting range, gas, auto-ignition temperature, etc. also should be indi-
cated in this section. These properties are to be determined using testing meth-
ods as given by Commission Regulation. When a particular hazard does not
apply, then it should be indicated whether the results are negative or no infor-
mation is available. For preparations, it is necessary to give properties of all the
components in it.
(j) Stability and reactivity: The stability of the substance/preparation and hazard-
ous reactions occurring under certain conditions and when released into the
environment is provided in this section. Conditions and materials that might
cause dangerous reaction such as temperature, pressure, light, shock, water, air,
acids, bases, oxidizing agents, or any other specific substance are to be given,
as well as hazardous products generated upon decomposition together with
need for stabilizers, possibility of exothermic reaction, change in the physical
appearance of the substance/preparation, products formed upon contact with
water, and possibility of degradation of unstable products.
(k) Toxicological information: Complete and comprehensible description of vari-
ous toxicological health effects when exposed to the substance/preparation is
provided in this section. The information included will be dangerous-to-health
effects upon exposure to the substance/preparation concluded from test data
and experience. This should also be inclusive of delayed, immediate, and
chronic effects from short- and long-term exposure such as sensitization, nar-
cosis, carcinogenicity, mutagenicity, and reproductive toxicity (developmental
toxicity and fertility). The routes of exposure inhalation, ingestion, and skin
and eye contact and the symptoms related to physical, chemical, and
toxicological characteristics should be given in this section. Information on

potential effects should be included such as toxicokinetics, metabolism and
distribution, acute effects (acute toxicity, irritation, and corrosivity), sensitiza-
tion, repeated dose toxicity, and CMR effects (carcinogenicity, mutagenicity,
and toxicity for reproduction).
(l) Ecological information: The description of the possible effects and behavior
and environmental fate of the substance/preparation in air, water, or soil along
with the test data (e.g., LC50 fish ≤ 1 ml) is given under this section. This
information should be the same when compared with those provided in the
registration and Chemical Safety Report of the substance/preparation.
Ecotoxicity includes data on aquatic toxicity, both acute and chronic for fish,
crustaceans, algae, and other aquatic plants, and toxicity data on soil micro-
and macro-organisms and other environmentally relevant organisms, such as
birds, bees, and plants should be included. If the substance/preparation pos-
sesses inhibitory effects on the activity of micro-organisms, the possible impact
on sewage treatment plant should be given. Mobility data when released into
the environment includes known or predicted known or predicted distribution
to environmental compartments, surface tension, and absorption/desorption.
The persistence and degradability relate to the potential of the substance/prepa-
ration to degrade in environmental media by biodegradation, oxidation, hydro-
lysis, or other such processes. Degradation half-life is to be provided where
available. The degradation of substance/preparation in sewage treatment plants
is also to be provided. The potential of the substance/preparation to accumulate
in biota and pass through the food chain is known as bioaccumulative potential.
This is measured in terms of octanol-water partition coefficient (Kow) and bio-
concentration factor (BCF) to be provided under this section of the safety data
sheet. The persistent, bioaccumulative, and toxicity assessment data should
also be included here. Any other adverse effects such as ozone depletion poten-
tial, photochemical ozone creation potential, endocrine-disrupting potential,
and/or global warming potential might be mentioned. The ecotoxicological
information should also be mentioned in accidental release measures, handling
and storage, disposal considerations, transport information, and regulatory
information of the safety data sheet.
(m) Disposal considerations: When the disposal of the substance/preparation pos-
sesses danger, then description of its residue and safe handling should be pro-
vided. The appropriate methods of disposal of the substance/preparation and
contaminated packaging should be specified. This waste management specifi-
cation should be consistent with exposure management in Chemical
Safety Record.
(n) Transport information: The precautions to be taken by the user in terms of
transport of the substance/preparation within or outside his/her premises are
given under this heading. The transport regulations are provided by the
International Maritime Dangerous Goods (IMDG) Code (sea route), Agreement
concerning the International Carriage of Dangerous Goods by Road (ADR)
code, RID code (by rail), and ICAO/IATA code (by air). The UN number, class,
proper shipping name, marine pollutant, and other applicable information

should be provided during the transport of dangerous substance/preparation.
(o) Regulatory information: The chemical safety assessment for the substance/
preparation should be indicated. The health, safety, and environmental infor-
mation should be shown on the label. The specific provisions related to protec-
tion of man or the environment at the community level should be stated. The
laws or measures which implement these provisions should also be mentioned.
(p) Other information: Any other information being of importance to the health
and safety of the user and for the protection of the environment such as relevant
R phrases, training advice, recommended restrictions on use, written refer-
ences, technical contact point, and data source used for compiling safety data
sheet should be provided. A revised safety data sheet should also indicate what
has been added, deleted, or revised under this section unless indicated
elsewhere.
Sample Safety Data Sheet
SECTION 1: IDENTIFICATION
Product identifier: Ethanol

Synonyms: Ethyl alcohol; ethyl hydrate
CAS No: 64-17-5
Details of the supplier of the safety data sheet:
Supplier:
Name
Address
Information contact
E-Mail (competent person)
Emergency telephone number:
SECTION 2: HAZARD(S) IDENTIFICATION
Classification:
Classification according to Regulation (EC) No Classification procedure

1272/2008 [CLP]
Flam. Liq. 2, H225 On basis of test data
Eye Irrit. 2A, H319 Practical experience/human evidence
Label elements:
Labelling according to Regulation (EC) No 1272/2008 [CLP/GHS]
Hazard pictograms
GHS02 GHS07 GHS08
Signal word:
Danger
Hazard statements:
H225 Highly flammable liquid and vapor
Precautionary statements:
P210 Keep away from heat, hot surfaces, sparks, open flames and other ignition
sources. No smoking.
P280 Wear protective gloves/protective clothing/eye protection/face protection.
P308+P311 IF exposed or concerned: Call a POISON CENTER/doctor.
P301+P330 IF SWALLOWED: Rinse mouth.
P303+P361+P353 IF ON SKIN (or hair): Take off immediately all contaminated clothing.
Rinse skin with water/shower.
P304+P340 IF INHALED: Remove person to fresh air and keep comfortable for
breathing.
Supplemental Hazard information:
ECTION 3. COMPOSITION/INFORMATION
S
ON INGREDIENTS
Component CAS No. Weight %

Ethyl alcohol 64-17-5 60–70
SECTION 4: FIRST AID MEASURES
Description of first aid measures

General advice
Following inhalation
Following skin contact
Following eye contact
Following ingestion
Self-protection of the first aider
Most important symptoms and effects, both acute and delayed
Symptoms
Effects
Indication of any immediate medical attention and special treatment needed
Notes for the doctor
Special treatment
SECTION 5: FIREFIGHTING MEASURES
Extinguishing media
Suitable extinguishing media
Unsuitable extinguishing media
Special hazards arising from the substance or mixture
Hazardous combustion products
Advice for firefighters
Additional information
SECTION 6: ACCIDENTAL RELEASE MEASURES
Personal precautions, protective equipment, and emergency procedures

For non-emergency personnel
Protective equipment
Emergency procedures
For emergency responders
Personal protective equipment
Environmental precautions
Methods and material for containment and cleaning up
Reference to other sections
SECTION 7: HANDLING AND STORAGE
Precautions for safe handling

Conditions for safe storage, including any incompatibilities
Specific end uses
Recommendations
Specific end uses
ECTION 8: EXPOSURE CONTROLS/

S
PERSONAL PROTECTION
Control parameters
Exposure controls
SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES
Information on basic physical and chemical properties
Appearance: Physical state: Color: Odor: Odor threshold:
Value Concentration Method Temperature Pressure Remark

pH
Melting point/
freezing point
Initial boiling point/
boiling range
Value Concentration Method Temperature Pressure Remark

Flash point
Evaporation rate
Flammability (solid,
gas)
Vapor pressure
Vapor density
Relative density
Solubility(ies)
SECTION 10: STABILITY AND REACTIVITY
Reactive Hazard
Stability
Conditions to avoid
SECTION 11: TOXICOLOGICAL INFORMATION
Acute toxicity
Delayed and immediate effects as well as chronic effects from short- and long-
term exposure
SECTION 12: ECOLOGICAL INFORMATION
Ecotoxicity
Persistence and degradability
Bioaccumulation/accumulation
SECTION 13: DISPOSAL CONSIDERATIONS
Waste disposal method

SECTION 14: TRANSPORT INFORMATION
UN No.
UN Proper shipping name
Transport hazard class(es)
Packing group
SECTION 15: REGULATORY INFORMATION
Safety, health and environmental regulations/legislation specific

EU regulations
Authorizations and/or restrictions on use
Authorizations
Restrictions on use
Restrictions of occupation
Other National regulations
SECTION 16: OTHER INFORMATION
Indication of changes
Abbreviations and acronyms
Key literature references and sources for data
Classification for mixtures and used evaluation method according to regulation
(EC) 1207/2008 [CLP]
Relevant R-, H-, and EUH-phrases (number and full text)
Training advice
Further information
Bibliography
1. legislation.gov.uk – Regulation (EC) No 1272/2008 of the European Parliament and of the

Council. 16 Dec. 2008, https://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:200
8:353:0001:1355:EN:PDF. Accessed 30 Jun. 2020
2. Chemsafetypro, https://www.chemsafetypro.com/Topics/EU/CLP_Regulation_EC_
No_1272_2008.html. Accessed 30 Jun. 2020

Council. 16 Dec. 2008, http://www.legislation.gov.uk/eur/2008/1272/article/1/adopted.
Accessed 27 Jun. 2020
Council. 16 Dec. 2008, http://www.legislation.gov.uk/eur/2008/1272/annex/i/adopted.
Council. 18 Dec. 2006, https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:200
7:136:0003:0280:en:PDF. Accessed 12 May 2020
Accessed 27 May. 2020
Council. 16 Dec. 2008, http://www.legislation.gov.uk/eur/2008/1272/annex/vi/adopted.
Council. 16 Dec. 2008, http://www.legislation.gov.uk/eur/2008/1272/annex/v/adopted.
Council. 16 Dec. 2008, http://www.legislation.gov.uk/eur/2008/1272/annex/iii/adopted.
Council. 16 Dec. 2008, http://www.legislation.gov.uk/eur/2008/1272/annex/iv/adopted.
Council. 16 Dec. 2008, http://www.legislation.gov.uk/eur/2008/1272/annex/ii/adopted.
Council. 16 Dec. 2008, http://www.legislation.gov.uk/eur/2008/1272/annex/vi/adopted.
Council. 16 Dec. 2008, http://www.legislation.gov.uk/eur/2008/1272/annex/v/adopted.
Accessed 1 Jul. 2020
EU 2015/863: Restriction of Hazardous
Substances (RoHS) -3
Harini Sriram and Indumathy Jagadeeswaran
1 Introduction
The European Parliament and the Council of the European Union, with regard to the
Treaty on the Functioning of the European Union, a proposal from the European
Commission, an opinion of the European Economic and Social Committee, an opin-
ion of the Committee regions, and in accordance with the legislative procedure, has
laid down restrictions on the use of hazardous substances in electrical and electronic
equipment (EEE). This enables to prevent the occurrence of any barriers between
the safety of human health and environment and trade and competition. The Council
Resolution stresses that the Commission should pursue measures to combat cad-
mium pollution by restricting its use and encouraging alternatives. The Member
States cannot effectively protect the environment and human health against pollut-
ants because of the transboundary effects of pollutants. Hence, the European
Parliament and Council recommend that measures should be taken at Union level
such that the organic pollutants such as dioxins and furans should be identified and
reduced and ultimately eliminated whenever possible [1]. The collection, treatment,
recycling, and disposal of waste of EEE are essential to reduce problems arising
from heavy metals and flame retardants. In spite of these regulations, waste from
EEE (mercury, cadmium, lead, chromium VI, polybrominated biphenyls (PBB))
and polybrominated diphenyl ethers (PBDE) would be present in the disposal even
if collected and recycled separately and pose a risk to human health and the environ-
ment [2]. The regulation takes into account the technical and economic feasibility of
small and medium-sized enterprises (SMEs) to find an effective way of ensuring the
H. Sriram (*)
I. Jagadeeswaran
298 H. Sriram and I. Jagadeeswaran
reduction and substitution of hazardous substances in EEE. By restricting it can

enhance profitability and the possibility of recycling waste EEE and reducing risk
to health and environment at the recycling plants. In the measures provided under
this regulation, international guidelines have to be considered and compactions and
the assessment of scientific and technical information recommended. The measures
have to be constantly reviewed and updated to achieve the chosen level of protection
of human health and environment. Particularly, risks due to hexabromocyclododec-
ane, bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), and dibutyl
phthalate (DBP) should be prioritized. Therefore, Annexes XIV (List of substances
subject to authorization) and XVII (Restrictions on the manufacture, placing on the
market, and use of certain dangerous substances, preparations, and articles) to
Regulation (EC) No 1907/2006 of the European Parliament and of the Council
should be periodically reviewed and updated. This Directive also gives the general
Union waste management legislation [3]. Definitions are also included to specify
the scope and multipurpose character to determine the functions of EEE based on its
characteristics, design, and marketing. Ecological designing specifications of EEE
in energy-related products such as batteries and accumulators are also included in
this directive, along with other Directives [4, 5]. Based on the scientific evidence it
should be examined that substances classified as hazardous owing to their very
small internal surface and structure such as nanomaterials and substituted with more
environmentally friendly alternatives. This regulation holds the list of restricted
substances in Annex II in coherence with Regulation (EC) No 1907/2006. This
directive should not prevent the development of renewable energy technologies that
cause no negative impact on health and the environment [6]. The substitutions of
hazardous substances in EEE should consider the health and safety of users.
Exemptions from these substitutions are made if it is not possible from a scientific
and technical point of view, taking into account the availability of substitutes and
the socioeconomic impact. The situation of SMEs should also be taken into account,
and whether the negative environmental, health, and consumer safety impacts of the
substitution outweigh the environmental, health, and consumer safety benefits of
the substitution. This also applies to materials used in medical devices. The safety
of the potential substitute for a medical or in vitro diagnostic device is not demon-
strated, then it should be regarded to have a negative impact on socioeconomic,
health, and consumer safety [7]. The exemptions for substitutions should be limited
in order to facilitate the phasing-out of hazardous substances in EEE. The procedure
for harmonizing conformity in the assessment of EEE is given under this directive
and should conform with the Union legislation [8]. The EEE should be marked with
CE markings when marketed and the market surveillance mechanisms govern the
requirements for the accreditation and marketing of these products [9]. The
Commission is empowered to implement power to ensure conformity with regard to
guidelines laid out under this directive. The restrictions under this directive are gov-
erned both by the Member States and at Union Level.
EU 2015/863: Restriction of Hazardous Substances (RoHS) -3 299
2 Scope
This Directive applies to EEE listed under Annex I: Large household appliances,
Small household appliances, IT, and telecommunications equipment, Consumer
equipment, Lighting equipment, Electrical and electronic tools, Toys, leisure, and
sports equipment, Medical devices, Monitoring and control instruments including
industrial monitoring and control instruments, Automatic dispensers, and other EEE
not covered by any of the categories above. The EEE outside the scope of Directive
2002/95/EC and that does not comply with this directive should not be available on
the market after 22 July 2019. This directive will apply to the requirements of Union
legislation on safety and health, and on chemicals, and Union waste management
legislation. This directive does not apply to equipment used for security of the
Member States such as arms, munitions, and war material intended for specifically
military purposes, equipment sent into space, equipment that is specifically designed
and installed to be a part of another type of equipment that is excluded or that does
not fall within the scope of this Directive, large-scale stationary industrial tools,
large-scale fixed installations, means of transport for persons or goods, excluding
electric two-wheel vehicles, nonroad mobile machinery made available exclusively
for professional use, active implantable medical devices, photovoltaic panels to pro-
duce energy from solar light for public, commercial, industrial, and residential
applications, and equipment designed for research and development only available
on a business-to-business basis.
3 Restriction Through Prevention
The Member States should make sure that EEE and their cables and spare parts do
not contain substances such as lead (0.1%), mercury (0.1%), cadmium (0.01%),
hexavalent chromium (0.1%), polybrominated biphenyls (PBB) (0.1%), polybromi-
nated diphenyl ethers (PBDE) (0.1%), DEHP (0.1%), BBP (0.1%), DBP (0.1%),
and diisobutyl phthalate (DIBP) (0.1%). The restriction of DEHP, BBP, DBP, and
DIBP in EEE and their spare parts applies to medical devices, in vitro diagnostic
medical devices, and medical and industrial monitoring and control instruments,
from 22 July 2021. The restriction of DEHP, BBP, DBP, and DIBP does not apply
to cables or spare parts of EEE used in the repair, reuse, and updating of functional-
ities or capacity before 22 July 2019. The restriction of DEHP, BBP, and DBP does
not apply to toys, which are governed by Regulation (EC) No 1907/2006 [10, 11].
This list of substances applies to medical devices, monitoring and control instru-
ments, in vitro diagnostic medical devices, and industrial monitoring and control
instruments, placed on the market from 22 July 2014, 22 July 2016, and 22 July
2017 respectively. The restriction of this list of substances should not apply to cables
and spare parts used in the repair, reuse, and updating of the functionalities and
capacity of EEE (before 1 July 2006), medical devices (before 22 July 2014), in
vitro diagnostic medical devices, (before 22 July 2016), monitoring and control
instruments (before 22 July 2014), industrial monitoring and control instruments
(before 22 July 2017), and the EEE placed on the market that are already exempt.
This list of substances does not apply to reused and recovered spare parts of EEE
placed on the market before 1 July 2006 and fitted into equipment on the market
from 1 July 2016, only if the reuse happens after audit in a closed-loop business-to-
business return system and the customer is notified. The EEEs exempted from this
substance restriction are given in Annex II and III of this derivative. To quote a few
examples: mercury in single capped (compact) fluorescent lamps, lead in the glass
of cathode ray tubes, cadmium and its compounds in one shot pellet type thermal
cut-offs, etc.
4 daptation of the Annexes to Scientific

A
and Technical Progress
To adapt Annexes III and IV, the Commission should adapt some measures to indi-
vidual delegated acts. The inclusion of hazardous substances in EEEs that are
exempt should ensure that it does not weaken the environmental and health protec-
tion. It should also be considered that the elimination or substitution of hazardous
substances listed under Annex II via design changes should not make it scientifi-
cally or technically impractical, the substitution should be reliable, and the negative
impact on the environment, health, and consumer safety should outweigh the ben-
efits. The materials and components of EEE added to Annexes III and IV should
take into account the availability of the substitutes and socio-economic impacts of
the substitution. If these conditions are not fulfilled, these materials and components
can be deleted from the list. The measures are adapted to include materials and
components of EEE for large household appliances, small household appliances, IT
and telecommunications equipment, consumer equipment, lighting equipment,
electrical and electronic tools, toys, leisure and sports, and automatic dispenser
equipment have validity of up to 5 years, and for medical devices, monitoring and
control instruments, including industrial monitoring and control instruments, a
validity of 7 years is granted. The exemptions laid out for applications in Annex III
(e.g., mercury in single-capped (compact) fluorescent lamps, lead in the glass of
cathode ray tubes, cadmium and its compounds in one shot pellet type thermal cut-
offs, etc.) as at 21 July 2011, the maximum validity period (may be renewed) for
large household appliances, small household appliances, IT and telecommunica-
tions equipment, consumer equipment, lighting equipment, electrical and electronic
tools, toys, leisure and sports, and automatic dispenser equipment is 5 years from 21
July 2011 and for medical devices, monitoring and control instruments, including
industrial monitoring and control instruments, is 7 years unless a shorter period is
specified. The 7-year validity applies to applications included under Annex IV of
this Directive (e.g., lead, cadmium, and mercury in detectors for ionizing radiation,
mercury in reference electrodes: low chloride mercury chloride, mercury sulfate

and mercury oxide, lead, cadmium, and mercury in infra-red light detectors, etc.)
unless a shorter period is specified. The Commission should provide a harmonized
application format with guidelines for exemptions. The application should be sub-
mitted to the Commission for granting, renewing, or revoking an exemption by a
manufacturer, the authorized representative of a manufacturer, or any economic
operator in the supply chain with the name, address, and contact details of the appli-
cant; information on the material or component and the specific uses of the sub-
stance in the material and component for which an exemption, or its revocation, is
requested, and its particular characteristics; verifiable and referenced justification
for an exemption, or its revocation; an analysis of possible alternative substances,
materials, or designs on a life-cycle basis, including information about independent
research, peer-review studies, and development activities by the applicant, and an
analysis of the availability of such alternatives; information on the possible prepara-
tion for reuse or recycling of materials from waste EEE, and on the provisions relat-
ing to the appropriate treatment of waste [12]; the proposed actions to develop,
request the development, and/or to apply possible alternatives including a timetable
for such actions by the applicant; an indication of the information that should be
regarded as proprietary accompanied by verifiable justification; a proposal with a
precise and clear wording for the exemption and a summary of the application. The
renewal application for an exemption should be made 18 months before the current
exemption expires and the Commission should process the renewal within 6 months
before the expiry unless other deadlines are specified. The Commission should
notify the receipt of application within 15 days of the receiving date, inform the
Member of States of the receipt of application with its details, write a summary of
the application to notify the public, and evaluate the application. The Commission
should make decisions after consulting economic operators, recyclers, treatment
operators, environmental organizations, and employee and consumer associations
and make the comments received publicly available. In the case of rejection/revoca-
tion of the renewal application, the existing exemption is deemed valid until
12–18 months after the decision date.
5 eview and Amendment of the List of Restricted

R
Substances in Annex II
The Commission should periodically review and amend the list of restricted sub-
stances in Annex II in coherence with other legislations and made it publicly avail-
able [13]. These points should be considered after consultation with economic
operators, recyclers, treatment operators, environmental organizations, and
employee and consumer associations including: whether a substance is very small
or has a very small internal or surface structure, causes a negative impact during
EEE waste management operations, including the possibility of reuse and recycling,
uncontrolled or diffuse release of substances into the environment gives rise to haz-
ardous residues, or transformation or degradation products through the preparation
for reuse, recycling, or other treatment of materials from waste EEE, unacceptable
exposure of workers involved in waste EEE collection or treatment processes, a
substance is replacable by substitutes or alternative technology. The proposal to
review and amend should at least the following information: precise and clear word-
ing of the proposed restriction, references and scientific evidence for the restriction,
information on the use of the substance or the group of similar substances in EEE,
information on detrimental effects and exposure, in particular during waste EEE
management operations, information on possible substitutes and other alternatives,
their availability and reliability, justification for considering a Union-wide restric-
tion, and socioeconomic assessment.
6 Obligations of Manufacturers
The manufacturers have an obligation to ensure that the EEE is designed and manu-
factured as per requirements set out by legislation. The technical documentation and
internal production control should be created, updated, and maintained [14].
Manufacturers have to draw up an EU declaration of conformity and affix the CE
marking on the finished product. The conformity assessment as per other Union
legislations has to be demonstrated and documentation has to be drawn. The techni-
cal documentation and EU declaration conformity has to be kept for 10 years after
the EEE has been placed on the market. The nonconforming products and recalled
products have to be documented and the distributors informed. The type, batch,
serial number, and other identification elements, along with the manufacturer’s
information, such as name, registered trade name or registered trade mark, and the
contact address to be given on the EEE and in the case of a small EEE the details
have to be on the accompanying package or document. Other Union legislation
pertaining to the affixing of the manufacturer’s name and address should be fol-
lowed as well. When an EEE is found not to confirm to this Directive then the manu-
facturer should take the responsibility to make corrective measures, and to recall
and inform the national authorities of the Member States in which it is marketed.
The manufacturers have to provide all the information and documents to demon-
strate the conformity of the EEE under this Directive to a competent national author-
ity of the Member States in the language comprehensible to the authorities and
cooperate with them.
7 Obligations of Authorized Representatives
The manufacturers can appoint authorized representatives with a written mandate.

This should not include the technical documentation. The authorized representative
is obligated to perform the tasks assigned as in the mandate. These shall include:
maintaining the EU declaration of conformity and technical documentation at the
disposal of the national authorities for 10 years, providing these documents to the
national authorities on request, and cooperating with the authorities to ensure com-
pliance with this Directive.
8 Obligations of Importers
Importers have an obligation to place on the market only those EEEs that comply
with this Directive. The importers should also make sure that the conformity assess-
ment, technical documents, and CE markings as per the regulations are done cor-
rectly by the manufacturer. If the importers feel that the EEE to be placed on the
market is not up to the conformity standards they have to inform the manufacturer
and the market surveillance authorities. The importers have to indicate their name,
registered trade name and trademark, and contact address on the EEE and if the EEE
is too small then it should be given in a separate accompanying document or pack-
age. The importers also have to keep a register of noncompliance EEEs and EEE
recalls, and inform the distributors of the same. If the importers discover that the
EEE does not conform to this Directive, they have an obligation to make sure that
the corrective measures are taken or withdrawn or recalled, and also inform the
national authorities of the Member States. The importer have to maintain the records
of EU declaration conformity and technical documentation for 10 years and provide
them with competent national authority upon request.
9 Obligations of Distributors
The distributors have to take appropriate care that the EEE made available on the
market by them has proper CE markings and that the required document in the lan-
guage is easily understood by the end-users in the Member State. The distributor is
also obligated to confirm that the manufacturer and importer have complied with the
requirements under this Directive. The nonconforming EEE should not be made
available on the market by the distributor until it is corrected and the manufacturer,
importer, and market surveillance authorities have been informed. The distributors,
at the request of the national authority, should provide all information and docu-
mentation to demonstrate the conformity of the EEE.
Member States should ensure that an importer/distributor who places the EEE on
the market is also considered a manufacturer under this Directive. The importers/
distributors are subjected to the same obligations of the manufacturer when he/she
places an EEE on the market under their name or trademark or modifies an EEE
already on the market in that it requires compliance.
Member States should ensure that economic operators identify who has supplied
them with an EEE and to whom they have supplied EEEs for 10 years after placing
the EEE on the market to the market surveillance authorities.
10 EU Declaration of Conformity
The EU declaration of Conformity is the document that states whether the EEE
meets the requirement set out under this derivative. The EU declaration of Conformity
should have a model structure as given in this section and contain elements specified
in Annex VI. It should be updated and translated into (a) language(s) required by the
Member States. A single document should be drawn up in cases where other Union
legislations require a conformity assessment procedure similar to this Directive that
applies to the EEE. Once the EU declaration of conformity is drawn up it is the
responsibility of the manufacturer to take responsibility for the compliance. It can be
presumed by the Member States that the EEE marked with CE complies with this
Directive. The materials, components, and EEE on which the compliance test and
measurements have been performed should also conform with this Directive.
EU Declaration of Conformity
1. No … (unique identification of the EEE):
2. Name and address of the manufacturer or his authorized representative:
3. This declaration of conformity is issued under the sole responsibility of the man-
ufacturer (or installer):
4. Object of the declaration (identification of the EEE allowing traceability. It may
include a photograph, where appropriate):
5. The object of the declaration described above is in conformity with Directive
2011/65/EU of the European Parliament
and of the Council of 8 June 2011 on the restriction of the use of certain haz-
ardous substances in electrical and
electronic equipment (*):
6. Where applicable, references to the relevant harmonized standards used or refer-
ences to the technical specifications in
relation to which conformity is declared:
7. Additional information:
Signed for and on behalf of: .............................................................................
........ .......................................................................................
(place and date of issue):
(name, function) (signature)
11 Rules and Conditions for Affixing the CE Marking
The general principles for CE markings are given under a separate regulation [15].
The CE marking should be fixed visibly, legibly, and indelibly on the EEE or on the
data plate unless it is not possible owing to the size and nature of the EEE. In that
case it should be fixed to the packaging or accompanying document. It should be
fixed before the EEE is available on the market. Member States should oversee the
rules governing CE markings being correctly applied and actions taken when CE
markings are done improperly. Member States apply penalties for infringements,
including criminal sanctions. The penalties should be congruent with the gravity of
the offence and discourages improper use.
12 Formal Objection to a Harmonized Standard
When a harmonized standard does not entirely satisfy the requirements it governs,
the Member States or the Commission can escalate it to the Committee, giving rea-
sons [16]. The Committee is formed by representatives of Member States and
chaired by a representative of the Commission [17]. The opinion of the Committee
is given on the notified issue after consulting with other European standardization
bodies. After receiving the opinion, the Commission should publish, not publish,
publish with restriction, maintain, maintain with restriction, or withdraw the stan-
dard. The Commission should notify the European standardization body and if
required, request the revision of the harmonized standards. The market surveillance
should be carried out by Member States following the appropriate regulations [18].
13 Exercise, Revocation, and Objection to Delegation
To achieve the objectives of this Directive, the Commission holds the power to
adopt delegated acts [19]. The European Parliament should be notified of this
empowerment and the Council and can extend it to a period of 5 years. The
Commission should present a report 6 months before the end of the 50year period.
This delegation is automatically renewed unless the European Parliament or Council
revokes it. Whichever institution has decided to revoke the delegation of power with
possible reasons should inform the other institution as well as the Commission
before the final decision has been taken. Once decided, the delegation of power will
cease immediately or at a later specified date and it should not interfere with the
other delegated acts in force. This revocation should be published in the Official
Journal of the European Union. The European Parliament or the Council can object
to a delegated act within 2 months of the notification date and that period is extend-
able by another 2 months. Within the expiry of this period if neither the European
Parliament nor the Council objected to the delegated act it should be published and
in force on the stated date. When there is an objection by either institution with
proper reasons, the delegated act should not be published.
14 Penalties, Review, Repeal, and Entry into Force
The Member States should lay down effective and appropriate penalties to violation
of provisions under this Directive and ensure their implementation. These penalties
should be communicated along with any subsequent amendments to the Commission
without any delay. By 22 July 2014, the Commission would have examined and
amended this Directive and reported it to the European Parliament and the Council
[20, 21]. Another general review has to be carried out by 22 July 2021 and submit a
report or if applicable a legislative proposal. The Directive 2002/95/EC was
amended and repealed from 3 January 2013. The repealed acts should be under-
stood as a reference for this Directive as given under Annex VII. Any Directive has
to be entered into force on the 20th day following its publication in the Official
Journal of the European Union.
References
1. Regulation (EC) No 850/2004 of the European Parliament and of the Council of 29 April 2004
on persistent organic pollutants.
2. Directive 2002/96/EC of the European Parliament and of the Council of 27 January 2003 on
waste electrical and electronic equipment (WEEE).
3. Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008
on waste and repealing certain Directives and Regulation (EC) No 1907/2006 of the European
Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation,
Authorization and Restriction of Chemicals (REACH), establishing a European Chemicals
Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93
and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and
Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC.
4. Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009
establishing a framework for the setting of eco-design requirements for energy-related
products.
5. Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006
on batteries and accumulators and waste batteries and accumulators and Regulation (EC) No
850/2004.
6. Directive 2009/28/EC of the European Parliament and of the Council of 23 April 2009 on the
promotion of the use of energy from renewable sources.
7. Council Directive 93/42/EEC of 14 June 1993 concerning medical devices (1) and Directive
98/79/EC of the European Parliament and of the Council of 27 October 1998 on in vitro diag-
nostic medical devices.
8. Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a
common framework for the marketing of products.
9. Regulation (EC) No 765/2008 of the European Parliament and of the Council of 9 July 2008
setting out the requirements for accreditation and market surveillance relating to the marketing
of products.
10. Commission delegated directive (EU) 2015/863 of 31 March 2015 amending Annex II to
Directive 2011/65/EU of the European Parliament and of the Council as regards the list of
restricted substances.
11. Entry 51 of Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of
the Council of 18 December 2006 concerning the Registration, Evaluation, Authorization and
Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC
12. Annex II to Directive 2002/96/EC of the European Parliament and of the Council of 27 January
2003 on waste electrical and electronic equipment (WEEE)
13. Annexes XIV and XVII, Regulation (EC) No 1907/2006 of the European Parliament and of
the Council of 18 December 2006 concerning the Registration, Evaluation, Authorization and
Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC
14. Module A of Annex II to Decision No 768/2008/EC of the European Parliament and of the
Council of 9 July 2008 on a common framework for the marketing of products, and repealing
Council Decision 93/465/EEC.
15. Article 30 of Regulation (EC) No 765/2008 of the European Parliament and of the Council of
9 July 2008 setting out the requirements for accreditation and market surveillance relating to
the marketing of products and repealing Regulation (EEC) No 339/93.
16. Committee set up pursuant to Article 5 of Directive 98/34/EC OF THE EUROPEAN
PARLIAMENT AND OF THE COUNCIL of 22 June 1998 laying down a procedure for the
provision of information in the field of technical standards and regulations.
17. REGULATION (EU) No 182/2011 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 16 February 2011 laying down the rules and general principles concerning
mechanisms for control by Member States of the Commission’s exercise of implement-
ing powers.
18. Articles 15 to 29 of Regulation (EC) No 765/2008 of the European Parliament and of the
Council of 9 July 2008 setting out the requirements for accreditation and market surveillance
relating to the marketing of products and repealing Regulation (EEC) No 339/93.
19. Article 290 of the Treaty on the Functioning of the European Union in respect of amendments
to Annex II, detailed rules for complying with maximum concentration values, and the adapta-
tion of Annexes III and IV to technical and scientific progress.
20. COMMISSION DELEGATED DIRECTIVE (EU) 2015/863 of 31 March 2015 amending
Annex II to Directive 2011/65/EU of the European Parliament and of the Council as regards
the list of restricted substances.
21. COMMISSION DELEGATED DIRECTIVE (EU) 2016/585 of 12 February 2016 amending,
for the purposes of adapting to technical progress, Annex IV to Directive 2011/65/EU of the
European Parliament and of the Council as regards an exemption for lead, cadmium, hexava-
lent chromium, and polybrominated diphenyl ethers (PBDE) in spare parts recovered from and
used for the repair or refurbishment of medical devices or electron microscopes.
EU 722/2012 – Animal Tissue Regulations
in Effect for Some Medical Devices

Abbreviations
EC European Commission
EEC European Economic Community
EU European Union
TSE Transmissible spongiform encephalopathy
WHO World Health Organization
Highlights
• The chapter provides information on EU regulation on medical device utilizing
animal tissue.
• It also explains the risk of TSE infectious agents and its inactivation methods.
1 Introduction
Modern medical devices incorporate a range of materials into finished products,

including animal tissues and other materials of animal origin. The type and quanti-
ties of materials of animal origin in medical devices vary. These materials can com-
prise a major part of the device (e.g., porcine/bovine heart valves, bone substitutes
T. Sampath (*)
S. Thamizharasan
Krithaksha V.
RMKSSS, RMK Group of Institutions, Chennai, Tamil Nadu, India
for use in orthopedic or dental applications and hemostatic devices), shall be used
in the device manufacturing process (e.g., tallow derivatives such as stearates and
oleates, fetal calf serum, culture media, enzymes), and can be a product coating/
covering or impregnation (e.g., gelatine, collagen, heparin). Although animal mate-
rials can provide therapeutic and biocompatibility advantages over non-animal
materials, their significant use in medical devices also introduces the risk of disease
transmission from animals to humans. Most important concern is the potential
transmission of transmissible spongiform encephalopathy (TSE), a devastating dis-
ease affecting the brains of susceptible species, including cattle, goats, and sheep,
which can be transmitted to humans through contact with TSE-infected animal tis-
sues and materials.
Article 1
(i) This Regulation lays down particular requirements in relation to the placing on
the market and/or putting into service of medical devices, including active
implantable medical devices, manufactured utilizing animal tissue which is
rendered non-viable or non-viable products derived from animal tissue.
(ii) This Regulation shall apply to animal tissues, as well as their derivatives, origi-
nating from bovine, ovine, and caprine species, deer, elk, mink, and cats.
(iii) Collagen, gelatine, and tallow used for the manufacturing of medical devices
shall meet at least the requirements as fit for human consumption laid down in
Regulation (EC) No 1069/2009.
(iv) This Regulation shall not apply to any of the following:
–– Tallow derivatives, processed under vigorous conditions
–– Medical devices which are not intended to come into contact with the
human body or which are intended to come into contact with intact skin only
Article 2
The following definitions apply in addition to the definitions set out in Directive
90/385/EEC and Directive 93/42/EEC:
Cell: The smallest organized unit of any living form which is capable of indepen-
dent existence and of replacement of its own substance in a suitable environment
Tissue: An organization of cells, extracellular constituents, or both
Derivative: A material obtained from animal tissue through one or more treatments,
transformations, or steps of processing
Non-viable: Having no potential for metabolism or multiplication
TSE: Transmissible spongiform encephalopathies
TSE infectious agents: Unclassified pathogenic agents which are capable of trans-
mitting TSEs
Reduction, elimination, or removal: A process by which the number of TSE infec-
tious agents is reduced, eliminated, or removed in order to prevent infection or
pathogenic reaction
Inactivation: A process by which the ability to cause infection or pathogenic reac-
tion by TSE infectious agents is reduced
EU 722/2012 – Animal Tissue Regulations in Effect for Some Medical Devices 311
Source country: The country or countries in which the animal was born, has been
reared, and/or has been slaughtered
Starting materials: Raw materials or any other product of animal origin out of
which, or with the help of which, the devices are produced
Article 3
• Before lodging an application for a conformity assessment pursuant to Article
9(1) of Directive 90/385/EEC or Article 11(1) of Directive 93/42/EEC, the man-
ufacturer of medical devices referred to in Article 1(1) of this Regulation or his
authorized representative shall carry out the risk analysis and risk management
scheme set out in this Regulation.
• For custom-made devices and devices intended for clinical investigation which
fall under Article 1(1), the statement of the manufacturer or his authorized repre-
sentative and the documentation in accordance with Annex 6 to Directive 90/385/
EEC or Annex VIII to Directive 93/42/EEC, respectively, shall also address com-
pliance with the particular requirements set out in this Regulation.
Article 4
• Member States shall verify that bodies notified under Article 11 of Directive
90/385/EEC or Article 16 of Directive 93/42/EEC have up-to-date knowledge of
the medical devices.
• Referred to in Article 1(1), in order to assess the conformity of those devices with
the provisions of Directive 90/385/EEC or Directive 93/42/EEC, respectively,
and with the particular requirements laid down in this Regulation. Member States
shall regularly verify that those bodies maintain the required up-to-date knowl-
edge and expertise. Where, on the basis of that verification, it is necessary for a
Member State to amend the tasks of a notified body, that Member State shall
notify the Commission and the other Member States accordingly.
• The Member States shall inform the Commission and the other Member States
regarding the outcome of the verification.
Article 5
• Conformity assessment procedures for medical devices referred to in Article 1(1)
shall include the evaluation of compliance of the devices with the essential
requirements of Directive 90/385/EEC or Directive 93/42/EEC, respectively, and
the particular requirements laid down to this Regulation.
• Notified bodies shall assess the documentation submitted by the manufacturer to
verify that the benefits of the device outweigh the residual risks. Particular
account shall be taken of:
–– The manufacturer’s risk analysis and risk management process
–– The justification for the use of animal tissues or derivatives, taking into con-
sideration lower-risk tissues or synthetic alternatives
–– The results of elimination and inactivation studies or results of the analysis of
relevant literature
–– The manufacturer’s control of the sources of raw materials, finished products,
production process, testing, and subcontractors
–– The need to audit matters related to the sourcing and processing of animal
tissues and derivatives or processes to eliminate or inactivate pathogens,
including those activities carried out by suppliers.
• Notified bodies shall, during the evaluation of the risk analysis and risk manage-
ment in the framework of the conformity assessment procedure, take account of
the TSE certificate of suitability issued by the European Directorate for the
Quality of Medicines, hereinafter “TSE certificate of suitability,” for starting
materials, where available.
Where additional information is necessary to assess the suitability of the starting
material for a given medical device, notified bodies may require submission of
additional information to allow the evaluation.
• Before issuing an EC design-examination certificate or an EC type-examination
certificate, the notified bodies shall, through their competent authority, hereinaf-
ter “coordinating competent authority,” inform the competent authorities of the
other Member States and the Commission of their assessment carried out sum-
mary evaluation report in accordance with this Regulation.
• The competent authorities of the Member States may submit comments on the
summary evaluation report referred to in paragraph 4 within the following
deadlines:
(a) In relation to medical devices using starting materials for which a TSE cer-
tificate of suitability has been submitted, within 4 weeks from the date on
which the notified body informed the coordinating competent authority
(b) In relation to medical devices using starting materials for which a TSE cer-
tificate of suitability has not been submitted, within 12 weeks from the date
on which the notified body informed the coordinating competent authority
The competent authorities of the Member States and the Commission may agree on
shortening the time periods set out in points (a) and (b).
• They shall convey an explanation as regards this consideration, including any
due justification not to take account of one or more of the comments received,
and their final decisions to the coordinating competent authority, which shall
then make these available to the Commission and the competent authorities from
which comments were received.
• The manufacturer shall collect, evaluate, and submit to the notified body infor-
mation regarding changes with regard to the animal tissue or derivatives used for
the device or with regard to the TSE risk in relation to the device. Where such
information leads to an increase of the overall TSE risk.
Article 6
• Member States shall take all necessary steps to ensure that medical devices
referred to in Article 1(1) are placed on the market and/or put into service only if
they comply with the provisions of Directive 90/385/EEC or Directive 93/42/
EEC, respectively, and the particular requirements laid down in this Regulation.
Article 7
• Holders of EC design-examination certificates or EC-type examination certifi-
cates issued before 29 August 2013 for active implantable medical devices
referred to in Article 1(1) shall apply to their notified body for a complementary
EC design-examination certificate or EC-type examination certificate attesting
compliance with the particular requirements laid down in this Regulation.
• Until 29 August 2014, Member States shall accept the placing on the market and
the putting into service of active implantable medical devices referred to in
Article 1(1) which are covered by an EC design-examination certificate or an
EC-type examination certificate issued before 29 August 2013.
Article 8
• Directive 2003/32/EC is repealed with effect from 29 August 2013.
• References to the repealed Directive are to be construed as references to this
Regulation. This Regulation enters into force on the 20th day following that of
its publication in the Official Journal of the European Union. It shall apply from
29 August 2013 except for Article 4 which shall apply from the date of entry into
force of this Regulation.
2 Risk Analysis and Risk Management
2.1 Justification for the Use of Animal Tissues or Derivatives
The manufacturer must justify, on the basis of his overall risk analysis and risk
management strategy for a specific medical device, the decision to use animal tis-
sues or derivatives, referred to in Article 1 (specifying animal species, tissues, and
sourcing), taking into account the clinical benefit, potential residual risk, and suit-
able alternatives (such as lower-risk tissues or synthetic alternatives).
2.2 Process of Risk Assessment
In order to ensure a high level of protection for patients and users, the manufacturer
of devices utilizing animal tissues or derivatives must implement an appropriate and
well-documented risk analysis and risk management strategy, to address all relevant
aspects relating to TSE. The manufacturer must identify the hazards and evaluate
the risks associated with those tissues or derivatives, establish documentation on
measures taken to minimize the risk of transmission, and demonstrate the accept-
ability of the residual risk associated with the device utilizing such tissues or deriva-
tives, taking into account the intended use and the benefit of the device.
The safety of a device, in terms of its potential for passing on a TSE infectious
agent, is dependent on all the factors described below to which the manufacturer
must analyze, evaluate, and manage. These measures in combination determine the
device safety.
The manufacturer must consider the following key steps:
• Selecting starting materials (tissues or derivatives) considered appropriate
regarding their potential contamination with TSE infectious agents taking into
account further collection, handling, transport, storage, and processing.
• Applying a production process to remove or inactivate TSE infectious agents on
controlled sourced tissues or derivatives.
• Maintaining a system to collect and evaluate production and post-production
information regarding changes which may affect the assessment of the suitability.
In performing the risk analysis and risk management strategy, the manufacturer
must give due consideration to the relevant published opinions adopted by the rele-
vant European or international scientific committees or bodies, such as the Scientific
Steering Committee (SSC), the European Food Safety Agency (EFSA), the
European Medicines Agency (EMA), the World Organisation for Animal Health
(OIE), and the World Health Organization (WHO).
2.3 Animals as a Source of Material
The TSE risk is related to the source species, strains, and nature of the starting tis-
sue. As the accumulation of TSE infectivity occurs over an incubation period of
several years, sourcing from young healthy animals is considered to be a factor
reducing the risk. Risk animals such as fallen stock, emergency slaughtered, and
TSE suspected animals must be excluded as a source of material.
Geographical Sourcing When assessing the risk of the source country,
Commission Decision 2007/453/EC of 29 June 2007 establishing the BSE status of
Member States or third countries or regions thereof according to their BSE risk is to
be taken into account.
2.4 Nature of Starting Tissue
The manufacturer must take into account the classification of the risks relating to
different types of starting tissue as defined in the WHO Guidelines on Tissue
Infectivity Distribution in Transmissible Spongiform Encephalopathies (2006), as
amended. Sourcing of animal tissue must be performed in such a manner as to main-
tain control over the traceability and integrity of source tissue. Where appropriate,
the animals shall be subjected to veterinary ante- and postmortem inspection.
In addition, Regulation (EC) No 1069/2009 applies.
Without prejudice to the provision in the following paragraph, only category 3

material in accordance with Article 10 of Regulation (EC) No 1069/2009 shall
be used.
The manufacturer must not source animal tissue or derivatives classified as
potentially high TSE infective, unless sourcing of these materials is necessary in
exceptional circumstances, taking into account the important benefit for the patient
and the absence of an alternative starting tissue.
For bovine, ovine, and caprine animals, the list of specified risk material (SRM)
laid down in Annex V to Regulation (EC) No 999/2001 is to be considered as being
potentially of high TSE infectivity.
Slaughtering and processing controls to prevent cross-contamination: The manu-
facturer must ensure that the risk of cross-contamination during slaughtering, col-
lection, processing, handling, storage, and transport is minimized.
2.5 Inactivation or Removal of TSE Infectious Agents
For devices which cannot withstand an inactivation or elimination process without

undergoing unacceptable degradation, the manufacturer must rely principally on the
control of sourcing. For other devices, if claims are made by the manufacturer for
the ability of manufacturing processes to remove or inactivate TSE infectious
agents, these must be substantiated by appropriate documentation. Relevant infor-
mation from an analysis of appropriate scientific literature can be used to support
inactivation and elimination factors, where the specific processes referred to in the
literature are comparable to those used for the device. This search and analysis shall
also cover the available scientific opinions that may have been adopted by a
European or international scientific committee or body. These opinions are to serve
as a reference, in cases where there are conflicting opinions.
If the literature search fails to substantiate the claims, the manufacturer must set
up a specific inactivation or elimination study, as appropriate, on a scientific basis,
and the following need to be considered:
–– The identified hazard associated with the tissue
–– Identification of the relevant model agents
–– Rationale for the choice of the particular combinations of model agents
–– Identification of step and/or stage chosen to eliminate or inactivate the TSE
infectious agents
–– Documentation of the parameters for any TSE inactivation or elimination valida-
tion study
–– Calculation of the reduction factors
The manufacturer must apply appropriate documented procedures to ensure that
the validated processing parameters are applied during routine manufacture. A final
report must identify manufacturing parameters and limits that are critical to the
effectiveness of the inactivation or elimination process.
Quantities of Animal Tissues or Derivatives Required to Produce One Unit of

the Medical Device The manufacturer must evaluate the quantity of raw tissues or
derivatives of animal origin required to produce a single unit of the medical device.
The manufacturer must assess whether the production process has the potential to
concentrate levels of TSE infectious agents present in the animal starting tissues or
derivatives.
Tissues or Derivatives of Animal Origin Coming into Contact with the Patients
and Users The manufacturer must consider:
–– The maximum quantity of animal tissues or derivatives coming into contact with
the patient or user when using a single medical device
–– The contact area: its surface, type (e.g., skin, mucous tissue, brain), and condi-
tion (e.g., healthy or damaged)
–– The type of the tissues or derivatives coming into contact with the patients
or users
–– -The period of time the device is intended to remain in contact with the body
(including bioresorption effect)
–– -The number of medical devices that could be used in a given procedure or, if
possible, over the lifetime of a patient or user
Route of Administration In the risk assessment, the manufacturer must take into
account the route of administration as indicated in the product information.
2.6 Review of the Risk Assessment
The manufacturer must establish and maintain a systematic procedure to review

information gained about the medical device or similar devices in the post-
production phase. The information must be evaluated for possible relevance to
safety, especially in any of the following cases:
–– Previously unrecognized hazards are identified.
–– The estimated risk arising from a hazard has changed or is no longer acceptable.
–– The original assessment is otherwise invalidated.
In the cases set out in the above points, the manufacturer shall feed back the
results of the evaluation as an input to the risk management process. In the light of
this new information, a review of the appropriate risk management measures for the
device must be considered (including rationale for choosing an animal tissue or
derivative). If there is a potential that the residual risk or its acceptability has
changed, the impact on previously implemented risk control measures must be re-
evaluated and justified. The results of this evaluation must be documented.
3 Evaluation by Notified Bodies
For the medical devices referred to in Article 1(1), manufacturers must provide to
the notified bodies referred to in Article 4 all relevant information to allow evalua-
tion of their risk analysis and risk management strategy in accordance with
Article 5(2).
3.1 I nformation of the Notified Body Regarding Changes

and New Information
Any change in relation to processes of sourcing, collection, handling, processing,

and inactivation or elimination and any new information on TSE risk collected by
the manufacturer and relevant for the medical device that could modify the result of
the manufacturer’s risk assessment must be transmitted to the notified body and,
where applicable, need to be approved by the notified body prior to its
implementation.
3.2 Renewal of Certificates
In the context of its decision regarding the extension for a further period of maxi-
mum 5 years of an EC design-examination certificate or an EC-type examination
certificate in accordance with Article 9(8) of Directive 90/385/EEC or Article 11(11)
of Directive 93/42/EEC, respectively, the notified body shall review for the purpose
of this Regulation at least in the following aspects:
–– Updated justification for the use of animal tissue or derivative, including a com-
parison with lower-risk tissues or synthetic alternatives
–– Updated risk analysis
–– Updated clinical evaluation
–– Updated test data and/or rationales, for example, in relation to the current harmo-
nized standards
–– Identification of any changes made since the issue of the original certificate (or
last renewal) that could impact the TSE risk
–– Evidence that the design dossier remains state of the art in relation to TSE risks
Increase of the Overall TSE Risk Where on the basis of information submitted in
accordance with Sects. 3.1 or 3.2 a notified body establishes that the overall TSE
risk in relation to a medical device is increased, this notified body shall follow the
procedure set out in Article 5.
3.3 Rigorous Processes for Tallow Derivatives
• Trans-esterification or hydrolysis at not less than 200 °C for not less than 20 min
under pressure (glycerol, fatty acids, and fatty acid esters production)
• Saponification with NaOH 12 M (glycerol and soap production)
• Batch process: at not less than 95 °C for not less than 3 h
• Continuous process: at not less than 140 °C, under pressure for not less than
8 min or equivalent
• Distillation at 200 °C
3.4 ummary Evaluation Report in Accordance with Article

S
5(4) of Regulation (EU) No 722/2012
Details relating to the submitting notified body:

1. Name of the notified body
2. Notified body number
3. Country
4. Sent by
5. Contact person
6. Telephone
7. Fax
8. E-mail
9. Client reference(name of the manufacturer and, if applicable, of authorized
representative)
10. Confirmation that, in accordance with Article 11 of Directive 90/385/EEC AND
Article 16 of Directive 93/42/EEC, respectively, and Article 4 of Regulation(EU)
No 722/2012, the submitting notified body has been designated by its compe-
tent authority for the conformity assessment of:
◌ Active implantable medical devices manufactured utilizing tissues of ani-
mal origin subject to Regulation (EU) No 722/2012
◌ Medical devices manufactured utilizing tissues of animal origin subject to
Regulation (EU) No 722/2012
Data relating to the (active implantable) medical devices:
11. (a) ◌ Active implantable medical devices ◌ other medical devices
(b) Product description and composition
12. Information on intended use
13. Starting material
(a) EDQM certificate available ◌ Yes ◌ No

(if the EDQM certificate is available, it must be submitted with this sum-
mary evaluation report)
(b) Information regarding
––The nature of the starting tissue(s)
––Animal species(s)
––Geographical source(s)
14. A description of key the elements adopted to minimize the risk of infection
15. An estimate of the TSE risk arising from the use of the product, taking into
account the likelihood of contamination of the product and the nature and dura-
tion of patient exposure
16. A justification for the use of animal tissues or derivatives in the medical device,
including a rationale for the acceptability of the overall TSE risk estimate, the
evaluation of alternative materials, and the expected clinical benefit
17. The approach to the auditing of source establishments and suppliers for the
animal material used by the device manufacturer
Notified body statement
18. Conclusion of this assessment:
Based on the evaluation of data and the assessment process, it is our prelimi-
nary decisions that the application meets the requirements of conformity with:
◌ Council Directive 90/385/EEC and Regulation (EU) No 722/2012
◌ Council Directive 93/42/EEC
Date of Submission
19. This report was sent on………………………….to the Coordinating Competent
Authority of………………………….to inform the Competent Authorities of
the other Member States and the Commission and to seek their comments, if any.
Reference
1. EU – 722/2012, Commission Regulation Concerning particular requirements as regards the

requirements laid down in Council Directives 90/385/EEC and 93/42/EEC with respect to
active implantable medical devices and medical devices manufactured utilising tissues of ani-
mal origin, 09.08.2012, Official journal of European Union, 212:3–12.
EU 2017/746 – In Vitro Diagnostic Medical
Devices

Abbreviations
CE European conformity
CS Common specifications
EMA European Medicines Agency
EU European Union
EUDAMED European Database on Medical Devices
IVDR In Vitro Diagnostic Medical Devices Regulations
MDCG Medical Device Coordination Group
NANDO New Approach Notified and Designated Organisations
PMPF Post-market Performance Follow up
PSUR Periodic Safety Update Report
SRN Single Registration Number
UDI Unique Device Identification
UDI-DI UDI Device Identifier
UDI-PI UDI Production Identifier
Highlights
• The chapter provides information about EU regulatory process involved in
in vitro diagnostic medical device manufacturing process.
• It also explains the articles laid for nomenclature, identification, design, and
development of in vitro diagnostic medical devices.
T. Sampath (*)
S. Thamizharasan
1 Scope
1. This Regulation lays down rules concerning the placing on the market, making
available on the market, or putting into service of in vitro diagnostic medical
devices for human use and accessories for such devices in the Union.
2. For the purposes of this Regulation, in vitro diagnostic medical devices and
accessories for in vitro diagnostic medical devices shall hereinafter be referred
to as “devices.”
3. This Regulation does not apply to:
(a) Products for general laboratory use or research-use only products, unless
such products, in view of their characteristics, are specifically intended by
their manufacturer to be used for in vitro diagnostic examination
(b) Invasive sampling products or products which are directly applied to the
human body for the purpose of obtaining a specimen
(c) Internationally certified reference materials
(d) Materials used for external quality assessment schemes
4. This Regulation shall not affect the right of a Member State to restrict the use of
any specific type of device in relation to aspects not covered by this Regulation.
5. This Regulation shall not affect national law concerning the organization, deliv-
ery, or financing of health services and medical care, such as the requirement that
certain devices may only be supplied on a medical prescription, the requirement
that only certain health professionals or healthcare institutions may dispense or
use certain devices, or that their use be accompanied by specific professional
counselling.
6. Nothing in this Regulation shall restrict the freedom of the press or the freedom
of expression in the media insofar as those freedoms are guaranteed in the Union
and in the Member States, in particular under Article 11 of the Charter of
Fundamental Rights of the European Union.
2 Definitions
In vitro diagnostic medical device: any medical device which is a reagent, reagent
product, calibrator, control material, kit, instrument, apparatus, piece of equip-
ment, or software or system, whether used alone or in combination, intended by
the manufacturer to be used in vitro for the examination of specimens, including
blood and tissue donations, derived from the human body, solely or principally
for the purpose of providing information on one or more of the following:
–– Concerning a physiological or pathological process or state
–– Concerning congenital physical or mental impairments
–– Concerning the predisposition to a medical condition or a disease
EU 2017/746 – In Vitro Diagnostic Medical Devices 323
–– To determine the safety and compatibility with potential recipients

–– To predict treatment response or reactions
–– To define or monitoring therapeutic measures
Specimen receptacle: a device, whether of vacuum type or not, specifically intended
by its manufacturer for the primary containment and preservation of specimens
derived from the human body for the purpose of in vitro diagnostic examination
Accessory for an in vitro diagnostic medical device: an article which, while not
being itself an in vitro diagnostic medical device, is intended by its manufacturer
to be used together with one or several particular in vitro diagnostic medical
device(s) to specifically enable the in vitro diagnostic medical device(s) to be
used in accordance with its/their intended purpose(s) or to specifically and
directly assist the medical functionality of the in vitro diagnostic medical
device(s) in terms of its/their intended purpose(s)
Device for self-testing: any device intended by the manufacturer to be used by lay-
persons, including devices used for testing services offered to laypersons by
means of information society services
Device for near-patient testing: any device that is not intended for self-testing but is
intended to perform testing outside a laboratory environment, generally near to,
or at the side of, the patient by a health professional
Generic device group: a set of devices having the same or similar intended purposes
or a commonality of technology allowing them to be classified in a generic man-
ner not reflecting specific characteristics
Single-use device: a device that is intended to be used during a single procedure
Falsified device: any device with a false presentation of its identity and/or of its
source and/or its CE marking certificates or documents relating to CE marking
procedures. This definition does not include unintentional non-compliance and is
without prejudice to infringements of intellectual property rights
Kit: a set of components that are packaged together and intended to be used to per-
form a specific in vitro diagnostic examination, or a part thereof
Intended purpose: the use for which a device is intended according to the data sup-
plied by the manufacturer on the label, in the instructions for use, or in promo-
tional or sales materials or statements or as specified by the manufacturer in the
performance evaluation
Label: the written, printed, or graphic information appearing either on the device
itself or on the packaging of each unit or on the packaging of multiple devices
Instructions for use: the information provided by the manufacturer to inform the
user of a device’s intended purpose and proper use and of any precautions to
be taken
Unique Device Identifier (UDI): a series of numeric or alphanumeric characters that
is created through internationally accepted device identification and coding stan-
dards and that allows unambiguous identification of specific devices on the market
Risk: the combination of the probability of occurrence of harm and the severity of
that harm
Benefit-risk determination: the analysis of all assessments of benefit and risk of pos-
sible relevance for the use of the device for the intended purpose, when used in
accordance with the intended purpose given by the manufacturer
Putting into service: the stage at which a device, other than a device for perfor-
mance study, has been made available to the final user as being ready for use on
the Union market for the first time for its intended purpose
Manufacturer: a natural or legal person who manufactures or fully refurbishes a
device or has a device designed, manufactured, or fully refurbished and markets
that device under its name or trademark
Authorized representative: any natural or legal person established within the Union
who has received and accepted a written mandate from a manufacturer, located
outside the Union, to act on the manufacturer’s behalf in relation to specified
tasks with regard to the latter’s obligations under this Regulation
Importer: any natural or legal person established within the Union that places a
device from a third country on the Union market
Distributor: any natural or legal person in the supply chain, other than the manufac-
turer or the importer, that makes a device available on the market, up until the
point of putting into service
User: any healthcare professional or layperson who uses a device
Layperson: an individual who does not have formal education in a relevant field of
healthcare or medical discipline
Conformity assessment: the process demonstrating whether the requirements of this
Regulation relating to a device have been fulfilled
Conformity assessment body: a body that performs third-party conformity assess-
ment activities including calibration, testing, certification, and inspection
Notified body: a conformity assessment body designated in accordance with this
Regulation
CE marking of conformity: a marking by which a manufacturer indicates that a
device is in conformity with the applicable requirements set out in this Regulation
and other applicable Union harmonization legislation providing for its affixing
Clinical evidence: clinical data and performance evaluation results, pertaining to a
device of a sufficient amount and quality to allow a qualified assessment of
whether the device is safe and achieves the intended clinical benefit(s), when
used as intended by the manufacturer
Clinical benefit: the positive impact of a device related to its function, such as that
of screening, monitoring, diagnosis, or aid to diagnosis of patients, or a positive
impact on patient management or public health
Performance evaluation: an assessment and analysis of data to establish or verify
the scientific validity, the analytical, and, where applicable, the clinical perfor-
mance of a device
Device for performance study: a device intended by the manufacturer to be used in
a performance study. A device intended to be used for research purposes, without
any medical objective, shall not be deemed a device for performance study
Interventional clinical performance study: a clinical performance study where the

test results may influence patient management decisions and/or may be used to
guide treatment
Subject: an individual who participates in a performance study and whose
specimen(s) undergo in vitro examination by a device for performance study
and/or by a device used for control purposes
Investigator: an individual responsible for the conduct of a performance study at a
performance study site
Diagnostic specificity: the ability of a device to recognize the absence of a target
marker associated with a particular disease or condition
Diagnostic sensitivity: the ability of a device to identify the presence of a target
marker associated with a particular disease or condition
Likelihood ratio: the likelihood of a given result arising in an individual with the
target clinical condition or physiological state compared to the likelihood of the
same result arising in an individual without that clinical condition or physiologi-
cal state
Calibrator: a measurement reference material used in the calibration of a device
Control material: a substance, material, or article intended by its manufacturer to be
used to verify the performance characteristics of a device
Sponsor: any individual, company, institution, or organization which takes respon-
sibility for the initiation, management, and setting up of the financing of the
performance study
Device deficiency: any inadequacy in the identity, quality, durability, reliability,
safety, or performance of a device for performance study, including malfunction,
use errors, or inadequacy in information supplied by the manufacturer
Recall: any measure aimed at achieving the return of a device that has already been
made available to the end user
Withdrawal: any measure aimed at preventing a device in the supply chain from
being further made available on the market
Corrective action: action taken to eliminate the cause of a potential or actual non-
conformity or other undesirable situation
Field safety corrective action: corrective action taken by a manufacturer for techni-
cal or medical reasons to prevent or reduce the risk of a serious incident in rela-
tion to a device made available on the market
Field safety notice: a communication sent by a manufacturer to users or customers
in relation to a field safety corrective action
3 Regulatory Status of Products and Counselling
Regulatory Status of Products (Article 3)

1. A duly substantiated request of a Member State, the Commission shall, after
consulting the Medical Device Coordination Group established under Article
103 of Regulation (EU) 2017/745 (MDCG), by means of implementing acts,
determine whether or not a specific product, or category or group of products,

falls within the definitions of “in vitro diagnostic medical device” or “accessory
for an in vitro diagnostic medical device.”
2. The Commission shall ensure that Member States share expertise in the fields of
in vitro diagnostic medical devices, medical devices, medicinal products, human
tissues and cells, cosmetics, biocides, food, and, if necessary, other products, in
order to determine the appropriate regulatory status of a product, or category or
group of products.
3. When deliberating on the possible regulatory status as a device of products
involving medicinal products, human tissues and cells, biocides, or food prod-
ucts, the Commission shall ensure an appropriate level of consultation of the
European Medicines Agency (EMA), the European Chemicals Agency, and the
European Food Safety Authority, as relevant.
Genetic Information, Counselling, and Informed Consent (Article 4)
1. Member States shall ensure that where a genetic test is used on individuals, in
the context of healthcare and for the medical purposes of diagnostics, improve-
ment of treatment, predictive, or prenatal testing, the individual being tested or,
where applicable, his or her legally designated representative is provided with
relevant information on the nature, the significance, and the implications of the
genetic test, as appropriate.
2. Member States shall, in particular, ensure that there is appropriate access to
counselling in the case of the use of genetic tests that provide information on the
genetic predisposition for medical conditions and/or diseases which are gener-
ally considered to be untreatable according to the state of science and technology.
3. Nothing in this Article shall prevent Member States from adopting or maintain-
ing measures at the national level which are more protective of patients, more
specific or which deal with informed consent.
4 Marketing and Service
Placing on the Market and Putting into Service (Article 5)

–– A device may be placed on the market or put into service only if it complies with
this Regulation when duly supplied and properly installed, maintained, and used
in accordance with its intended purpose.
–– Devices that are manufactured and used within health institutions, with the
exception of devices for performance studies, shall be considered as having been
put into service.
–– The requirements of this Regulation shall not apply to devices manufactured and
used only within health institutions established in the Union, provided that all of
the following conditions are met:
(a) The devices are not transferred to another legal entity.
(b) Manufacture and use of the devices occur under appropriate quality manage-
ment systems.
(c) The laboratory of the health institution is compliant with standard EN ISO
15189 or where applicable national provisions, including national provisions
regarding accreditation.
(d) The health institution justifies in its documentation that the target patient
group’s specific needs cannot be met, or cannot be met at the appropriate
level of performance by an equivalent device available on the market.
Distance Sales (Article 6)
Without prejudice to national law regarding the exercise of the medical profession,
a device that is not placed on the market but used in the context of a commercial
activity, whether in return for payment or free of charge, for the provision of a diag-
nostic or therapeutic service offered by means of information society services or by
other means of communication, directly or through intermediaries, to a natural or
legal person established in the Union shall comply with this Regulation.
Claims (Article 7)
In the labelling, instructions for use, making available, putting into service, and
advertising of devices, it shall be prohibited to use text, names, trademarks, pictures,
and figurative or other signs that may mislead the user or the patient with regard to
the device’s intended purpose, safety, and performance by:
(a) Ascribing functions and properties to the device which the device does not have
(b) Creating a false impression regarding treatment or diagnosis, functions, or
properties which the device does not have
(c) Failing to inform the user or the patient of a likely risk associated with the use
of the device in line with its intended purpose
(d) Suggesting uses for the device other than those stated to form part of the
intended purpose for which the conformity assessment was carried out
Use of Harmonized Standards (Article 8)
Devices that are in conformity with the relevant harmonized standards, or the rele-
vant parts of those standards, the references of which have been published in the
Official Journal of the European Union, shall be presumed to be in conformity with
the requirements of this Regulation covered by those standards. References in this
Regulation to harmonized standards shall also include the monographs of the
European Pharmacopoeia adopted in accordance with the Convention on the
Elaboration of a European Pharmacopoeia, provided that references to those mono-
graphs have been published in the Official Journal of the European Union.
Common Specifications (Article 9)
Where no harmonized standards exist or where relevant harmonized standards are
not sufficient, or where there is a need to address public health concerns, the
Commission, after having consulted the MDCG, may, by means of implementing
acts, adopt common specifications (CS) in respect of the general safety and
performance requirements. Those implementing acts shall be adopted in accordance

with the examination procedure referred to in Article 107.
General Obligations of Manufacturers (Article 10)
When placing their devices on the market or putting them into service, manufactur-
ers shall ensure that they have been designed and manufactured in accordance with
the requirements of this Regulation. Manufacturers shall establish, document,
implement, maintain a system for risk management, and conduct a performance
evaluation in accordance with the requirements set out in Article 56. Manufacturers
shall draw up and keep up to date the technical documentation for those devices.
The technical documentation shall be such as to allow the conformity of the device
with the requirements of this Regulation to be assessed. Manufacturers shall ensure
that procedures are in place to keep series production in conformity with the require-
ments of this Regulation. Changes in product design or characteristics and changes
in the harmonized standards or CS by reference to which the conformity of a prod-
uct is declared shall be adequately taken into account in a timely manner.
Manufacturers of devices, other than devices for performance study, shall establish,
document, implement, maintain, keep up to date, and continually improve a quality
management system that shall ensure compliance with this Regulation in the most
effective manner and in a manner that is proportionate to the risk class and the type
of device.
Authorized Representative (Article 11)
Where the manufacturer of a device is not established in a Member State, the device
may only be placed on the Union market if the manufacturer designates a sole
authorized representative. The designation shall constitute the authorized represen-
tative’s mandate, and it shall be valid only when accepted in writing by the autho-
rized representative and shall be effective at least for all devices of the same generic
device group. The authorized representative shall perform the tasks specified in the
mandate agreed between it and the manufacturer. The authorized representative
shall provide a copy of the mandate to the competent authority, upon request.
Change of Authorized Representative (Article 12)
The detailed arrangements for a change of authorized representative shall be clearly
defined in an agreement between the manufacturer, where practicable the outgoing
authorized representative, and the incoming authorized representative. That agree-
ment shall address at least the following aspects: (a) the date of termination of the
mandate of the outgoing authorized representative and date of beginning of the
mandate of the incoming authorized representative; (b) the date until which the
outgoing authorized representative may be indicated in the information supplied by
the manufacturer, including any promotional material; (c) the transfer of documents,
including confidentiality aspects and property rights; and (d) the obligation of the
outgoing authorized representative after the end of the mandate to forward to the
manufacturer or incoming authorized representative any complaints or reports from
healthcare professionals, patients, or users about suspected incidents related to a
device for which it had been designated as authorized representative.
General Obligations of Importers (Article 13)

Importers shall place on the Union market only devices that are in conformity with
this Regulation. In order to place a device on the market, importers shall verify that
(a) the device has been CE marked and that the EU declaration of conformity of the
device has been drawn up; (b) a manufacturer is identified and that an authorized
representative in accordance with Article 11 has been designated by the manufac-
turer; (c) the device is labelled in accordance with this Regulation and accompanied
by the required instructions for use; and (d), where applicable, a UDI has been
assigned by the manufacturer in accordance with Article 24.
General Obligations of Distributors (Article 14)
When making a device available on the market, distributors shall, in the context of
their activities, act with due care in relation to the requirements applicable. Before
making a device available on the market, distributors shall verify that all of the fol-
lowing requirements are met:
(a) The device has been CE marked, and the EU declaration of conformity of the
device has been drawn up.
(b) The device is accompanied by the information to be supplied by the manufac-
turer in accordance with Article 10.
(c) For imported devices, the importer has complied with the requirements set out
in Article 13.
Person Responsible for Regulatory Compliance (Article 15)
Manufacturers shall have available within their organization at least one person
responsible for regulatory compliance who possesses the requisite expertise in the
field of in vitro diagnostic medical devices. The requisite expertise shall be demon-
strated by either of the following qualifications: (a) a diploma, certificate, or other
evidence of formal qualification, awarded on completion of a university degree or of
a course of study recognized as equivalent by the Member State concerned, in law,
medicine, pharmacy, engineering, or another relevant scientific discipline, and at
least 1 year of professional experience in regulatory affairs or in quality manage-
ment systems relating to in vitro diagnostic medical devices; and (b) 4 years of
professional experience in regulatory affairs or in quality management systems
relating to in vitro diagnostic medical devices.
Cases in Which Obligations of Manufacturers Apply to Distributors
(Article 16)
A distributor, importer, or other natural or legal person shall assume the obligations
incumbent on manufacturers if it does any of the following: (a) makes available on
the market a device under its own name, registered trade name, or registered trade
mark, except in cases where a distributor or importer enters into an agreement with
a manufacturer whereby the manufacturer is identified as such on the label and is
responsible for meeting the requirements placed on manufacturers in this Regulation;
(b) changes the intended purpose of a device already placed on the market or put
into service; and (c) modifies a device already placed on the market or put into
service in such a way that compliance with the applicable requirements may be
affected.
EU Declaration of Conformity (Article 17)
The EU declaration of conformity shall state that the requirements specified in this
Regulation have been fulfilled. The manufacturer shall continuously update the EU
declaration of conformity. Where concerning aspects not covered by this Regulation,
devices are subject to other Union legislation which also requires an EU declaration
of conformity by the manufacturer that fulfilment of the requirements of that legis-
lation has been demonstrated, a single EU declaration of conformity shall be drawn
up in respect of all Union acts applicable to the device. The declaration shall contain
all the information required for identification of the Union legislation to which the
declaration relates. By drawing up the EU declaration of conformity, the manufac-
turer shall assume responsibility for compliance with the requirements of this
Regulation and all other Union legislation applicable to the device.
CE Marking of Conformity (Article 18)
Devices, other than devices for performance studies, considered to be in conformity
with the requirements of this Regulation shall bear the CE marking of conformity.
The CE marking shall be affixed visibly, legibly, and indelibly to the device or its
sterile packaging. Where such affixing is not possible or not warranted on account
of the nature of the device, the CE marking shall be affixed to the packaging. The
CE marking shall also appear in any instructions for use and on any sales packaging.
Devices for Special Purposes (Article 19)
Member States shall not create obstacles to devices for performance study being
supplied for that purpose to laboratories or other institutions, if they meet the condi-
tions laid down in Articles 57 to 76, and in the implementing acts adopted pursuant
to Article 77. At trade fairs, exhibitions, demonstrations, or similar events, Member
States shall not create obstacles to the showing of devices which do not comply with
this Regulation, provided that a visible sign clearly indicates that such devices are
intended for presentation or demonstration purposes only and cannot be made avail-
able until they have been brought into compliance with this Regulation.
Parts and Components (Article 20)
Any natural or legal person who makes available on the market an item specifically
intended to replace an identical or similar integral part or component of a device that
is defective or worn in order to maintain or restore the function of the device without
changing its performance or safety characteristics or its intended purpose shall
ensure that the item does not adversely affect the safety and performance of the
device. Supporting evidence shall be kept available for the competent authorities of
the Member States. An item that is intended specifically to replace a part or compo-
nent of a device and that significantly changes the performance or safety character-
istics or the intended purpose of the device shall be considered a device and shall
meet the requirements laid down in this Regulation.
Free Movement (Article 21)

Member States shall not refuse, prohibit, or restrict the making available on the
market or putting into service within their territory of devices which comply with
the requirements of this Regulation.
5 Identification, Traceability, and Registration of Devices
Identification Within the Supply Chain (Article 22)

Distributors and importers shall co-operate with manufacturers or authorized repre-
sentatives to achieve an appropriate level of traceability of devices. Economic oper-
ators shall be able to identify the following to the competent authority, for the period
referred to in Article 10: (a) any economic operator to whom they have directly
supplied a device; (b) any economic operator who has directly supplied them with a
device; and (c) any health institution or healthcare professional to which they have
directly supplied a device.
Medical Devices Nomenclature (Article 23)
To facilitate the functioning of the European database on medical devices as referred
to in Article 33 of Regulation (EU) 2017/745, the Commission shall ensure that an
internationally recognized medical devices nomenclature is available free of charge
to manufacturers and other natural or legal persons required by this Regulation to
use that nomenclature. The Commission shall also endeavor to ensure that that
nomenclature is available to other stakeholders free of charge, where reasonably
practicable.
Unique Device Identification System (Article 24)
The UDI is a series of numeric or alphanumeric characters that is created through a
globally accepted device identification and coding standard. It allows the unam-
biguous identification of a specific device on the market. The UDI is comprised of
(i) a UDI device identifier (“UDI-DI”) specific to a manufacturer and a device pro-
viding access to the information and (ii) a UDI production identifier (“UDI-PI”) that
identifies the unit of device production and if applicable the packaged devices. The
Commission shall, by means of implementing acts, designate one or several entities
to operate a system for assignment of UDIs pursuant to this Regulation (“issuing
entity”). That entity or those entities shall satisfy all of the following criteria: (a) the
entity is an organization with legal personality; (b) its system for the assignment of
UDIs is adequate to identify a device throughout its distribution and use in accor-
dance with the requirements of this Regulation; (c) its system for the assignment of
UDIs conforms to the relevant international standards; and (d) the entity gives
access to its system for the assignment of UDIs to all interested users in accordance
with a set of predetermined and transparent terms and conditions.
UDI Database (Article 25)

The Commission, after consulting the MDCG, shall set up and manage a UDI data-
base in accordance with the conditions and detailed arrangements provided for in
Article 28 of Regulation (EU) 2017/745.
Registration of Devices (Article 26)
Before placing a device on the market, the manufacturer shall, in accordance with
the rules of the issuing entity referred to in Article 24, assign a Basic UDI-DI to the
device and shall provide it to the UDI database together with the other core data
elements. After issuance of the relevant certificate and before placing the device on
the market, the manufacturer shall provide the Basic UDI-DI to the UDI database
together with the other core data elements.
Electronic System for Registration of Economic Operators (Article 27)
The Commission, after consulting the MDCG, shall set up and manage an elec-
tronic system to create the single registration number referred to in Article 28 and to
collate and process information that is necessary and proportionate to identify the
manufacturer and, where applicable, the authorized representative and the importer.
The details regarding the information should be provided to that electronic system
by the economic operators. Within 2 weeks of placing a device on the market,
importers shall verify what the manufacturer or authorized representative has pro-
vided to the electronic system.
Registration of Manufacturers, Authorized Representatives, and Importers
(Article 28)
Before placing a device on the market, manufacturers, authorized representatives,
and importers shall, in order to register, submit to the electronic system referred to
in Article 30. In cases where the conformity assessment procedure requires the
involvement of a notified body pursuant to Article 48, shall be provided to that elec-
tronic system before applying to the notified body. After having verified the data
entered pursuant to paragraph 1, the competent authority shall obtain a single regis-
tration number (“SRN”) from the electronic system referred to in Article 27 and
issue it to the manufacturer, the authorized representative, or the importer. The man-
ufacturer shall use the SRN when applying to a notified body for conformity assess-
ment and for accessing EUDAMED in order to fulfil its obligations under Article 26.
Summary of Safety and Performance (Article 29)
The summary of safety and performance shall include at least the following aspects:
(a) the identification of the device and the manufacturer, including the Basic UDI-DI
and, if already issued, the SRN; (b) the intended purpose of the device and any indi-
cations, contraindications, and target populations; (c) a description of the device,
including a reference to previous generation(s) or variants if such exist and a
description of the differences, as well as, where relevant, a description of any acces-
sories, other devices, and products, which are intended to be used in combination
with the device; (d) reference to any harmonized standards and CS applied; (e) the
summary of the performance evaluation and relevant information on the PMPF; (f)
the metrological traceability of assigned values; (g) suggested profile and training
for users; and (h) information on any residual risks and any undesirable effects,
warnings, and precautions.
European Database on Medical Devices (Article 30)
The Commission, after consulting the MDCG, shall set up, maintain, and manage
the European database on medical devices (“EUDAMED”) in accordance with the
conditions and detailed arrangements established by Articles 33 and 34 of Regulation
(EU) 2017/745. EUDAMED shall include the following electronic systems: (a) the
electronic system for registration of devices referred to in Article 26; (b) the UDI
database referred to in Article 25; (c) the electronic system on registration of eco-
nomic operators referred to in Article 27; (d) the electronic system on notified bod-
ies and on certificates referred to in Article 52; (e) the electronic system on
performance studies referred to in Article 69; (f) the electronic system on vigilance
and post-market surveillance referred to in Article 87; and (g) the electronic system
on market surveillance referred to in Article 95.
6 Notified Bodies (Article 31–46)
Authorities Responsible for Notified Bodies

Any Member State that intends to designate a conformity assessment body as a noti-
fied body, or has designated a notified body, to carry out conformity assessment
activities under this Regulation shall appoint an authority (the “authority responsi-
ble for notified bodies”), which may consist of separate constituent entities under
national law and shall be responsible for setting up and carrying out the necessary
procedures for the assessment, designation, and notification of conformity assess-
ment bodies and for the monitoring of notified bodies, including subcontractors and
subsidiaries of those bodies. The authority responsible for notified bodies shall be
established, organized, and operated so as to safeguard the objectivity and impar-
tiality of its activities and to avoid any conflicts of interests with conformity assess-
ment bodies. The authority responsible for notified bodies shall safeguard the
confidential aspects of the information it obtains. However, it shall exchange infor-
mation on notified bodies with other Member States, the Commission, and, when
required, other regulatory authorities.
Application by Conformity Assessment Bodies for Designation Conformity
assessment bodies shall submit an application for designation to the authority
responsible for notified bodies. The application shall specify the conformity
assessment activities as defined in this Regulation, and the types of devices for
which the body is applying to be designated, and shall be supported by documenta-
tion demonstrating compliance (Article 34).
Assessment of the Application The authority responsible for notified bodies shall
within 30 days check that the application referred to in Article 34 is complete and
shall request the applicant to provide any missing information. Once the application
is complete, that national authority shall send it to the Commission. The authority
responsible for notified bodies shall review the application and supporting docu-
mentation in accordance with its own procedures and shall draw up a preliminary
assessment report. The authority responsible for notified bodies shall submit the
preliminary assessment report to the Commission which shall immediately transmit
it to the MDCG (Article 35).
Language Requirements All documents required pursuant to Articles 34 and 35
shall be drawn up in a language or languages which shall be determined by the
Member State concerned. Member States, in applying the first paragraph, shall con-
sider accepting and using a commonly understood language in the medical field, for
all or part of the documentation concerned. The Commission shall provide transla-
tions of the documentation pursuant to Articles 34 and 35, or parts thereof into an
official Union language, such as is necessary for that documentation to be readily
understood by the joint assessment team appointed in accordance with Article 35.
Identification Number and List of Notified Bodies The Commission shall assign
an identification number to each notified body for which the notification becomes
valid in accordance with Article 38. It shall assign a single identification number
even when the body is notified under several Union acts. If they are successfully
designated in accordance with this Regulation, bodies notified pursuant to Directive
98/79/EC shall retain the identification number assigned to them pursuant to that
Directive. The Commission shall make the list of the bodies notified under this
Regulation, including the identification numbers that have been assigned to them
and the conformity assessment activities as defined in this Regulation and the types
of devices for which they have been notified, accessible to the public in NANDO. The
Commission shall ensure that the list is kept up to date.
Monitoring and re-assessment of notified bodies: Notified bodies shall, without
delay, and at the latest within 15 days, inform the authority responsible for notified
bodies of relevant changes which may affect their compliance or their ability to
conduct the conformity assessment activities relating to the devices for which they
have been designated.
Challenge to the Competence of Notified Bodies The Commission, in conjunc-
tion with the MDCG, shall investigate all cases where concerns have been brought
to its attention regarding the continued fulfilment by a notified body, or of one or
more of its subsidiaries or subcontractors, of the requirements or the obligations to
which they are subject. It shall ensure that the relevant authority responsible for
notified bodies is informed and is given an opportunity to investigate those concerns
(Article 43).
Peer Review and Exchange of Experience Between Authorities Responsible
for Notified Bodies
The Commission shall provide for the organization exchange of experience and
coordination of administrative practice between the authorities responsible for noti-
fied bodies. Such exchange shall cover elements including:
(a) Development of best practice documents relating to the activities of the authori-
ties responsible for notified bodies
(b) Development of guidance documents for notified bodies in relation to the
implementation of this Regulation
(c) Training and qualification of the experts referred to in Article 36
(d) Monitoring of trends relating to changes to notified body designations and noti-
fications and trends in certificate withdrawals and transfers between noti-
fied bodies
(e) Monitoring of the application and applicability of scope codes referred to in
Article 38(13)
(f) Development of a mechanism for peer reviews between authorities and the
Commission
(g) Methods of communication to the public on the monitoring and surveillance
activities of authorities and the Commission on notified bodies
Coordination of Notified Bodies The Commission shall ensure that appropriate
coordination and cooperation between notified bodies is put in place and operated
in the form of the coordination group of notified bodies, as referred to in Article 49
of Regulation (EU) 2017/745. The bodies notified under this Regulation shall par-
ticipate in the work of that group.
7 Classification and Conformity Assessment (Article 47–55)
Classification of Devices Devices shall be divided into classes A, B, C, and D,

taking into account the intended purpose of the devices and their inherent risks. Any
dispute between the manufacturer and the notified body concerned, arising from the
application of Annexure, shall be referred for a decision to the competent authority
of the Member State in which the manufacturer has its registered place of business.
The competent authority of the Member State in which the manufacturer has its
registered place of business shall notify the MDCG and the Commission of its deci-
sion. The decision shall be made available upon request. In order to ensure the uni-
form application of Annexure, and taking account of the relevant scientific opinions
of the relevant scientific committees, the Commission may adopt implementing acts
to the extent necessary to resolve issues of divergent interpretation and of practical
application.
Certificates of Conformity The certificates shall be valid for the period they indi-
cate, which shall not exceed 5 years. On application by the manufacturer, the valid-
ity of the certificate may be extended for further periods, each not exceeding 5 years,
based on a re-assessment in accordance with the applicable conformity assessment
procedures. Any supplement to a certificate shall remain valid as long as the certifi-
cate which it supplements is valid. Where a notified body finds that the requirements
of this Regulation are no longer met by the manufacturer, it shall, taking account of
the principle of proportionality, suspend or withdraw the certificate issued or impose
any restrictions on it unless compliance with such requirements is ensured by appro-

priate corrective action taken by the manufacturer within an appropriate deadline set
by the notified body. The notified body shall give the reasons for its decision
(Article 51).
Voluntary Change of Notified Body In cases where a manufacturer terminates its
contract with a notified body and enters into a contract with another notified body in
respect of the conformity assessment of the same device, the detailed arrangements
for the change of notified body shall be clearly defined in an agreement between the
manufacturer, the incoming notified body, and, where practicable, the outgoing
notified body. That agreement shall cover at least the following aspects: (a) the date
on which the certificates issued by the outgoing notified body become invalid; (b)
the date until which the identification number of the outgoing notified body may be
indicated in the information supplied by the manufacturer, including any promo-
tional material; (c) the transfer of documents, including confidentiality aspects and
property rights; (d) the date after which the conformity assessment tasks of the
outgoing notified body are assigned to the incoming notified body; and (e) the last
serial number or lot number for which the outgoing notified body is responsible.
The outgoing notified body shall withdraw the certificates it has issued for the
device concerned on the date on which they become invalid (Article 53).
Certificate of Free Sale For the purpose of export and upon request by a manufac-
turer or an authorized representative, the Member State in which the manufacturer
or the authorized representative has its registered place of business shall issue a
certificate of free sale declaring that the manufacturer or the authorized representa-
tive, as applicable, has its registered place of business on its territory and that the
device in question bearing the CE marking in accordance with this Regulation may
be marketed in the Union. The certificate of free sale shall set out the Basic UDI-DI
of the device as provided to the UDI database under Article 26. Where a notified
body has issued a certificate pursuant to Article 51, the certificate of free sale shall
set out the unique number identifying the certificate issued by the notified body
(Article 55).
8 linical Evidence, Performance Evaluation

C
(Articles 56–77)
Performance Evaluation and Clinical Evidence Performance evaluation of a

device is a continuous process by which data are assessed and analyzed to demon-
strate the scientific validity, analytical performance, and clinical performance of
that device for its intended purpose as stated by the manufacturer. To plan, continu-
ously conduct, and document a performance evaluation, the manufacturer shall
establish and update a performance evaluation plan. The performance evaluation
plan shall specify the characteristics and the performance of the device and the pro-
cess and criteria applied to generate the necessary clinical evidence. The perfor-
mance evaluation shall be thorough and objective, considering both favorable and
unfavorable data. Its depth and extent shall be proportionate and appropriate to the
characteristics of the device including the risks, risk class, performance, and its
intended purpose. The manufacturer shall specify and justify the level of the clinical
evidence necessary to demonstrate conformity with the relevant general safety and
performance requirements. That level of clinical evidence shall be appropriate in
view of the characteristics of the device and its intended purpose.
General Requirements Regarding Performance Studies The manufacturer shall
ensure that a device for performance study complies with the general safety and
performance requirements covered by the performance study and that, with regard
to those aspects, every precaution has been taken to protect the health and safety of
the patient, user, and other persons. Where appropriate, performance studies shall
be performed in circumstances similar to the normal conditions of use of the device.
Performance studies shall be designed and conducted in such a way that the rights,
safety, dignity, and well-being of the subjects participating in such performance
studies are protected and prevail over all other interests and the data generated are
scientifically valid, reliable, and robust. Performance studies, including perfor-
mance studies that use leftover samples, shall be conducted in accordance with
applicable law on data protection (Article 57).
Informed Consent (Article 58) Informed consent shall be written, dated, and
signed by the person performing the interview and by the subject or, where the sub-
ject is not able to give informed consent, his or her legally designated representative
after having been duly informed. Where the subject is unable to write, consent may
be given and recorded through appropriate alternative means in the presence of at
least one impartial witness. In that case, the witness shall sign and date the informed
consent document. The subject or, where the subject is not able to give informed
consent, his or her legally designated representative shall be provided with a copy
of the document or the record, as appropriate, by which informed consent has been
given. The informed consent shall be documented. Adequate time shall be given for
the subject or his or her legally designated representative to consider his or her deci-
sion to participate in the performance study. Information given to the subject or,
where the subject is not able to give informed consent, his or her legally designated
representative for the purposes of obtaining his or her informed consent shall:
(a) Enable the subject or his or her legally designated representative to understand:
(i) The nature, objectives, benefits, implications, risks, and inconveniences of
the performance study
(ii) The subject’s rights and guarantees regarding his or her protection, in par-
ticular his or her right to refuse to participate in and the right to withdraw
from the performance study at any time without any resulting detriment
and without having to provide any justification
(iii) The conditions under which the performance study is to be conducted,

including the expected duration of the subject’s participation in the perfor-
mance study
(iv) The possible treatment alternatives, including the follow-up measures if
the participation of the subject in the performance study is discontinued
(b) Be kept comprehensive, concise, clear, relevant, and understandable to the sub-
ject or his or her legally designated representative
(c) Be provided in a prior interview with a member of the investigating team who
is appropriately qualified under national law
(d) Include information about the applicable damage compensation system
Performance Studies on Minors (Article 61) A performance study on minors
may be conducted only where, in addition to the conditions set out in Article 58, all
of the following conditions are met:
(a) The informed consent of their legally designated representative has been
obtained.
(b) The minors have received the information referred to in Article 59(2) in a way
adapted to their age and mental maturity and from investigators or members of
the investigating team who are trained or experienced in working with children.
(c) The explicit wish of a minor who is capable of forming an opinion and assess-
ing the information referred to in Article 59 to refuse participation in, or to
withdraw from, the performance study at any time is respected by the
investigator.
(d) No incentives or financial inducements are given to subjects or their legally
designated representatives, except for compensation for expenses and loss of
earnings directly related to the participation in the performance study.
(e) The performance study is intended to investigate treatments for a medical con-
dition that only occurs in minors, or the performance study is essential with
respect to minors to validate data obtained in performance studies on persons
able to give informed consent or by other research methods.
(f) The performance study either relates directly to a medical condition from which
the minor concerned suffers or is of such a nature that it can only be carried out
on minors.
(g) There are scientific grounds for expecting that participation in the performance
study will produce:
(i) A direct benefit to the minor subject outweighing the risks and burdens
involved
(ii) Some benefit for the population represented by the minor concerned when
the performance study will pose only minimal risk to, and will impose
minimal burden on, the minor concerned in comparison with the standard
treatment of the minor’s condition.
(h) The minor shall take part in the informed consent procedure in a way adapted
to his or her age and mental maturity.
(i) If during a performance study the minor reaches the age of legal competence to
give informed consent as defined in the national law, his or her expressed
informed consent shall be obtained before that subject can continue to partici-
pate in the performance study.
Performance Studies on Pregnant or Breastfeeding Women (Article 62) A per-
formance study on pregnant or breastfeeding women may be conducted only where,
in addition to the conditions set out in Article 58, all of the following conditions
are met:
(a) The performance study has the potential to produce a direct benefit for the preg-
nant or breastfeeding woman concerned, or her embryo, fetus, or child after
birth, outweighing the risks and burdens involved.
(b) If such a performance study has no direct benefit for the pregnant or breastfeed-
ing woman concerned, or her embryo, fetus, or child after birth, it can be con-
ducted only if:
(i) A performance study of comparable effectiveness cannot be carried out on
women who are not pregnant or breastfeeding
(ii) The performance study contributes to the attainment of results capable of
benefitting pregnant or breastfeeding women or other women in relation to
reproduction or other embryos, fetuses, or children
(iii) The performance study poses a minimal risk to, and imposes a minimal
burden on, the pregnant or breastfeeding woman concerned, her embryo,
fetus, or child after birth
(c) Where research is undertaken on breastfeeding women, particular care is taken
to avoid any adverse impact on the health of the child.
(d) No incentives or financial inducements are given to subjects, except for com-
pensation for expenses and loss of earnings directly related to the participation
in the performance study.
Additional national measures (Article 63): Member States may maintain addi-
tional measures regarding persons performing mandatory military service; persons
deprived of liberty; persons who, due to a judicial decision, cannot take part in
performance studies; or persons in residential care institutions.
Performance Studies in Emergency Situations (Article 64) (a)
Due to the urgency of the situation, caused by a sudden life-threatening or other
sudden serious medical condition, the subject is unable to provide prior informed
consent and to receive prior information on the performance study.
(b) There are scientific grounds to expect that participation of the subject in
the performance study will have the potential to produce a direct clinically relevant
benefit for the subject resulting in a measurable health-related improvement allevi-
ating the suffering and/or improving the health of the subject, or in the diagnosis of
its condition.
(c) It is not possible within the therapeutic window to supply all prior informa-
tion to and obtain prior informed consent from his or her legally designated
representative.
(d) The investigator certifies that he or she is not aware of any objections to
participate in the performance study previously expressed by the subject.
(e) The performance study relates directly to the subject’s medical condition
because of which it is not possible within the therapeutic window to obtain prior
informed consent from the subject or from his or her legally designated representa-
tive and to supply prior information, and the performance study is of such a nature
that it may be conducted exclusively in emergency situations.
(f) The performance study poses a minimal risk to, and imposes a minimal
burden on, the subject in comparison with the standard treatment of the subject’s
condition.
Damage Compensation (Article 65) Member States shall ensure that systems for
compensation for any damage suffered by a subject resulting from participation in a
performance study conducted on their territory are in place in the form of insurance,
a guarantee, or a similar arrangement that is equivalent as regards its purpose and
which is appropriate to the nature and the extent of the risk.
Assessment by Member States (Article 67) Member States shall ensure that the
persons validating and assessing the application, or deciding on it, do not have con-
flicts of interest and are independent of the sponsor, the investigators involved, and
natural or legal persons financing the performance study, as well as free of any other
undue influence. Member States shall ensure that the assessment is done jointly by
a reasonable number of persons who collectively have the necessary qualifications
and experience. Member States shall assess whether the performance study is
designed in such a way that potential remaining risks to subjects or third persons,
after risk minimization, are justified, when weighed against the clinical benefits to
be expected.
Conduct of a Performance Study (Article 68) The sponsor and the investigator
shall ensure that the performance study is conducted in accordance with the
approved performance study plan. In order to verify that the rights, safety, and well-
being of subjects are protected, that the reported data are reliable and robust, and
that the conduct of the performance study is in compliance with the requirements of
this Regulation, the sponsor shall ensure adequate monitoring of the conduct of a
performance study. The extent and nature of the monitoring shall be determined by
the sponsor on the basis of an assessment that takes into consideration all character-
istics of the performance study including the following:
(a) The objective and methodology of the performance study
(b) The degree of deviation of the intervention from normal clinical practice
Recording and Reporting of Adverse Events That Occur During Performance
Studies (Article 76) The sponsor shall fully record all of the following:
(a) Any adverse event of a type identified in the performance study plan as being
critical to the evaluation of the results of that performance study
(b) Any serious adverse event
(c) Any device deficiency that might have led to a serious adverse event if appropri-
ate action had not been taken, intervention had not occurred, or circumstances
had been less fortunate
(d) Any new findings in relation to any event referred to in points (a) to (c)
The sponsor shall report without delay to all Member States in which a perfor-
mance study is being conducted all of the following by means of the electronic
system referred to in Article 69:
(a) Any serious adverse event that has a causal relationship with the device, the
comparator, or the study procedure or where such causal relationship is reason-
ably possible
(b) Any device deficiency that might have led to a serious adverse event if appropri-
ate action had not been taken, intervention had not occurred, or circumstances
had been less fortunate
(c) Any new findings in relation to any event referred to in points (a) and (b)
The period for reporting shall take account of the severity of the event. Where
necessary to ensure timely reporting, the sponsor may submit an initial report that is
incomplete followed up by a complete report.
9 ost-market Surveillance, Vigilance, and Market

P
Surveillance (Article 78–95)
Post-market Surveillance System of the Manufacturer For each device, manu-

facturers shall plan, establish, document, implement, maintain, and update a post-
market surveillance system in a manner that is proportionate to the risk class and
appropriate for the type of device. That system shall be an integral part of the manu-
facturer’s quality management system referred to in Article 10. The post-market
surveillance system shall be suited to actively and systematically gather, record, and
analyze relevant data on the quality, performance, and safety of a device throughout
its entire lifetime and draw the necessary conclusions and determine, implement,
and monitor any preventive and corrective actions.
Periodic Safety Update Report (Article 81) Manufacturers of class C and class D
devices shall prepare a periodic safety update report (“PSUR”) for each device and
where relevant for each category or group of devices summarizing the results and
conclusions of the analyses of the post-market surveillance data gathered as a result
of the post-market surveillance plan referred to in Article 79 together with a ratio-
nale and description of any preventive and corrective actions taken. Throughout the
lifetime of the device concerned, that PSUR shall set out (a) the conclusions of the
benefit-risk determination, (b) the main findings of the PMPF, and (c) the volume of
sales of the device and an estimate of the size and other characteristics of the popu-
lation using the device and, where practicable, the usage frequency of the device.
Manufacturers of class D devices shall submit PSUR by means of the electronic
system referred to in Article 87 to the notified body involved in the conformity
assessment of such devices in accordance with Article 48. The notified body shall
review the report and add its evaluation to that electronic system with details of any
action taken. Such PSUR and the evaluation by the notified body shall be made
available to competent authorities through that electronic system.
Reporting of Serious Incidents and Field Safety Corrective Actions

(Article 82)
Manufacturers of devices, made available on the Union market, other than devices
for performance study, shall report, to the relevant competent authorities, in accor-
dance with Articles, the following: (a) any serious incident involving devices made
available on the Union market, except expected erroneous results which are clearly
documented and quantified in the product information and in the technical docu-
mentation and are subject to trend reporting pursuant to Article 83; and (b) any field
safety corrective action in respect of devices made available on the Union market,
including any field safety corrective action undertaken in a third country in relation
to a device which is also legally made available on the Union market, if the reason
for the field safety corrective action is not limited to the device made available in the
third country.
Manufacturers shall report any serious incident as referred to in point (a) imme-
diately after they have established a causal relationship between that incident and
their device or that such causal relationship is reasonably possible, and not later than
15 days after they become aware of the incident. In the event of death or an unantici-
pated serious deterioration in a person’s state of health, the report shall be provided
immediately after the manufacturer has established or as soon as it suspects a causal
relationship between the device and the serious incident but not later than 10 days
after the date on which the manufacturer becomes aware of the serious incident.
Analysis of Vigilance Data (Article 85) The Commission shall, in collaboration
with the Member States, put in place systems and processes to actively monitor the
data available in the electronic system referred to in Article 87, in order to identify
trends, patterns, or signals in the data that may reveal new risks or safety concerns.
Where a previously unknown risk is identified or the frequency of an anticipated
risk significantly and adversely changes the benefit-risk determination, the compe-
tent authority or, where appropriate, the coordinating competent authority shall
inform the manufacturer or where applicable the authorized representative, which
shall then take the necessary corrective actions.
Market Surveillance Activities (Article 88) The competent authorities shall per-
form appropriate checks on the conformity characteristics and performance of
devices including, where appropriate, a review of documentation and physical or
laboratory checks on the basis of adequate samples. The competent authorities
shall, in particular, take account of established principles regarding risk assessment

and risk management, vigilance data, and complaints. The competent authorities
shall draw up annual surveillance activity plans and allocate a sufficient number of
material and competent human resources in order to carry out those activities taking
into account the European market surveillance program developed by the MDCG
pursuant to Article 99 and local circumstances.
Evaluation of Devices Suspected of Presenting an Unacceptable Risk or Other
Non-compliance (Article 89) Where the competent authorities of a Member State,
based on data obtained by vigilance or market surveillance activities or on other
information, have reason to believe that a device:
(a) May present an unacceptable risk to the health or safety of patients, users, or
other persons, or to other aspects of the protection of public health.
(b) Otherwise does not comply with the requirements laid down in this Regulation,
they shall carry out an evaluation of the device concerned covering all require-
ments laid down in this Regulation relating to the risk presented by the device
or to any other non-compliance of the device.
Good Administrative Practice (Article 94) Where such a measure is addressed to
a specific economic operator, the competent authority shall notify without delay the
economic operator concerned of that measure and shall at the same time inform that
economic operator of the remedies available under the law or the administrative
practice of the Member State concerned and of the time limits to which such reme-
dies are subject. Where the measure is of general applicability, it shall be appropri-
ately published. Except in cases where immediate action is necessary for reasons of
unacceptable risk to human health or safety, the economic operator concerned shall
be given the opportunity to make submissions to the competent authority within an
appropriate period of time that is clearly defined before any measure is adopted.
10 U Reference Laboratories and Device Registers

E
(Articles 96–101)
Competent Authorities (Article 96) The Member States shall designate the com-
petent authority or authorities responsible for the implementation of this Regulation.
They shall entrust their authorities with the powers, resources, equipment, and
knowledge necessary for the proper performance of their tasks pursuant to this
Regulation. The Member States shall communicate the names and contact details of
the competent authorities to the Commission which shall publish a list of competent
authorities.
Cooperation (Article 97) The competent authorities of the Member States shall
cooperate with each other and with the Commission. The Commission shall provide for
the organization of exchanges of information necessary to enable this Regulation to be
applied uniformly. Member States shall with the support of the Commission partici-
pate, where appropriate, in initiatives developed at international level with the aim of
ensuring cooperation between regulatory authorities in the field of medical devices.
Medical Device Coordination Group (Article 98) The Medical Device
Coordination Group (MDCG) established in accordance with the conditions and
detailed arrangements referred to in Article 103 and 107 of Regulation (EU)
2017/745 shall carry out, with the support of the Commission as provided in Article
104 of Regulation (EU) 2017/745, the tasks conferred on it under this Regulation as
well as those under Regulation (EU) 2017/745.
Tasks of the MDCG (Article 99) Under this Regulation, the MDCG shall have the
following tasks: (a) to contribute to the assessment of applicant conformity assess-
ment bodies; (b) to advise the Commission, at its request, in matters concerning the
coordination group of notified bodies as established pursuant to Article 45; (c) to
contribute to the development of guidance aimed at ensuring effective and harmo-
nized implementation of this Regulation, in particular regarding the designation and
monitoring of notified bodies, application of the general safety and performance
requirements, and conduct of performance evaluations by manufacturers, assess-
ment by notified bodies, and vigilance activities; (d) to contribute to the develop-
ment of device standards and of CS; (e) to assist the competent authorities of the
Member States in their coordination activities in particular in the fields of classifica-
tion and the determination of the regulatory status of devices, performance studies,
vigilance, and market surveillance including the development and maintenance of a
framework for a European market surveillance program with the objective of
achieving efficiency and harmonization of market surveillance in the Union, in
accordance with Article 88; (f) to provide advice, either on its own initiative or at
request of the Commission, in the assessment of any issue related to the
implementation of this Regulation; and (g) to contribute to harmonized administra-
tive practice with regard to devices in the Member States.
Device Registers and Databanks (Article 101) The Commission and the Member
States shall take all appropriate measures to encourage the establishment of regis-
ters and databanks for specific types of device setting common principles to collect
comparable information. Such registers and databanks shall contribute to the inde-
pendent evaluation of the long-term safety and performance of devices.
11 onfidentiality, Data Protection, Funding, and Penalties

C
(Articles 102–106)
Confidentiality (Article 102) Unless otherwise provided for in this Regulation

and without prejudice to existing national provisions and practices in the Member
States on confidentiality, all parties involved in the application of this Regulation
shall respect the confidentiality of information and data obtained in carrying out
their tasks in order to protect the following:
(a) Commercially confidential information and trade secrets of a natural or legal

person, including intellectual property rights unless disclosure is in the public
interest
(b) The effective implementation of this Regulation, in particular for the purpose of
inspections, investigations, or audits
Data Protection (Article 103) Member States shall apply Directive 95/46/EC to
the processing of personal data carried out in the Member States pursuant to this
Regulation. Regulation (EC) No 45/2001 shall apply to the processing of personal
data carried out by the Commission pursuant to this Regulation.
Levying of Fees (Article 104) This Regulation shall be without prejudice to the
possibility for Member States to levy fees for the activities set out in this Regulation,
provided that the level of the fees is set in a transparent manner and on the basis of
cost-recovery principles. Member States shall inform the Commission and the other
Member States at least 3 months before the structure and level of fees are to be
adopted. The structure and level of fees shall be made publicly available on request.
Funding of Activities Related to Designation and Monitoring of Notified Bodies
(Article 105) The costs associated with joint assessment activities shall be covered
by the Commission. The Commission shall, by means of implementing acts, lay
down the scale and structure of recoverable costs and other necessary implementing
rules. Those implementing acts shall be adopted in accordance with the examination
procedure referred to in Article 107(3).
Penalties (Article 106) The Member States shall lay down the rules on penalties
applicable for infringement of the provisions of this Regulation and shall take all
measures necessary to ensure that they are implemented. The penalties provided for
shall be effective, proportionate, and dissuasive.
Annexure
Device Classification Rules
Rule 1: Devices intended to be used for the following purposes are classified as
class D:
–– Detection of the presence of, or exposure to, a transmissible agent in blood, blood com-
ponents, cells, tissues, or organs, or in any of their derivatives, in order to assess their
suitability for transfusion, transplantation, or cell administration
–– Detection of the presence of, or exposure to, a transmissible agent that causes a life-
threatening disease with a high or suspected high risk of propagation;
–– Determining the infectious load of a life-threatening disease where monitoring is criti-
cal in the process of patient management
Rule 2: Devices intended to be used for blood grouping, or tissue typing to ensure
the immunological compatibility of blood, blood components, cells, tissue, or
organs that are intended for transfusion or transplantation or cell administration,

are classified as class C.
Rule 3: Devices are classified as class C if they are intended:
(a) For detecting the presence of, or exposure to, a sexually transmitted agent
(b) For detecting the presence in cerebrospinal fluid or blood of an infectious agent
without a high or suspected high risk of propagation
(c) For detecting the presence of an infectious agent, if there is a significant risk that an
erroneous result would cause death or severe disability to the individual, fetus, or
embryo being tested, or to the individual’s offspring
(d) For prenatal screening of women in order to determine their immune status toward
transmissible agents
(e) For determining infective disease status or immune status, where there is a risk that
an erroneous result would lead to a patient management decision resulting in a life-
threatening situation for the patient or for the patient’s offspring
(f) To be used as companion diagnostics
(g) To be used for disease staging, where there is a risk that an erroneous result would
lead to a patient management decision resulting in a life-threatening situation for
the patient or for the patient’s offspring
(h) To be used in screening, diagnosis, or staging of cancer
(i) For human genetic testing
(j) For monitoring of levels of medicinal products, substances, or biological compo-
nents, when there is a risk that an erroneous result will lead to a patient manage-
ment decision resulting in a life-threatening situation for the patient or for the
patient’s offspring
(k) For management of patients suffering from a life-threatening disease or condition
(l) For screening for congenital disorders in the embryo or fetus
(m) For screening for congenital disorders in newborn babies where failure to detect
and treat such disorders could lead to life-threatening situations or severe
disabilities
Rule 4: (a) Devices intended for self-testing are classified as class C, except for
devices for the detection of pregnancy, for fertility testing, and for determining
cholesterol level and devices for the detection of glucose, erythrocytes, leuco-
cytes, and bacteria in urine, which are classified as class B. (b) Devices intended
for near-patient testing are classified in their own right.
Rule 5: The following devices are classified as class A: (a) products for general
laboratory use, accessories which possess no critical characteristics, buffer solu-
tions, washing solutions, and general culture media and histological stains,
intended by the manufacturer to make them suitable for in vitro diagnostic pro-
cedures relating to a specific examination; (b) instruments intended by the manu-
facturer specifically to be used for in vitro diagnostic procedures; and (c)
specimen receptacles.
Reference
Regulation (EU) 2017/746 ofThe European Parliament and of the Council of 5 April 2017 on
in vitro diagnostic medical devices and repealing Directive 98/79/EC and Commission
Decision 2010/227/EU, Official Journal of the European Union.
Device Regulations of Other Countries
Karnika Singh
1 Introduction
This chapter covers medical device regulation from several countries listed below:
1. India Medical Device regulations
2. China Medical Device regulations
3. Canada Medical Device regulations
4. New Zealand Medical Device regulations
5. Australia Medical Device regulations
6. Japan Medical Device regulations
7. Singapore Medical Device regulations
8. United Kingdom Medical Device regulations
9. European Medical Device regulations
The medical device regulations of these countries are similar in many aspects to
that of the United States. However, they differ in a lot of areas as highlighted in each
section.
1. India Medical Device Regulations
The medical device regulations came into existence in India in the year 2017
(Ministry of Health and Family Welfare Notification No. G.S.R, 78(E) dated 31
January 2017 notifies Medical Devices Rules 2017). Certain medical devices and
in vitro diagnostic devices belonging to risk class B and C are included in the regu-
lation. New devices are regularly added to this list by the Ministry of Health and
Family Welfare. Since India imports most of its medical devices, the CDSCO
(Central Drugs Standard Control Organization) has Central Licensing Authority
(CLA) and State Licensing Authority (SLA) which are responsible for licensing to
K. Singh (*)
348 K. Singh
import, manufacture for sale or for distribution and sale, stock, exhibit, or offer for
sale. CLA does licensing for all import devices and Class C and Class D medical
devices manufacturing, loan, and wholesale licenses. CLA may take services of a
notified body to examine the manufacturing site of Class C and Class D medical
devices and technical review. SLA is responsible for the manufacturing, loan, and
wholesale licenses of Class A and Class B medical devices. SLA selects and autho-
rizes a notified body to validate the requirements of quality management system and
technical review for Class A and Class B medical device manufacturers.
Regulated imported medical devices that have obtained prior approval in the
United States, the European Union (EU), Canada, Japan, or Australia may legally be
sold in India by obtaining the necessary license which would cause a limited con-
formity assessment process. In such cases, the applications should accompany all
documentation used in support of prior approvals. It is advised to foreign manufac-
turers that they must appoint an importer, holding a valid wholesale license, and
would also submit a device registration application and dossier to the CLA.
1.1 Steps to Import Medical Devices in India
In order to import medical devices in India, first, the device is assigned a risk class
(A, low risk; B, low–moderate high risk; C, moderate high risk; D, high risk). Then,
an application of licensing needs to be filed through the online portal of Ministry of
Health and Family Welfare (SUGAM). After this, the CLA may schedule an inspec-
tion of the manufacturing site. If the device under consideration has a prior approval
from countries like the United States, Canada, Japan, EU, and Australia, then the
license is granted. However, if that is not the case, then class A and B devices are
evaluated for their safety and performance based on the published data or the clini-
cal investigation that was carried out in the respective country. For class C and D
devices, the same is established by conducting clinical investigation by India itself
before the granting of license.
1.2 teps to Manufacture Medical Devices for Sale or

S
for Distribution
The first few steps until filing an application are same as above. Once the applica-
tions are received, they are examined by the SLA or CLA already defined. The SLA
can provide the license to the applicant and then schedule for a technical review and
onsite audit or vice versa. The CLA however will always grant the license after the
technical review and onsite audit.
Device Regulations of Other Countries 349
2 China Medical Device Regulations
The medical device regulations in China are controlled by NMPA (National

Medical Products Administration) formally known as the China Food and Drug
Administration (CFDA). It classifies devices in risk categories, I, II, and III, rang-
ing from low to high. China follows the following criteria to classify medical
devices into the abovementioned three classes:
• Class I: those devices whose safety and effectiveness can be ensured through
routine administration.
• Class II: the devices which would need additional control to establish their safety
and effectiveness.
• Class III: these include devices which are used for life support and/or implanted
into the body and therefore may be a major threat to patient’s health.
In order to register medical devices in China, which are not manufactured in the
country, the respective company has to provide device samples to NMPA. In the
case of class II and III devices, it is mandatory for the manufacturer to send appli-
cable documents stating that the device has been approved in its manufacturing
country. Examples of such documents include CE Mark, 510(k) letter, ISO 13485
certification, approved Premarket Approval Application, etc. The application may
also require providing supporting clinical data associated with the device. All the
product information on the packaging label of the device should be translated to
simplified Chinese. Once approved, the medical device registration in China is valid
for 5 years (as opposed to 4 years). For renewal of registration, the renewal applica-
tion should be submitted to the same department 6 months prior to the expiration of
previous application. It is required by the outside manufacturers to hire China-based
agents to represent their interests. Such agents would be responsible for proving
technical service, maintenance support for the device, recall assistance, supervising
the registration process, and providing support for the manufacturer in the case of
an adverse event of device malfunction. The manufacturer will provide all their
details (name, address, contact information, etc.) to the designated agent in the reg-
istration application.
In the year 2017, NMPA amended the medical device regulations, and in 2018, a
revised draft was published. Some significant changes are outlined below:
• Unique Data Identification (UDI): The purpose of UDI is to monitor the medical
devices by allowing their tracking from the manufacturing point to their distribu-
tion and use. The information to be stored in the UDI database includes the
expiry and production dates of the device, the device model, and the UDI code.
• Market Authorization Holder (MAH): The MAH has to ensure the quality of
their products and that they meet all applicable requirements, submit yearly self-
inspection reports to respective authorities, and regularly update their products’
information in the NMPA’s UDI.
• Clinical Trial Management System: The clinical evaluation is not mandatory for
class I and most class II devices. In order for class III devices to skip the clinical
350 K. Singh
evaluation, they should have a proven safety record. The NMPA would review
the clinical data from foreign countries. All high-risk devices and devices for life
support would have to be evaluated in China.
• Prioritization of innovative devices: Foreign manufacturers would be allowed to
import “innovative” medical devices into China without any approval
certificates.
3 Canada Medical Device Regulations
The Medical Device Regulations of Canada apply to sale, advertising and import of
a medical device for sale to the general public as opposed to personal use. These
regulations also apply on in vitro diagnostic products (could be a drug or contains a
drug). The Canada medical device regulations also classify the devices according to
risk levels. Class I is the lowest risk, and class IV is the highest risk. It should be
noted that a device could be classified into more than one class; in this case, the
highest classification would apply.
3.1 General
It is the manufacturer’s responsibility to ensure that the medical device meets all the
relevant requirements.
Safety and effectiveness requirement: The manufacturer has to identify all the
inherent risks of the device, eliminate them if possible or reduce them to an accept-
able level, and provide protection guidelines from those risks. The manufacturer has
to also provide the information about the remaining risks with the device. The man-
ufacturer has to minimize the hazard arising from potential failures of the device
during its usage. The characteristic and performance of the medical device should
not decrease under regular use such that the health and safety of the patient are
compromised. The transport and storage conditions of the device should not
adversely affect the medical device. The materials used in the device should com-
plement each other so that it does not pose a risk to the patient. The design, manu-
facture, and packaging of the device should minimize any hazards like flammability,
contamination, radiation, leakage, and electric hazards. If a medical device is sup-
posed to be sterile, then they should be manufactured in sterile conditions and steril-
ized by a validated method. A measuring device should function within the tolerance
limits suitable for the medical conditions and other intended purposes. For software-
based devices, software would be designed keeping the intended performance in
mind and validated regularly.
Labeling Requirements The import and selling of a medical device is not permit-
ted until the labeling requirements are met. The label shall contain the name of the
device, details of the manufacturer, all the identifying information, control number
for high-risk devices, details about the package contents, indication of sterility,
expiry date or best before date, directions for use, performance specifications, and
storage conditions. All the labeling has to be legit and easily understandable to the
user. In case of absence of a label in the imported device, a prior notice has to be
sent to the Minister. Before selling the medical device, it should be relabeled within
3 months of importation according to these regulations. The Minister needs to be
notified in writing about who is going to relabel the product in Canada. The labeling
has to be done in at least two languages (English and French). Other labeling
requirements are similar to those outlined in ISO 16061.
Contraceptive Devices: Advertising A condom can be sold as long as it is mar-

keted as a device for preventing sexually transmitted diseases (STDs), and the label
of the condom should specify the same. Contraceptive devices except intrauterine
devices (IUDs) can be advertised publicly but may not utilize door-to-door distribu-
tion or mail as a means of advertising.
Class I Medical Devices The minister reserves the right to ask for more informa-
tion in order to approve a class I medical device.
Class II, III, and IV Medical Devices

Prohibition: These devices require a license to import or sell and advertise. The
advertisement has to clearly contain the warning, “may not have been licensed in
accordance with the Canadian law.”
Medical Devices Deemed Licensed: For a licensed system, all its parts are consid-
ered licensed for import, sale, and advertisement. In case of a test kit, all its
reagents are licensed for import, sale, and advertisement. If a licensed medical
device is a part of a medical device group, that group is deemed licensed for
import, sale, and advertisement and vice versa.
Application for a Medical Device License: The application for license has to be
submitted to the Minister in the format decided by the Minister. It would contain
the name, class, and identifier of the device, manufacturer details, and establish-
ment where the device is manufactured.
The application for class II device would have additional details like medical
conditions for which the device would be used for, list of applicable standards
attested by a senior official, and copy of device label, and the in vitro diagnostic
device would have to be attested by a senior official that it has undergone investiga-
tional testing on human subjects representing intended users, with a copy of the
quality management system certificate indicating that it satisfies National Standard
of Canada CAN/CSA-ISO 13485:2016, Medical devices – Quality management
systems – Requirements for regulatory purposes.
The license application for class III devices would additionally include list of
countries other than Canada where the device has been sold with all the details of
the sale (units sold, problems during sale, etc.), risk assessment, quality plan, details
352 K. Singh
of the materials used in the device, the manufacturing process, a list of validation
studies (preclinical and clinical, process validation, software validation, etc.), evi-
dence of the biological safety of the device, bibliography of all the reports about the
use, and safety and effectiveness of the device.
Quality Management System Certificate: This would be taken care of by an appro-
priately qualified person appointed by the Minister. This certificate is valid for
3 years at most. The Minister has to be notified in writing by the registrar about
suspending or cancelling a certificate. Also he will notify the Minister within
15 days of expiration if the certificate is not renewed. The Minister reserved the
right to fire or reinstate the registrar under certain conditions.
Foreign Manufacturers: If the foreign manufacturer were from a country that has a
regulatory authority recognized by the minister, then this would allow for exemp-
tion in the submission of abovementioned documents. The application needs to
contain a certificate of compliance and a summary report issued by the regula-
tory body of that country. The Minister can recognize a regulatory authority of a
foreign country if it is able to establish that the device meets all the applicable
requirements. The Minister can also provide the list of recognized regulatory
authorities of foreign countries upon request.
Application for a Medical Device License Amendment: The Minister would approve
any amendments like:
(a) A significant change in the application for class III or IV device
(b) A change that would influence the class of device
(c) Change in manufacturer’s name
(d) Change in name of device
(e) Change in the device identifier
(f) Changes in the medical conditions, purposes or uses, or selling criteria of a
class II device
Additional Information and Samples: The minister may request for additional docu-
mentation if he is not able to reach a decision about the application. This addi-
tional information may also be requesting device samples.
Issuance: If the application meets all the requirements, the Minister shall issue a
medical device license or amend the license of the manufacture. The license
holder would then have to comply with the terms and conditions of the license.
Refusal to Issue: If the applicant does not comply with the regulations or supplied
false information, it may lead to refusal of a medical device license or amend-
ment. The Minister shall inform the applicant in writing and provide an applicant
with an opportunity to be heard.
Suspension: The following conditions would lead to suspension of the device
license: any contradiction of the regulations, supplying misleading information
in the application, failure to comply with the terms and conditions of the license,
failure to provide the extra information/materials requested by the Minister, ces-
sation of meeting requirements, and any future information obtained after the
granting of license in terms of quality, manufacturing, etc. The Minister would
consider the licensee’s history of compliance with the regulations and risk that
would be caused if the license were continued. The minister shall wait to suspend
the license until he informs the licensee in writing the reason of suspension and
any corrective measures that may be required with the time limit. The licensee
would be given an opportunity to be heard. However, if the risk were big such
that patients and people using the device would be at a health risk, then the
licensee would not be heard. The licensee holds the rights to appeal a reconsid-
eration of suspension to the Minister in writing. The Minister will then have
45 days for hearing the licensee. The minister may reinstate the license if the
corrective measures have been taken or the basis of suspension is unjustified.
Obligation to Inform: The license holder shall inform the Minister in an authorized
form, before November 1, that all documents supplied by the manufacturer are
still valid or have changed since last time. Failure to do this may result in suspen-
sion. If the licensee decides to discontinue the sale of the device in Canada, then
he has to inform the Minister within 30 days of discontinuation, and the license
would be cancelled.
Obligation to submit certificate: The manufacturer has to submit a copy of new or
modified quality management system certificate to the Minister within 30 days
of issuance.
Disclosure of Information in Respect of Clinical Studies or Investigational Testing:
This is in regard to the application for class III or IV medical devices. The details
of the clinical study or investigational testing have to be disclosed if the Minister
issues a license under conditions discussed under “issuance.” However, if this
information was provided as a supporting material or contains methods exclusive
to the manufacturer, then they need not be revealed. The Minister can divulge
this information without the consent of the manufacturer.
Establishment License
Prohibition: Nobody can import or sell a medical device without an establishment
license. This does not apply to a retailer; healthcare facility; manufacturer of a
class II, III, or IV device; and a class I device manufacturer if he imports or dis-
tributes the device through someone with an establishment license.
Application: The application for the establishment license would be submitted to
the Minister and contain the name and address of the establishment, details of the
establishment, if the establishment is for importation or distribution, manufac-
turer details, medical specifications of the device, classes of the device, attesta-
tion by a senior official of the establishment that their establishment has
procedures in place for distribution records, complaint holding, recalls, problem
reporting, handling, storage, delivery, installation, corrective action, and servic-
ing. The address of each building where the above procedures are carried
out would also be included.
Issuance: The license would be issued by the Minister if he determines that all
application requirements are met.
Annual Review of License: The review of the licenser would be submitted before
April 1 every year and include all the documents in application. The review
354 K. Singh
application would be evaluated by the Minister based on the information

provided.
Refusal: In an event of incorrect information or other reasonable grounds that may
pose a risk to the safety of the users, the Minister would refuse to issue the
license. The Minister has to notify the applicant in writing and give him the
opportunity to be heard.
Suspension: The suspension requirements for establishment license are the same as
for device license.
Cancellation: If the license has remained suspended for 12 months or the licensee
has failed to submit a review application, then their license is subjected to
cancellation.
3.2 Distribution Records
The manufacturer, importer, and distributer of a medical device would maintain

distribution records for each device. Retailers and healthcare facilities may not have
to maintain such records. The distribution record will contain enough information
to permit complete and quick withdrawal of the medical device from the market. In
the case of implants, the distribution records shall contain the information on the
implant registration cards. The manufacturer would regularly update this informa-
tion as per healthcare facility or the patient. The manufacturer, importer, and distrib-
uter have to retain this information for the useful life of the device and 2 years after
the shipping of device. These records would be maintained in a way that they can be
retrieved timely.
3.3 Complaint Handling
The manufacturer, importer, and distributer would maintain records of any reported
problems regarding safety and device performance, consumer complaints, and
actions taken by the manufacturer, importer, and distributer to these problems.
Retailers and healthcare facilities are exempted from this as well. The manufacturer,
importer, and distributer would establish and document procedures that would lead
to an effective and timely investigation of the problem as well as recall of the device
if needed.
3.4 Mandatory Problem Reporting
The manufacturer would make a preliminary report and a final report for the
Minister, for any incident that is sold in Canada. This would include failure of the
device or a decrease in its effectiveness, faulty labeling, incomplete information,
etc. If this incompetence has led to the death or serious injury to the user, then this
would also be reported. The preliminary report is submitted within 10 days of a seri-
ous incident and within 30 days of a minor incident. It would contain all the infor-
mation about the device indicated in earlier sections, the manufacturer details, and
the importer details if applicable. The date the incident was reported, details associ-
ated with the incident, contact information of the person who reported the incident,
identity of the device in question, and a statement indicating whether a similar
report has been made to the Minister before with details should also be included.
The final report would contain description of the incident, number of people who
experienced deleterious effects to their health or have died, an elaborate explanation
of the cause of incident and actions that were taken toward the incident with proper
justification, actions taken after the investigation of the incident like increased post-
market surveillance, corrective and preventive action with respect to the design and
manufacture of the device, and device recall. The importer can submit the reports on
behalf of the manufacturer with his consent. Their reports however should be identi-
cal, and the Minister should be informed about this arrangement.
3.5 Recall
The Minister shall be given the following information before any recall: details of
the device (name, identifier, etc.); contact of the manufacturer, importer, and the
establishment; reason for recall and associated details; assessment of the associated
risk with the reported problems; the number of affected units (totaling those manu-
factured, imported, and sold in Canada); time period during which the affected units
were circulated in Canada; name of the people to whom the device was sold; copy
of recall communication; strategy planned for conducting the recall (beginning date,
procedure for keeping the Minister up to date on the progress); action to prevent the
recurrence of the problem; and contact information of the representative (of the
manufacturer or the importer) that would answer to all recall-related questions.
The manufacturer and importer of the device would report to the Minister after
the completion of recall with the results and action taken to prevent the problem
from occurring again. The importer can do the submission on the manufacturer’s
behalf as long as they are identical and would inform the Minister of the same.
356 K. Singh
3.6 Implant Registration
The manufacturer shall provide tow implant registration cards with the implant that
would contain the details of the manufacturer and the person designated by the
manufacturer for collecting implant registration information; a notice informing the
patient that the purpose of the card is to allow the manufacture to advise the patient
of new information regarding safety, effectiveness, or performance of the implant
and any corrective action required; and statement telling the patient to notify the
manufacturer of an address change. An implant registration card would contain the
following information: device details, details of the healthcare professional who did
the implant procedure, date the device was implanted, details of the healthcare facil-
ity, and patient details. The card would be printed in both official languages and can
be a total of four (two in each language). The staff member of the healthcare facility
shall fill out the card immediately after the procedure and give one card to the
patient and the other to the manufacturer. Patient’s personal details would not be
entered on the card forwarded to the manufacturer without consent of the patient or
unless required by law. The manufacturer can ask the minister in writing to use an
alternative method for device registration other than the cards described above. If
the Minister feels that the alternate method can achieve the same goals as the cards
then he can authorize this method.
3.7 ustom-Made Devices and Medical Devices

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to Be Imported or Sold for Special Access
Application
In this section, special access means access to medical devices that would be avail-
able for emergency use when all other traditional therapies have failed.
General
The Minister would authorize the import and sale of a class III or IV custom-made
medical device for special access.
Authorization
The details of the application would include details of the device; number of
requested units; manufacturer/importer details; contact of the representative; diag-
nosis, treatment, or prevention for which the device would be used; statement
containing the reasons why the device was chosen for the respective condition and
its risk and benefits; details of the healthcare facility where the device would be
used; safety and effectiveness of the device; written statement by the healthcare
professional that he would inform the patient about the risks and benefits of the
device; directions for use if required; and in the case of a custom-made device, “a
copy of the healthcare professional’s written order to the manufacturer giving the
design characteristics of the device.”
The Minister would authorize the device if he establishes that the benefits pro-
vided to the patients by the device outweigh the associated risks, health and safety
of the patient is not compromised, there is no alternative device available in the
country, and the authorization of the device would not be misused by the manufac-
turer or the importer to bypass the previous requirements for general devices. The
issued authorization shall point out the number of units authorized for importing,
number of units authorized for selling, and details of the healthcare professional to
which the device would be sold.
Additional Information
The Minister may request any additional information necessary for authorization or
even after authorization. The minister may cancel the authorization if he feels that
the conditions for authorization are no longer being met or requested information is
not submitted.
Labeling
The label of the custom-made device shall contain the name of the manufacturer
and name of the device and indicate if the device is custom made or being imported
or sold for special access.
Distribution Records
The manufacturer or importer is expected to maintain the distribution records of

these devices in a similar manner as described before.
Reporting an Incident
The healthcare professional shall report the incident within 72 h of its occurrence
with the same regulations described above.
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Implant Registration
Same rules apply as above for the registration of special access devices.
3.8 edical Devices for Investigational Testing Involving

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Human Subjects
General
A manufacturer or importer may sell the device (class II, III, or IV) to a qualified
investigator to carry out investigational testing if the manufacturer or importers have
an issued authorization and have records containing the necessary information
described below.
Records
The records would contain the following information: details of the manufacturer
and importer, device details, materials used in its manufacture and packaging, fea-
tures of the device that allow it to be used for the respective medical condition, list
of countries other than Canada where the device has been sold and the details of the
sale, risk assessment and the risk reduction measures taken during the investiga-
tional testing, names of potential investigators to whom the device would be sold,
institutional details where the testing would be conducted, protocol of the testing
with details about device units required, hypothesis of the study, time period of the
study, the patient consent form, copy of device label, and a written undertaking from
each investigator; to conduct the investigational test by the protocol, inform the
enrolled patient about any potential risks and benefits associated with the device, do
not allow the use of the device by personnel other than the investigator, and report
any incident that might happen during the study within 72 h of its occurrence.
Authorization
A written application would be submitted to the Minister for authorization. The

Minister would issue the authorization if he feels that the device can be used for
investigational testing without affecting the safety of the patients, investigational
testing takes care of the best interests of enrolled patients, and that the objective of
the testing would be achieved. The authorization shall specify the name of the quali-
fied investigator to whom the device would be sold, kind of diagnosis or treatment
for which the device would be sold, number of units authorized for selling, and the
protocol for the authorized investigational testing.
Additional Information
The Minister may request additional information if he feels the need for it. The
conditions that may prompt this request are as follows: if the testing can seriously
endanger the health and safety of the patients, the testing contradicts the best inter-
est of the patients, the objective of the testing may not be achieved, the investigator
is not respecting the undertaking, and submission of false or misleading informa-
tion. If there is failure of submission of the above documents or if the Minister
identifies some problem with the submission, then he would notify the applicant in
writing with explanation to either stop the sale of the device or cancel their
authorization.
Labeling
The device label would contain the name of the manufacturer and the name of the
device. The statements “investigational device” and “to be used by qualified inves-
tigators only” in English and in French would be indicated on the device. In case of
IVDD (In Vitro Diagnostic Device), the statement “The performance specifications
of this device have not been established” would be written in English and French.
Advertising
Only the person who is authorized for importing and selling the medical device for
investigational testing can advertise it. The advertising has to clearly indicate that
the device is for investigational testing purposes.
Other Requirements
Maintenance of distribution records, complaint handling, mandatory problem

reporting, recalls, and implant registration requirements are the same as described
above in previous sections.
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4 New Zealand Medical Device Regulations
4.1 Legislation
The Medicines Act 1981 and its Regulations define the governing principles for the
supply of medical devices in New Zealand. If other regulations apply on the device,
then they need to be complied. The supplier has to ensure that their products comply
with all the legislations.
4.2 Medicines Act 1981
It specifies the legal definitions for therapeutic purpose, medical device, and medi-
cine. It defines the requirements for advertising and institutes the penalties for
breaches of the Act. The key sections of the Act are:
• Interpretation
• Meaning of medical device
• Meaning of therapeutic purpose
• Powers of the Minister to prohibit imports, etc. of medicines
• Restrictions on the sale of medical devices
• Compliance with standards
• Medical advertisements
• Enforcement
• Miscellaneous provisions
• Interpretation: This section outlines the meaning of terms used throughout the
act. These terms essentially have similar meanings to those described for the
United States and other countries. It is suggested to go through the Medicines
Act 1981 for further reading.
• Meaning of medical device: In this act, a medical device means any device,
instrument, apparatus, appliance, or other article that is intended for use in
humans for therapeutic purposes and not by any pharmacological, immunologi-
cal, or metabolic means. The medical device would include a material that
achieves the abovementioned goals. The medical device would also include any-
thing that is going to be used with the device.
• Meaning of therapeutic purpose: This means the medical device should prevent,
diagnose, monitor, alleviate, treat, cure, or compensate for a disease, ailment,
defect, or injury. It should influence, inhibit, or modify a physiological process.
The device has to test the susceptibility of person to a disease or ailment or influ-
ence, control, or prevent conception or test for pregnancy or investigate, replace,
or modify parts of the human anatomy.
• Powers of the Minister to prohibit import, etc. of medicines: The Minister may
prohibit the import, manufacture, packing, sale, possession, supply,
a dministration, or other use of medicines or medical devices by giving a notice

in the Gazette. This prohibition may be permanent or conditional (not exceeding
1 year), but the Minister can exercise this power only once. He has to inform any
concerned person in writing about his reasons of prohibition. It is an offence if a
person goes against this Act.
• Restrictions on the sale of medical devices: The Director-General can deem a
device to be unsafe and inform the importer or manufacturer in writing with his
reasons. The importer or the manufacturer would have to satisfy the Director-
General in return that the device is safe. They would have 45 days to send their
reply from the date of notice. The Director-General may request for more evi-
dence if he is not satisfied with those provided. If the Director-General has not
questioned the safety of the device, then it should not be assumed that the device
is safe as any new information may prompt him to do so. If there is an offence
reported against more than two devices that they are of the same kind, then they
would be considered the same until otherwise proven. If a seller fails to comply
with the Director-General’s request and sells the medical device or starts selling
the medical device before receiving a positive notification from the Director-
General, then the offending person is liable to imprisonment for up to 6 months
or a fine of $5000.
• Compliance with standards: The medical device and all its components (materi-
als and medicine it comes with, etc.) would need to comply with the standard.
The seller has to clearly inform the purchaser if the device that he is buying is
different from what the standard is defined for. The following things would deem
a medical device to deviate from the standard: (a) any addition that is not permit-
ted by the regulations, (b) the quantity of the addition is greater or more than
permitted, and (c) the addition does not comply with the standard that is defined
for that purpose. It is an offence to disregard the compliance of the standards.
• Medical advertisements: The advertisement of a medical device is prohibited if
it conveys the opposite of what the device is intended for. Any advertisement that
leaves out the name or description of the device, words required to be included
by the regulation, or statement required by the law is not permitted.
• The advertisement that contains statement prohibited by the law or is either false
or misleading is not permitted. The advertisement should directly state or imply
that the medical device is not harmful or for addiction. The advertisement on TV
has to have clear legit letters and should air for sufficient time to be read by the
viewer. The advertisement would be considered misleading if it conveys the
wrong purpose of the medical device, does not clearly tell the safety of the
device, and adds purpose/effects to the medical device it is not designed for. It is
an offence to create misleading advertisements for medical devices under
this Act.
• Enforcement: The officer has similar power as in the United States or Canada to
directly supervise medical devices. They can perform surprise inspections of the
establishment where the device is being manufactured, examine any packages
containing the device, oversee the manufacturing process, collect samples of the
362 K. Singh
device, check the related documents, seize any item, take photographs of articles
and establishment, etc.
• Miscellaneous provisions: When any person other than the manufacturer requests
for a sample of the device, they would need to put in a written request, specify
the purpose of analysis, and pay the cost of the sample. Then an officer would
submit it for analysis unless he believes that request is false or a hoax.
5 Australia Medical Device Regulations
The Australian Therapeutic Goods Administration (TGA) is the regulatory author-

ity in Australia, which takes care of the therapeutic goods regulations in the country.
Medical devices are categorized under therapeutic goods in this country and follow
the Therapeutic Goods (Medical Devices) Regulations 2002. These regulations are
similar to any other country that we have discussed in this chapter. Therefore, here,
we would discuss the Australian Regulatory Guidelines for Medical Devices
(ARGMD). These regulations are currently under review by the Australian govern-
ment, so the version discussed here is soon to be superseded by the new one. The
ARGMD gives information about the import, export, and supply of medical devices
within Australia. It also describes the legislative requirements that control medical
devices.
5.1 The Regulation of Medical Devices
There were approximately 36000 entries of medical devices in the Australian

Register of Therapeutic Goods (ARTG) on July 1, 2011, but today, it may contain
around 1 million devices. The TGA takes a risk-based approach toward regulating
medical devices. The amount of regulation depends on the “intended purpose” of
the device; amount of risk associated with the device in regard to the patient, the
user, and other surrounding people; and internal or external use of the device and the
period of use.
5.2 The Medical Device Classification System
Medical device
classifications Examples
Class I Elastic bandages, tongue depressors, cervical collard, slings, nonsterile
dressings
Class IIa X-ray films, intravenous tubing, contact lenses, catheters
Class IIb Blood bags, dressings for severe wounds, condoms
Medical device
classifications Examples
Class III Coronary artery probes, intrauterine contraceptive devices, medical
devices that contain medicines, such as dressings with an antimicrobial
agent
Active implantable Pacemakers, cochlear implants
medical devices
5.3 Conformity Assessment and ARTG Inclusion
For ARTG inclusion, the manufacturer may use different conformity assessment
procedures according to the risk classification of a device in order to show the
safety, quality, and performance of a device. All devices have to go through confor-
mity assessment except the nonsterile class I devices and those without a measuring
function. However, the lower-risk devices face regulation after ARTG inclusion as
opposed to higher-risk devices, which are subjected to extensive regulation before
ARTG inclusion.
5.4 Medical Device Inclusion Process
The medical device inclusion process has the following steps:

Step 1 – Identify if the product needs ARTG inclusion.
Step 2 – Examine certain things before application.
• Kind of medical device, including IVD (In Vitro Diagnostics) medical device
• Manufacturer evidence for a medical device or IVD medical device
• Classification of medical device or IVD medical device
• Priority review designation
• Supporting documentation for inclusion of a medical device or IVD medical
device, in the ARTG
• Auditing of applications for ARTG inclusion of a medical device or IVD med-
ical device in the ARTG
Step 3 – Enter the TGA Business Services system (TBS).
Step 4 – Submit an application in TBS for Class I nonsterile, non-measuring, and
Class 1 IVD medical devices.
Step 5 – Submit an application in TBS for Class I Medical Device (Export Only)
and Class I IVD medical device (Export Only).
Step 6 – Submit an application in TBS (for all classes except Class I nonsterile, non-
measuring medical device, Class 1 IVD medical device, and Class I medical
device/Class I IVD medical device Export Only)
Step 7 – Processing of application
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Step 8 – Printing the ARTG certificate of inclusion
5.5 Declaration of Conformity Templates (Medical Devices)
The manufacturer has to make a declaration of conformity that confirms that the
device complies with the applicable provisions of the essential principles, classifica-
tion rules, and relevant conformity assessment procedure. In addition, details about
conformity assessment procedure and manufacture of the device should be included.
5.6 Medical Devices with Predetermined Classifications
Group A
These devices provide a secondary effect to the patient along with its main intended
purpose. These devices also contain nonviable animal origin material, any materials
of microbial or recombinant origin like hyaluronic acid. Some examples of such
devices include wound dressings with collagen and heart valves with animal tissue
leaflets.
Group B
This group includes breast implants; knee, hip, or shoulder joint replacement
implants; contraceptive devices; active implantable medical devices; implantable
accessories; active implantable medical devices; and active devices that are meant
to control, monitor, or influence the working of an active implantable medical device.
Group C
This group contains devices like blood bags (with anticoagulant); ancillary medical
devices (used in joint replacement surgery); devices meant for disinfecting, clean-
ing, rinsing, or hydrating contact lenses; contraceptive medical devices; and those
that are non-implantable or invasive for long-term usage.
Group D
Medical devices like non-active medical devices that record X-ray diagnostic
images are part of this group.
Group E
This group contains devices that would be used to clean another medical device
physically, devices for export, and devices that consist of nonviable animal origin
material and are designed to come in contact with the skin and are nonsterile.
5.7 omparable Overseas Regulators for Medical

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Device Applications
The TGA accepts certifications from overseas regulators like the European union,
US FDA, Health Canada, Medical Device Single Audit Program (MDSAP) Auditing
Organization, and the Ministry of Health, Labor and Welfare and Pharmaceutical
and Medical Devices Agency of Japan. The manufacturer has to follow a guidance
developed by the TGA to include in their abridgement application.
5.8 Varying Entries in the ARTG: Medical Devices and IVDs
The sponsor would request the TGA to vary the entry in the ARTG if any previous
information in the ARTG has changed. The variation can be requested in situations
like information in the ARTG is no longer valid, manufacturer details have changed,
GMDN code (Global Medical Device Nomenclature System Code) of the device
has been revised, the device has a new intended purpose now, variants are added to
the device, the device identifier has changed, the UPI (unique product identifier) of
the device has been amended, sponsor desired to vary the list of IVD devices in the
ARTG entry, etc.
5.9 Changing the Sponsor of Therapeutic Goods
The ATG needs to be informed within 3 months of the sponsor change along with
the transfer assignment. The sponsor needs to submit a notification form with all the
details; the ARTG entries are updated within 10 working days, and the new certifi-
cate can be downloaded after 24 h.
366 K. Singh
5.10 Clinical Evidence Guidelines: Medical Devices
This section outlines the clinical evidence guidelines for the following devices: total
and partial joint prostheses, cardiovascular devices to promote patency or functional
flow, implantable pulse generators, heart valve prostheses, and supportive devices –
meshes, patches, and tissue adhesives. The clinical evidence is required by the
Australian government to ensure the safety and performance of the device. The
clinical evidence needs to remain on the register as long as the device is on the
ARTG list. It may be re-requested at any time. The clinical evidence should consist
of documented literature where the device has been used for its intended purpose.
The risk or safety profile of the device can then be demonstrated such that all the
undesirable effects and hazards associated with the device have been reduced. The
classification of the device would dictate the amount of clinical evidence to be sup-
plied along. This clinical evidence would be updated and reviewed regularly as new
information based on post-market surveillance activities and as product experience
become available.
5.11 ARTG Search
The ARTG register can be lawfully supplied in Australia. The Consumer Medicines
Information (CMI), Product Information (PI), and public summary documents can
be obtained from the ARTG. The sponsors can request cancellation of their entries
into the ARTG. The secretary has to authorize these cancellations. The cancellation
provisions in the Act that can be requested by the sponsor are:
• Cancellation of listed or registered therapeutic goods: section 30(1)(c)
• Cancellation of biologicals: section 32GA(1)(d)
• Cancellation of medical devices: section 41GL(d)
5.12 Regulatory Affairs Consultants
These consultants offer services like advice and assistance with the regulatory
requirements. Listed are some of the industry organizations that can provide assis-
tance with the regulatory requirements:
• ACCORD Australasia
• ARCS Australia
These are the names of the companies and they appear as it is on their website:
• Association of Therapeutic Goods Consultants Inc.
• AusBiotech
• Australian Dental Industry Association

• Australian Self-Medication Industry Association
• Complementary Medicines Australia (CMA)
• Pathology Technology Australia
• Medical Technology Association of Australia (MTAA)
5.13 Adverse Event Reporting
The sponsors would report the adverse events or the near adverse events that occur
in Australia to the TGA’s Incident Reporting and Investigation Scheme (IRIS). The
definition of adverse event is the same in TGA as discussed in previous chapters.
However, a near adverse event is an incident associated with the device that might
have caused death or a serious injury if not for a timely intervention.
Exemptions to Reporting
There are eight exemption rules that can prevent the reporting of an adverse event:
1. Deficiency of a new device found by the user prior to its use, for example, if a
sterile single-use device packaging is labeled with caution “do not use if package
is opened or damaged” and the package seals are found opened.
2. Adverse event caused solely by patient conditions; such a condition should be
preexisting or happening within the patient at the time of device use, for exam-
ple, if the patient dies after dialysis because he/she had an end-stage renal
disease.
3. Service life of the medical device, for example, a pacemaker loses its sensing
after reaching the end of life, the elective replacement indicator has set out in due
time according to the device specification.
4. Protection against a fault functioned correctly; this means that the design of the
device protected against a hazardous situation. For example, an infusion pump
stopped due to malfunction, and the alarm went on as intended and therefore,
prevented any injury to the patient.
5. Remote likelihood of occurrence of death or serious injury, for example, a soft-
ware bug is identified in a pacemaker supplied to the market, and the likelihood
of occurrence of a serious injury with a particular setting is remote. Also no
patients have experienced any adverse health effects.
6. Expected and foreseeable side effects that are documented in the manufacturer’s
instructions for use or labeling; an expected side effect that has been clearly
documented in the manufacturer’s submitted documents need not be reported.
7. Adverse events described in an advisory notice; if an adverse event occurs after
the manufacturer issues an advisory notice, it does not need reporting.
8. Reporting exemptions granted by the TGA; the sponsor may request the TGA to
exempt common and well-documented events from reporting or change it to
periodic reporting on a case-by-case basis.
368 K. Singh
5.14 Process of Reporting
The following information needs to be supplied to the TGA’s IRIS system in regard
to an adverse event:
• Source of information and the details of the reporter
• Device identification
• ARTG number of the device
• Date of occurrence
• Elaborate description of the event
• Date of implant, if applicable
• Details of any investigations or corrective actions taken by the sponsor or
manufacturer
• Information of any similar events
The report is submitted in three stages: initial report, follow-up report, and final
report. The initial report would be prepared by the sponsors according to the legisla-
tive time frame, and additional information is given as it becomes available. The
status of any additional investigations carried out by the manufacturer would be
provided in the follow-up report. The final report would contain the things above
and should be submitted within 90 days of the initial report.
5.15 Annual Charge Exemption Scheme
The Annual Charge Exemption (ACE) scheme gives a provision to exempt the
annual charge for a good that is registered, listed, or included in the ARTG until it
first starts generating turnover. The purpose of the scheme is to acknowledge the
fact that TGA’s post-market monitoring costs should only be acquired by goods that
have been established into the market. This scheme allows sponsors to register their
goods into the ARTG in advance before their marketing without annual charge.
Once an ARTG entry begins generating turnover in Australia, the exemption ends,
and the sponsor has to pay the annual charge for the respective ARTG entry each
financial year till it is cancelled from the ARTG.
6 Japan Medical Device Regulations
The Pharmaceutical and Medical Device Agency (PMDA) and Ministry of Health,
Labor, and Welfare (MHLW) regulate the medical devices and pharmaceuticals.
They use a similar “risk-based classification system” to categorize medical device
into four classes: class I being the lowest potential risk and class IV with the highest
potential risk. In 2014, the Japanese Pharmaceutical Affairs Law (JPAL) was
replaced with Pharmaceutical and Medical Device Act (PMDA). The PMD covers
major areas of device regulations like quality management system compliance,
device registration, medical software, and third-party certifications. The manufac-
turers have to comply with the current PMD Act to market medical devices in Japan.
There are three essential aspects to Japan’s regulatory information:
(a) Classification and Product Registration
The PMDA follows the Japan Medical Device Nomenclature (JMDN) sys-
tem, which is similar to US FDA’s product code classification, where codes are
fixed with reference to Global Medical Device Nomenclature (GMDN). These
“generic names” are then classified from class I to IV depending on the poten-
tial risk associated with them. Class I devices contain the lowest potential risk
as far as the patient health is concerned. Class I devices are registered through
a process called “notification.” All notification applications would contain a
detailed device description (measurements, materials involved, etc.). Some
examples include X-ray films, scalpels, and in vitro diagnostic devices. Class II
devices include moderately low-risk medical devices, like digestive catheter,
electronic endoscopes, and dental alloys. Class II devices have to undergo “cer-
tification” that is reviewed by a Registered Certification Body (RCB). These
devices may be classified as either controlled medical device (approved by
PMDA) or designated controlled medical device (certified by RCB). Those
devices, which cannot be certified as class II devices would have to submitted
for approval as class III and class IV devices. Class III medical devices present
a relatively high risk to patients if they malfunction. Such devices include dia-
lyzers, hemodialysis equipment, mechanical ventilation apparatuses, etc. Class
IV devices are the highest-risk devices that may be life-threatening under a
malfunction, for example, artificial cardiac valves, pacemakers, and stent grafts.
Class III and class IV medical devices are specially controlled medical devices,
class III medical devices can be reviewed by either RCB or PMDA, and class
IV medical devices must be reviewed by PMDA only. CE mark and FDA
approval are not accepted in Japan but can definitely speed up the registration
process. The device registration does not expire in Japan; however, it needs to
be renewed in every 5 years. All documents submitted to the PMDA or RCB
have to be translated to Japanese.
(b) Foreign Manufacturer Registration (FMR)
The foreign manufacturers have to undergo FMR in addition to product reg-
istration to market their devices in Japan. A FMR certificate is valid for 5 years
and should be renewed at least 5 months before the certification expires. The
Designated Marketing Authorization Holder (D-MAH) or the Marketing
Authorization Holder (MAH) would first obtain a business number by submit-
ting a business number registration form. The Japanese regulatory officials
from the PMDA would then perform audits/documentary inspection. After this
the D-MAH or MAH would submit the FMR application.
(c) Device Reimbursement
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After the regulatory approval of a medical device, it is mandatory to submit

a reimbursement request to the MHWL already defined. There are six general
reimbursement categories: A1, A2, B, C1, C2, and F. A and B categories contain
already categorized medical devices, and C and F categories have relatively
new devices. The decision on A and B devices is issued quickly, whereas for C
devices, the applicant has to wait a little longer.
7 Singapore Medical Device Regulations
The Singapore regulation is called the Singapore Health Products Act of 2007, and
it demands all medical devices to be certified by an accredited Certification
Assessment Body (CAB) that is registered in the Singapore Medical Device
Information and Communication System (MEDICS). All devices used for treatment
in hospitals and patient clinics have to be certified and distributed under an “estab-
lishment license.” This regulation prohibits the usage of any device by the hospitals
and clinics that are not certified, registered, or legally distributed. This ensures the
quality and integrity of all medical devices throughout the distribution process.
Some high-risk medical devices may qualify for an “abridged” product evalua-
tion if they have already been approved by one of the following regulatory bodies:
US FDA, EU Notified Body, Health Canada, Australia’s TGA, and Japan’s
MHLW. The device submitted for abridges approval must be identical to that
approved by the abovementioned authorities. In addition to certification by the
Health Sciences Authority (HSA), registration and licensed distribution require-
ments and the supply and use of medical devices in Singapore may be subject to
other regulations, such as the provisions of the Private Hospitals and Medical
Clinics Act and the Radiation Protection Act. Requirements may differ with respect
to the type of medical device under consideration. The manufacturers also have to
maintain a quality management system that meets the requirements of HAS’s
already defined Good Distribution Practice for Medical Devices (GDPMDS) stan-
dard, which is similar to the international standard ISO 13485.
8 United Kingdom Medical Device Regulations
Medicines and Healthcare products Regulatory Agency (MHRA) is the authority

which enforces the law on medical devices in the United Kingdom. The following
regulations are important for supplying medical devices in the United Kingdom
or Europe:
• The Medical Devices Regulations 2002 (SI 2002 No 618, as amended)
• The General Product Safety Regulations 2005 (SI 2005 No 1803)
These regulations fall under the Customer Protection Act from 1987 but are still
used by MHRA today.
8.1 The Customer Protection Act from 1987
The MHRA can release prohibition notices to stop the supply of any goods which
would be deemed unsafe or noncompliant with the regulations. They can warn the
manufacture to issue warnings about devices that are unsafe. They can pass suspen-
sion notices for any device based on suspicion that safety provisions have been
disobeyed. They can even forfeit orders for goods for the same reason. The MHRA
can request additional information to contemplate their decision for a revoke or
prohibition or to issue a warning.
8.2 The Medical Devices Regulations 2002
In this act, the MHRA can issue a compliance notice to the offenders and request the
correction of noncompliance or a restriction notice to restrict the sale of a particular
device or devices of a specific class or description.
8.3 The General Product Safety Regulations 2005
The manufacturer is responsible for ensuring that all the medical devices made,
imported, distributed, or sold in the United Kingdom are safe for the consumers and
follow the regulations set forth in regard to labeling. The GPSR requires all products
to be safe in their regular and reasonable usage; therefore, all manufacturers have to
demonstrate compliance with the safety regulations. To ensure this, they can take
corrective action, recalls, and report safety incidents. They are also liable for their
products under the Consumer Protection Act 1987 if their product causes harm or
death to any of their consumers.
8.4 Failure to Comply with the Regulations
If MHRA feels that the manufacturer has committed a serious offence by not com-
plying with these regulations or not meeting the conditions of a notice issued to
them, then they may be subject to prosecution, which includes a penalty of an
unlimited fine and/or imprisonment for 6 months.
372 K. Singh
8.5 Inspections
The MHRA can perform inspections of the manufacturing site at any time if they
feel the need to do so. It follows the protocol in Consumer Rights Act 2015 that the
MHRA can enter premises and can inspect the devices, can evaluate the manufac-
turing procedures and testing facilities, and can ask for business documents and
detain any if required. Any information gathered in the course of an inspection will
be considered confidential according to the confidentiality provisions in Article 20
of the Medical Devices Directive (93/42/EEC), article 19 of the In Vitro Diagnostic
Medical Devices Directive (98/79/EEC), and article 15 of the Active Implantable
Medical Devices Directive (90/385/EEC). These were included into UK legislation
by the Enterprise Act 2002, which allows the release of information to third parties
in certain circumstances.
8.6 Appeals Procedure
The manufacturer has the right to appeal any decision made by the MHRA through
Chartered Institute of Arbitrators (CIArb). The appeal procedure would depend on
the regulatory decision of the MHRA like prohibition notice (Consumer Protection
Act, schedule 2, part 1), notice to warn (Consumer Protection Act, schedule 2, part
2), recall notice (General Product Safety Regulations, Regulations 15 and 17), clini-
cal investigation notifications (Medical devices Regulations, Regulations 16 and
29), notified body designations (Medical Devices Regulations, Regulation 45), and
applications for exceptional use of noncomplying devices (medical devices regula-
tions, regulations 12, 26, and 39). Appeals against other regulatory decisions would
be processed separately probably through courts. MHRA would notify the manu-
facturer of their regulatory decision along with their rights to appeal.
8.7 Exceptional Use of Noncomplying Devices
A manufacturer may request to supply a medical device that is noncompliant with

the law if there are no options available. This is known as an “exceptional use of a
non-CE marked medical device.” There are separate guidelines for such devices
under Regulation 12(5) of the Medical Devices Regulations 2002. This also includes
active implantable medical devices in regulation 26 and for in vitro diagnostic medi-
cal devices under regulation 39(2).
8.8 Complaints
Complaints can be made about the behavior of MHRA personnel or advice given by
them (except enforcement decisions) according to complaints procedure. All
MHRA compliance inspectors and investigators are obligated to conduct their
inspections and investigations according to internal operating procedures.
9 European Medical Device Regulations
The European regulation comprises of rules concerned with marketing, both placing
and supplying, its human use, and accessories required for such devices. These reg-
ulations are also true for any clinical investigations that are being carried out for
these devices (not discussed here). Medical devices with both medical and non-
medical purpose have to satisfy all the requirements associated with devices with
and without the intended purpose. The regulation does not apply to in vitro medical
diagnostic devices, medicinal products, human fluids, cosmetic products, trans-
plants, and products containing live biological organisms like bacteria and virus and
food mentioned in the regulation. In this chapter, only the general requirements
associated with the safety and performance of the device are discussed.
9.1 General Requirements
The medical device has to deliver the performance as intended by the manufacturer
and would be designed and manufactured for the same. It should be safe and effec-
tive while doing so and should not affect the clinical condition or safety of the
patient or users in general. The manufacturers will supply the safety documentation
along with the device, which would include not only the risk management plan but
also any predicted hazards and estimated risks. The manufacturer shall employ risk
control measures during the design and manufacture of the device. The manufac-
turer would also manage risks so that the residual risk associated with each hazard
is limited to the acceptable level. For this, the manufacturer would erase or decrease
the risks through safe design and manufacture. He would also take appropriate pro-
tection measures like alarms and provide safety information and user manual. In
case of user error-related risks, the manufacturer shall reduce the risks related to the
ergonomic features of the device and the usage environment and provide training
for use wherever possible. The packaging of the device would be designed to pre-
vent it from damage during transport and storage.
374 K. Singh
9.2 Requirements Regarding Design and Manufacture
The materials used to design the device would be chosen in regard to (a) toxicity, (b)
compatibility between materials and substances and biological tissues and body
fluids, (c) compatibility between different parts of the device, (d) impact of pro-
cesses on material properties, (e) mechanical properties of used materials, (f) sur-
face properties, and (g) confirmation that the device meets the defined chemical and/
or physical specifications. The device would be designed and manufactured to
reduce the risk imposed by substances or particles like water, degradation products,
and residues. The device or part of device that will come in contact with the body
directly or through body fluids will contain only 0.1 %w/w of the respective sub-
stance. This information would also be present on the label of the device. The device
packaging has to be sterilized by approved methods. In case of non-sterilized
devices, the cleanliness of the product has to be maintained while packed and should
be sterilized before use according to manufacturer’s instructions. The labeling
should be clear in terms of sterile and nonsterile devices. The devices shall be
designed to prevent infection and microbial contamination to patients in instances
like cuts and pricks. The design of the device shall allow easy and safe handling,
reduce any possible microbial leakage from the device, and prevent device contami-
nation from any human fluids. The packaging and labeling of the devices would
reflect the same. The devices that contain tissues or cells of animal origin or their
nonviable derivatives would have to be subjected to appropriate veterinary controls:
sourcing, processing, preservation, testing, and handling of tissues, cells, and sub-
stances of animal origin; safety in terms of viruses and other transmissible agents
would be ensured by appropriate validation methods for elimination of such agents
during manufacturing while maintaining the clinical benefit of the device. In order
to reduce the risk imposed by medical devices that are used by laypersons, the
instruction for use provided by the manufacturer should be very simple and easy to
understand. Its design should ensure safety at each stage of use or after training,
reduce the risk associated with usage like cuts and pricks, and finally reduce error
by the user during handling.
9.3 equirements Regarding the Information Supplied

R
with the Device
In previous chapters and other countries’ regulations, labeling has been covered in
detail. The European regulation entails similar instructions regarding labeling. In
brief, each device has to have a label that contains its identity, manufacturer’s name,
and safety and performance profile. The label would appear on the device or its
packaging or both. It would contain the name of device, manufacturer’s trademark,
address of the manufacturer, contents of the device (biological or not), lot number/
serial number, indication of clinical or nonclinical use, and in case of implants the
serial number. The device shall contain instructions of use that are easily understood
by the user or the website link where they can be found. The information on the
label should be relevant to the respective device and must contain a radio-frequency
identification (RFID) or bar codes. The risk information like device limitations,
contraindications, precautions, or warnings has to be supplied with the device. The
manufacturer has to use internationally recognized symbols in the supplied infor-
mation wherever possible. In places where this is not possible, the manufacturer has
to define those symbols in the accompanying documentation.
9.4 Post-market Surveillance
The manufacturer shall plan, establish, document, implement, maintain, and update
a post-market surveillance system that is relevant to the risk class of the product and
type of device. This post-market surveillance system would be employed to gather,
record, and analyze relevant data on the quality, performance, and safety of a device
for its entire lifespan and to decide, implement, and monitor any preventive and cor-
rective actions that need to be taken. Some examples are updating of benefit-risk
determination and improving risk management, updating clinical evaluation, updat-
ing the summary of safety and clinical performance, etc. If during the post-market
surveillance a need for preventive or corrective action arises, the manufacturer shall
take appropriate measures and inform the respective authorities or notified body.
9.5 ooperation Between Member States, Medical Device

C
Coordination Group, Expert Laboratories, Expert Panels,
and Device Registers
The Member States shall allocate the competent authority or authorities that would
be responsible for the implementation of this regulation. These authorities would
have the powers, resources, equipment, and knowledge necessary to carry out the
tasks associated with this regulation. The names and contact of the competent
authorities shall be given to the Commission which would then publish a list. The
authorities shall cooperate with each other and the Commission. A medical device
coordination group (MDCG) would be appointed by each member state for 3 years
that can be renewed. The members of MDCG would be chosen based on their exper-
tise and competence in medical device field and in vitro diagnostic medical devices.
The MDCG would (a) establish rules for the acceptance of opinions or recommen-
dations regarding cases of urgency, (b) assign tasks to reporting and co-reporting
members, and (c) implement the regulation regarding the conflict of interests and
(d) functioning of subgroups.
376 K. Singh
9.6 Confidentiality, Data Protection, Funding, and Penalties
The confidentiality of information shall be maintained which would include any

personal data or commercially confidential data for the purpose of inspections,
investigations, or audits. The Commission shall cover any costs associated with
joint assessment activities. The penalties shall be imposed in case of infringement
of the provisions of this regulation, and necessary measures would be taken for their
implementation.
References
1. @TUVSUD. “UNDERSTANDING THE REGULATORY REQUIREMENTS FOR

MEDICAL DEVICES IN INDIA”, https://www.tuvsud.com/en/industries/healthcare-and-
medical-devices/medical-devices-and-ivd/medical-device-market-approval-and-certification/
regulation-of-medical-devices-in-india
2. @Regdesk. “An Overview of Medical Device Regulations in China”, January 9, 2019, https://
www.regdesk.co/an-overview-of-medical-device-regulations-in-china/
3. Medical Devices Regulations (SOR/98-282)
4. Medicines Act 1981
5. Therapeutic Goods (Medical Devices) Regulations 2002, Statutory Rules No. 236, 2002, made
under the, Therapeutic Goods Act 1989
6. @TGA. “Australian regulatory guidelines for medical devices (ARGMD)”. October 18, 2019,
https://www.tga.gov.au/node/5308
7. @Regdesk. “An Overview of Medical Device Regulations in Japan”, January 20, 2019, https://
www.regdesk.co/an-overview-of-medical-device-regulations-in-japan/
8. @GOV.UK, “Medical devices: the regulations and how we enforce them”, February 26.
2019, https://www.gov.uk/government/publications/report-a-non-compliant-medical-device-
enforcement-process/how-mhra-ensures-the-safety-and-quality-of-medical-devices
9. @EUR-Lex, “REGULATION (EU) 2017/745 OF THE EUROPEAN PARLIAMENT AND
OF THE COUNCIL”, April 5, 2017, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CE
LEX:02017R0745-20170505#tocId142
Index
A characterization procedure, 164

Accelerated Degradation Test, 166 chemical characterization, 163
Acceptable quality levels (AQLs), 193 degradation products, 167, 168
Acid treatments, 108 general principles, 164
Acquired immunodeficiency syndrome hazardous leachable substances, 182
(AIDS), 192 nanomaterials, 183
Activated partial thromboplastin time polymeric medical devices, 166
(APTT), 170 potential degradation products, 165, 166
Alkaline hydrolysis treatments, 108 residual EO, 181
Amino acids, 118 testing nanomaterials, 183
Analyte specific reagents (ASRs), 207 tests, 163
Animal models, 169 tolerable intake, 182
Annual Charge Exemption (ACE) scheme, 368 toxicokinetics, 184
Arteriograms, 168 Biological indicators (BIs), 148
Australia Medical device regulations, 362 Bovine blood derivatives, 117
adverse events, 367 Bovine Corneal Opacity and Permeability
ARTG, 363, 366 (BCOP) test method, 185
classifications, 362–365
clinical evidence, 366
declaration of conformity, 364 C
inclusion process, 363 Calibration, 133
IVD, 365 Canada medical device regulations, 350
process of report, 368 additional information, 357
regulatory requirements, 366 advertising, 351
sponsor, 365 amendments, 352
Australian Regulatory Guidelines for Medical Class I, 351
Devices (ARGMD), 362 Class II/III/IV, 351
complaint handling, 354
custom-made medical device, 356, 357
B distribution record, 354
Bacterial endotoxin, 71 distribution records, 357
Bioburden, 125, 148 establishment license, 353
Bioburden test, 71 application, 353
Biological evaluation, medical devices cancel, 354
allowable limits, 182 refusal, 354
Handbook, https://doi.org/10.1007/978-3-030-91855-2
378 Index
Canada medical device regulations (cont.) test methods, 63

review, 353 test substances, 63
suspension, 354 validation process, 61, 62, 66
foreign manufacturer, 352 validation, 58, 70, 71
implant registration, 356 Clinical investigation plans (CIPs)
label, 357 adverse events and adverse device
labeling requirements, 350, 351 effects, 17
license, 351 amendments, 17
obligation to inform, 353 deviations, 17
obligation to submit certificate, 353 early termination or suspension of
problem report, 355 study, 18
recall, 355 ISO 14155-2, 1, 12 (see also ISO 14155-2)
refusal, 352, 353 statistical considerations, 16
safety, 350 Clinical investigator, 9–11
samples, 352 Clinical Trial Management System, 349
testing, 358, 359 Code of Federal Regulations (CFR), 189, 190
Cardiovascular devices/prostheses, 169 Colony formation cytotoxicity test, 171
Case report form (CRF), 2, 18 Committee for standardization (CEN), 279
CE marking, 302, 305 Common specifications (CS), 327
Central Drugs Standard Control Organization Confidentiality, 5
(CDSCO), 347 Consumer Medicines Information (CMI), 366
Central nervous system (CNS) embolism, 117 Consumer Protection Act 1987, 371
Ceramic surfaces, 81 Consumer Rights Act 2015, 372
Certification Assessment Body (CAB), 370 Continued process verification (CPV), 72
Chartered Institute of Arbitrators (CIArb), 372 Contraceptive devices, 351
China Food and Drug Administration Controls
(CFDA), 349 collection, 100
China Medical Device Regulations, 349 current regional regulatory
Chromatographic methods, 166 requirements, 99
Cleanliness evaluation definitions, 97
bacterial endotoxins, 65 guidance, 99
bioburden test, 64 handling, 101
cytotoxicity, 70 inspection, 99, 100
detailed view, 64 personnel, 98
inorganic contaminants, 68, 69 procedures, 98
organic contaminants (see Organic quality system elements, 97
contaminants) scope, 97
particulate contamination, 69 sourcing, 99
visual test, 64 storage and transport, 101
Cleanliness of orthopaedic implants terms, 97
application, 57 traceability, 100
cleaning process, 72 Creutzfeldt-Jakob disease (CJD), 118
CPV, 72 Current good manufacturing practice
documentation, 72 (CGMP), 221
implantable devices, 57 Cytotoxicity, 70, 71
manufacturing process, 58
physical, chemical and biological
contaminants, 59 D
requirements, 58 Declaration of Helsinki (DoH), 4
design of cleaning process, 60, 61 Derived no-effect level (DNEL), 284
efficiency, 63 Designated Marketing Authorization Holder
QMS, 58 (D-MAH), 369
risk management, 59, 60, 65 Design history file (DHF), 222
sampling process, 62 Design of clinical investigation, 5
Index 379
Device history records (DHRs), 225 EU and EC 1272/2008

Device master records (DMRs), 225 classification
Direct peptide reactivity assay (DPRA), 185 flammable liquids, 265
Disclosure of residual risk, 55 C&L notification/inventory, 279
Disease Control and Prevention (CDC), 192 CLP, 261
Document and data control, 7 hazard classes, 263
Documentation, 7 labelling, 272, 276
Dosimetry/dosage measurement packaging, 278, 279
calibration, 133 safety data sheet, 281–284, 288, 289,
definition, 132 291, 292
dose mapping/gamma irradiators, 137, 138 EU declaration of Conformity, 304
electron beam irradiators, 138, 139 EU-722/2012 Regulation
establishing dose, 135, 136 animal tissues, 310
frequency, 142 conformity assessment procedures,
installation qualification, 136 311, 312
ISO, 142 directive, 311, 313
mapping data, 141 TSE, 310
mapping exercise, 141 EU Regulation of RoHS, 50, 51
maximum acceptable dose, 135 European database on medical devices
operational qualification, 137 (EUDAMED), 333
placement, 140, 141 European Medical Device Regulations, 373
PQ, 140 confidentiality, 376
routine monitoring position, 141 design manufacture, 374
system selection/calibration, 132 information supplied, 374
uncertainty, 134 Member States, 375
requirements, 373
European Medicines Agency (EMA), 314, 326
E European Parliament, 297, 305
Educational qualification, 5 Ex vivo tests, 168
Electrical and electronic equipment
(EEE), 297
authorized representatives, 303 F
EU declaration of Conformity, 304 FDA-CFR
hazardous substances, 298, 300 administrative practices/procedures, 193
manufacturers, 302 exemptions, 195
Electron beam irradiators, 139 federal preemption, part 808, 205
Electronic Code of Federal Regulations general labeling provisions, 193
(e-CFR), 190 general requirements, part 800, 192
Electrotechnical standardization, 19 IDE, part 812
Environmental Protection Agency (EPA), 195 administrative action, 211
Ethylene chlorohydrin (ECH), 179, 180 applicability, 209
Ethylene glycol (EG), 179 investigational devices, 210
Ethylene oxide (EO) investigators, 212
definition, 145 records, 213
limitations, 152 waivers, 210
microbial effectiveness, 147, 148 importer reporting requirements, 198
packaging sterilized product, 151 individual adverse event reports, 197
processing cycle/temperature/time/ initial importers of devices, part 807
pressure, 146, 147 device establishments, 200, 201
residues, 147, 150 foreign device establishments, 202, 203
routine control/efficacy/ premarket notification procedures,
reproducibility, 148 203, 204
selection process, 146 in vitro diagnostic products, part 809,
sterilization, 145 206, 207
380 Index
FDA-CFR (cont.) Human immunodeficiency virus (HIV), 192

labeling requirements, over-the-counter Human patch test (HPT), 185
devices, 194, 195 Hydrocarbon contaminants, 68
manufacturing reporting requirements, 198
MDR procedures, 197
medical device recall authority, part I
809, 208 IEC 62304, 49
medical device reporting, part 803, 196 IEC 62366:2007, 50
part 806 Imaging from intravascular ultrasound
correction/removals, records, 200 (IVUS), 168
correction/removals, report, 199 Immunotoxicity, 184
reporting requirements, device user Immunotoxicology testing, 176
facility, 196 Implantable devices, 57
user facility reporting requirements, 198 Independent ethics committee (IEC), 211
Federal Food, Drug, and Cosmetic Act (FD&C India Medical Device Regulations, 347, 348
Act), 189 import, 348
Federal Register (FR), 189 manufacture, 348
Federation, 19 Information for safety, 54
Feedback loop, 52 Informed consent, 6–7
observation and transmission, 53–54 Institutional review board (IRB), 220
risk assessment, 54 International Electrotechnical Commission
First fraction positive dose (FFP), 129 (IEC), 19
First no positive dose (FNP), 129, 130 International ISO 19227:2018, 58
Food/drugs International Organization for Standardization
CFR-FDA Parts 800 to 1299, 190 (ISO), 122
Foreign Manufacturer Registration International process standards, 49
(FMR), 369 International product safety and process
Formal agreement, 5 standards, 47
International standard process, 19, 22
International standard requirement, 19
G Intrauterine devices (IUDs), 351
Gas chromatography (HS-GC), 164 Investigational device exemption (IDE), 209
Gelatine, 116 In vitro cytotoxicity, 170, 171
Genotoxicity test, 177 In vitro diagnostic device (IVDD), 359
Global Medical Device Nomenclature In vitro diagnostic (IVD) medical devices, 32
(GMDN), 369 authorized representatives, 328, 332
Global Medical Device Nomenclature System CE marking of conformity, 330
Code (GMDN code), 365 claims, 327
Good clinical practice (GCP), 211 clinical evidence/performance
Good Distribution Practice for Medical evaluation, 336–340
Devices (GDPMDS), 370 confidentiality, 345
Good manufacturing processes conformity assessment, 335, 336
(GMPs), 110 data protection, 345
Guinea pig maximization test definitions, 322–325
(GPMT), 185 distributors, 329
EU declaration of conformity, 330
EU reference laboratories/device
H registers, 343
Haematology, 175 general obligation, manufactures, 328
Hazards, 40–41 harmonized standards, 327
analysis, 32, 56 (see also Risk analysis) identification/traceability/registration, 331
and sequence of events, 39 importers, 329
Hazards-related risks, 59 marketing/services, 326
Health Sciences Authority (HSA), 370 notified bodies, 333–335
Index 381
parts/components, 330 ethical considerations

post-market surveillance, 341, 342 compensation and additional
registration, 332 health care, 4
regulation, 322 DoH, 4
regulatory compliance, person improper influence/inducement, 4
responsible, 329 responsibilities, 4
regulatory status of products/ ethics committee, 3
counselling, 326 final report, 3
safety/performance, 332 general requirements
special purposes, 330 clinical investigator, 9–11
UDI, 331 confidentiality, 5
vigilance data, 342 design of clinical investigation, 5
In vitro haemocompatibility, 169 documentation, 7
In vitro models, 169 final report, 11
In vitro tests, 168 formal agreement, 5
Irritation test informed consent, 6–7
haemocompatibility, 186 monitor, 9
human skin, 186 qualification, 5
in vitro, 186 sponsor, 8
penile, 185 start of clinical investigation, 5
rectal, 185, 186 general requirements for biological tests, 2
Irritation tests, 185 informed consent, 3
ISO 10993, 50 investigation center/investigation site, 3
ISO 13485, 19 medical device, 3
definitions of standard, 22 monitor, 3
international standard, 20 multicenter investigation, 3
model system, 21 preparation of CIPs, 1
for QMS, 19 (see also Quality principal clinical investigator, 3
management system (QMS)) source data, 4
QMS requirements for medical devices source documents, 4
documentation requirements, 22 sponsor, 4
general requirement, 22 subject, 4
management resource, 24 ISO 14155-2
management responsibility, 23 approval and agreement, CIP, 14
measurement, analysis and CIP, 12
improvement, 27 clinical, principal and coordinating clinical
product/service realization, 24–26 investigator, 13
to control contamination, 24 database management, 13
work environment, 24 design of clinical investigation, 16
references, 22 follow-up period, 12
regulatory requirements, 20 identification of CIP, 13
scope, standard, 21 literature review, 14
ISO 14155:2011, 1, 2 medical device under investigation, 14
ISO 14155-1 monitoring arrangements, 13
adverse device effect, 2, 3 point of enrollment, 12
adverse event, 2, 3 preclinical testing, 15
case report form, 2 principal indicator, 12
clinical investigation, 3 recruitment, 12
clinical investigation plan, 3 requirements, 12
clinical investigator, 3 risk analysis and assessment, 15
clinical investigator’s brochure, 3 scope, 12
clinical performance, 3 secondary indicator, 12
conduct and performance, 1 sponsor, 13
coordinating clinical investigator, 3 ISO 14971, 49
382 Index
ISO 14971:2007, 52 plastic surfaces, 81

ISO 14971:2019 scope, 75
benefit, 33 sterilization process, 81
general requirements for risk management terms and definitions, 76
competence of personnel, 35
management process, 35, 36
risk management file, 37 L
risk management plan, 36, 37 Lethality, 148
harm, 33 Limulus amoebocyte lysate (LAL)
intended use, 33 assay, 184
in vitro diagnostic, 33 Limulus amoebocyte lysate (LAL) test, 65
medical purposes, 33 Local lymph node assay (LLNA), 185
post-production, 34
residual risk, 34
risk analysis, 38 M
identification of characteristics, 38 Market Authorization Holder (MAH),
identification of hazards and hazardous 349, 369
situations, 39 Marking, 87, 88
intended use and reasonably Material safety data sheet (MSDS), 147
foreseeable misuse, 38 Medical device classification procedures
risk estimation, 39–43 definition, 231
risk evaluation, 43 exemptions, 232
risk control reclassification, 232
benefit-risk analysis, 45 safety/effectiveness, 231
implementation, risk control Medical device coordination group (MDCG),
measures, 44 344, 375
overall residual risk, 45 Medical Device Information and
residual risk evaluation, 44 Communication System
risk control measures, 45 (MEDICS), 370
risk control option analysis, 44 Medical device listing/premarket
risk management review, 45–46 approval, 235
risk management, 34 Medical Device Regulation (MDR), 29
standard for risk management, 32 Medical devices, 145, 155
ISO technical committees, 19 application of risk management to medical
ISO/TR 24971, 46 devices (see ISO 14971:2019)
Isolated Chicken Eye (ICE) test method, 185 human application, 31
in vitro diagnostic (IVD), 32
ISO 14155-1, 3
J ISO 14155-2
Japanese Pharmaceutical Affairs Law biological evaluation, 1
(JPAL), 368 conformity assessment, 2
Japan Medical Device regulations, 368 testing animals
classifications, 369 animal care/accommodation, 173
device reimbursement, 370 human endpoints, 173
Joint replacement implants planning/performance, 173
ceramic surfaces, 81 requirements, 172
design attributes, 77 results/mutual acceptance, 173
design evaluation, 78, 80 Medical Device Single Audit Program
intended performance, 77 (MDSAP), 365
manufacturer, 81, 82 Medical device tracking requirements
materials, 78, 79 additional requirements/
metal surfaces, 80 responsibilities, 227
normative references, 76 device subject, 226
Index 383
records/inspections, 227 definition, 149

scope, 226 EO concentration measurement, 150
Medical implants, 57 humidity measurement, 149
Medicines and Healthcare products Regulatory PCD, 149
Agency (MHRA), 370–373 temperature measurement, 149
Member States, 299, 304, 306 Over-the-counter (OTC), 192, 208
Metals, 71
Metal surfaces, 80
Microbiological testing, 150 P
Ministry of Health, Labor, and Welfare Parametric release method, 149
(MHLW), 368, 370 Partial thromboplastin time (PTT), 170
Monitor, 9 Performance qualification (PQ), 138
MTT cytotoxicity test, 171 Performance standards development
advisory committees, 234
amendment/revocation, 234
N performance, 234
National Medical Products Administration standards, 233
(NMPA), 349, 350 Periodic safety update report (“PSUR”), 341
Neutral red uptake (NRU), 170 Persistent, bioaccumulative, and toxic (PBT),
New Zealand Medicines Act 1981, 360, 361 243, 283
Non-active surgical implants Pharmaceutical and Medical Device Act
associated implant, 83 (PMDA), 369
design attributes, 84, 85 Pharmaceutical and Medical Device Agency
design evaluation, 85, 86 (PMDA), 368
information supplied, manufacturer, 87, 88 Physical testing, 150, 151
instructions for use, 89 Physicochemical, morphological and
instrument, 84, 90 topographical (PMT)
intended performance, 84 characterization, 165
intended, single use, 90 Plastic surfaces, 81
labelling, 88 Postmarket surveillance
manufacture, 86 definition, 227
marking, instruments, 90 device usage, 227
packaging, 87 FDA, 228
power-driven instruments, 83 order, 227
requirements, 83 records/reports, 229
resupplied instrument, 84 system, 375
selection of materials, 85 Post-sterilization processes, 151
sterilization, 86 Premarket approval (PMA)
Non-CE marked medical device, 372 amendments, 215
Nontechnical language, 6 application, 214
No observed adverse effect level confidentiality, 214
(NOAEL), 182 definition, 214
FDA action, 216
humanitarian use devices, 218–220
O post-approval requirements, 218
Oral mucosa irritation test, 185 supplements, 216
Organic contaminants Process challenge device (PCD), 148
detection method, 68 Product and process-oriented research or
extraction method, 68 development (PPORD), 240
method(s), 67 Product development protocol
Overall residual risk, 55 (PDP), 214
Overkill approach Product information (PI), 366
chemical indicators, 149 Publication policy, 18
384 Index
Q amino acids, 118

Quality management system (QMS), animal charcoal, 117
19–22, 27, 58 animal materials, 115
cycle, 23 control, 95
ISO 13485-registered companies, 20 device contact, 93
(see also ISO 13485) documentation, 96
layout process, 28 evaluation, 95, 96
process approach, 19 hazards and hazardous situations, 94
superior business practices, 20 ISO/TR 24971, 47
Quality system regulation material incorporated, 94
acceptance activities, 223 medical devices, 115
definition, 221 microbiological controls, 94
design controls, 222 milk and milk derivatives, 117
document controls, 222 production and post-production
handling/storage/distribution/ information system, 96
installation, 224 risk control, 95
labeling/packaging control, 224 scope, 92
management responsibility, 221 substances, 94
personnel, 222 tallow derivatives, 117
quality audit, 221 terms and definitions, 92, 93
records, 225 viruses and TSE agents, 95
SOPs, 223 wool and derivatives, 118
Risk management process ISO 14971, 32
R
Radio-frequency identification (RFID), 375 S
Real-time degradation test, 167 Sample item portion (SIP), 126
Registered Certification Body (RCB), 369 Saturated steam, 157
Regulation EC 1907/2006 Scanning electron microscopy (SEM), 183
authorization Scanning probe microscopy (SPM), 183
review process, 252 Scientific Steering Committee (SSC), 314
commission, 257 Sexually transmitted diseases (STDs), 351
definition, 237 Singapore Medical Device Regulations, 370
principle, 238 Single-particle, inductively coupled plasma-
REACH, 238 mass spectrometry (spICP-MS), 183
restriction process, 256 Single registration number (SRN), 332
safety data sheet, 257 Specified risk material (SRM), 315
substances registration, 241, 243 Sponsor, 8
Restriction of hazardous substances (RoHS) Standard distribution of resistances
EEEs, 300 (SDR), 128
Risk acceptability, 52 Standard operating procedures (SOPs), 223
Risk analysis/risk management Steam penetration test, 157, 159
animal tissues/derivatives, 313 Steam sterilization
notified bodies, 317–319 agent, 157
process, 313 assessment effectiveness, 160
risk assessment, 316 indicators, 160
role, 32 ISO, 156
source of material, 314 limitations, 161
starting tissue, 314 medical devices, 160
TSE infectious agents, inactivation/ microbial effectiveness, 157
removal, 315, 316 microbicidal effectiveness, 158
Risk Assessment and Socioeconomic moist heat, 156, 157
Analysis, 256 packed medical devices, 159
Risk management, 32, 59, 60, 65 pre-sterilization, 156
Index 385
product specifications, 158 chemical methods, 108

saturated steam, 157 combined treatments, 109
specification, 156 guanidine and chaotropic chemicals, 109
standards/guidelines, 161 ineffective treatments, 110
superheated steam, 157, 158 infectivity vs. whole-process
validation, 159 validation, 113
Sterility assurance level (SAL), 127, 129, literature review, 103, 104
146, 155 management, 118, 119
Sterilization non-viable animal tissues, 110, 111
definition, 121 ovine-derived and caprine-derived
dose injectable materials, 106
bioburden data, 128 phenolic disinfectant, 109
fraction positive information, 128–130 physical methods, 108, 110
SAL, 127 porcine tissues, 106
VDmax, 131 principles, 105
dose audits, 132 protease treatments, 109
healthcare products protocol, 104
bioburden, 125 risk management, 102
identifying family, 126 scope, 101
SIP, 126 terms and definitions, 101
irradiation tissue infected, 107
agent characterization, 122 Transmissible spongiform encephalopathy
definition, 122 (TSE) risk management, 97
equipment, 123 Transmission electron microscopy
ISO, 122 (TEM), 183
methods, 121
process, 123, 124
validation, 124, 125 U
Stunning methods, 117 UDI device identifier (UDI-DI), 331
SUGAM, 348 UDI production identifier (UDI-PI), 331
Unique device identifier (UDI), 194, 200, 224,
225, 323, 349
T definition, 229
Tallow derivatives, 310, 318 FDA, 229
Therapeutic Goods Administration (TGA), FDA accreditation, 230
362, 363, 365, 367, 368, 370 United Kingdom Medical Device
Total hydrocarbon content (THC), 67, 71 Regulations, 370
Total organic carbon (TOC) method, 67, 71 United Nations Globally Harmonized Systems
Toxicity screening (UN GHS), 261
acute, 175 Universal product code (UPC), 224, 225
animal welfare requirement, 172
carcinogenicity test, 177
degradation products, 178 V
genotoxicity test, 177 very persistent and very bioaccumulative
irritation/skin sensitization, 176 (vPvB) assessment, 243
local effects after implantation, 174 Visual test, 71
reproduction/development, 177
risk management process, 171
systematic toxicity, 174, 175 W
Transmissible spongiform encephalopathy Water-soluble organic contaminants, 68
(TSE) agents, 310
animal tissues, 106
bioassay animals, 112, 113 X
biological mixtures, 110 XTT cytotoxicity test, 171

Medical Device Guidelines and Regulations Handbook

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Medical Device Guidelines and Regulations Handbook

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Prakash Srinivasan Timiri Shanmugam

Medical Device Guidelines

ISBN 978-3-030-91854-5 ISBN 978-3-030-91855-2 (eBook)

The international standard ISO 14155 was formulated by Technical Committee

2 Structure of ISO 14155:2011

The ISO 14155:2011 is divided into several sections, namely:

© The Author(s), under exclusive license to Springer Nature Switzerland AG 2022 1

5. Clinical investigation planning

3.2 Terms and Definitions

3.3 Ethical Considerations

Declaration of Helsinki (DoH)

Improper Influence or Inducement

Compensation and Additional Health Care

It is the responsibility of the participating parties to ensure that clinical investigation

3.4 General Requirements

Clinical Investigation Plan

This is discussed more in part 2.

Design of the Clinical Investigation

Start of Clinical Investigation

The following things should be kept in mind before starting a clinical

In the event of an early termination of the study, it is the sponsor’s responsibility to

Clinical investigator’s brochure and other documents like clinical investigation

• Make sure that device is accountable and traceable.

The monitor is responsible for the following:

The clinical investigator is an appropriately qualified clinician with a license to

4.2 Terms and Definitions

4.4 Clinical Investigation Plan (CIP)

4.5 General Information

Identification of the Clinical Investigation Plan

 linical Investigators, Principal Clinical Investigator, Coordinating

Data and Quality Management

An Overall Synopsis of the Clinical Investigation

Approval and Agreement to the Clinical Investigation Plan

The sponsor, coordinating investigator, and the principal clinical investigator(s) in

4.6 I dentification and Description of the Medical Device

4.7 Preliminary Investigations and Justification of the Study

Previous Clinical Experience

Device Risk Analysis and Risk Assessment

Objectives of the Clinical Investigation

Design of the Clinical Investigation

Deviations from the Clinical Investigation Plan

Amendments to the Clinical Investigation Plan

Adverse Events and Adverse Device Effects

The CIP would contain:

relevant regulations, specifications of those types of events, device-related and

Early Termination and Suspension of the Investigation

Case Report Forms (CRF)

B. Karthika and A. R. Vijayakumar

© The Author(s), under exclusive license to Springer Nature Switzerland AG 2022 19

• The understanding and meeting requirements

6.0. Resource Management

ISO 13485 Standard

• “Risk” – pertains to safety and performance requirements, or meeting regulatory

4.1. The General Requirement

Fig. 2 Quality management system cycle

7.3. Design and Development (Fig. 3)

7.3.1. Design and Development Transfer (New Subclause)

Fig. 3 Design and development process of medical device

7.4.3. Purchased Product Verification (New Added)

• Statistical techniques to analyze data

2 Structure of ISO 14155:2011

3.2 Terms and Definitions

3.3 Ethical Considerations

Declaration of Helsinki (DoH)

Improper Influence or Inducement

Compensation and Additional Health Care

3.4 General Requirements

Clinical Investigation Plan

Design of the Clinical Investigation

Start of Clinical Investigation

4.2 Terms and Definitions

4.4 Clinical Investigation Plan (CIP)

4.5 General Information

Identification of the Clinical Investigation Plan

linical Investigators, Principal Clinical Investigator, Coordinating

Data and Quality Management

An Overall Synopsis of the Clinical Investigation

Approval and Agreement to the Clinical Investigation Plan

4.6 I dentification and Description of the Medical Device

4.7 Preliminary Investigations and Justification of the Study

Previous Clinical Experience

Device Risk Analysis and Risk Assessment

Objectives of the Clinical Investigation

Design of the Clinical Investigation

Deviations from the Clinical Investigation Plan

Amendments to the Clinical Investigation Plan

Adverse Events and Adverse Device Effects

Early Termination and Suspension of the Investigation

Case Report Forms (CRF)

3 Terms and Definitions

4 General Requirements for Risk Management

4.1 Competence of Personnel

4.2 Risk Management Plan

4.3 Risk Management File

5.1 Intended Use and Reasonably Foreseeable Misuse

5.2 Identification of Characteristics Related to Safety

5.3 Identification of Hazards and Hazardous Situations

5.4 Risk Estimation

7.1 Risk Control Option Analysis

7.2 Implementation of Risk Control Measures

7.3 Residual Risk Evaluation

7.4 Benefit-Risk Analysis

7.5 Risks Arising from Risk Control Measures

7.6 Evaluation of Overall Residual Risk

8 Risk Management Review

9 I SO/TR 24971:2013: Guidance on Application

9.1 I nternational Product Safety Standards

9.2 IEC 62304: Medical Devices Software Life Cycle Processes

9.3 I EC 62366: Application of Usability Engineering

9.4 ISO 10993: Biological Evaluation of Medical Devices

9.5 eveloping the Policy for Determining the Criteria

9.6 Production and Post-production Feedback Loop

2.1 Quality Management System

2.2 Risk Management

2.3 Design of Cleaning Process

2.4 Validation Process

2.5 Sampling Process

2.6 Manufacturing of Test Substances

2.7 Testing Methods and Efficiency

3 leanliness Evaluation: Test Methods and Cleanliness

3.1 Detailed View

3.2 Visual Test

3.3 Bioburden Test

Fig. 2 The relation Implant Characteriscs and

3.4 Bacterial Endotoxins

3.5 Organic Contaminants