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Three Things You Should Know about Medical Device Regulations in Russia and the Eurasian Union, August 2022

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1.Draft Protocol on Prolongation of the Eurasian Transition Period until 2025

On 19 August 2022, the Council of the Eurasian Commission announced (link in Russian) approval of the protocol of amendments to the Eurasian Agreement on common principles and rules of circulation of medical devices and prolongation until 31 December 2025 of the transition period with possibility of registration of medical devices according to the national regulations.
According to the announcement on the website the Eurasian commission, the draft protocol with abovementioned amendments was forwarded to the Eurasian member states for carrying out procedures necessary for signing and implementation of this regulation.
The Eurasian Agreement on common principles and rules of circulation of medical devices was enforced by the Eurasian Commission in 2016; the transition period, that was initially established as 31 December 2021, was already extended for one year in June 2022.

2.Simplification of the Procedure of Importation of Samples of Medical Devices for Registration

On 8 August 2022, the Russian medical device regulator Roszdravnadzor has announced (link in Russian) change of the procedure of importation of samples of medical devices for registration in Russia. 
Since that date the requirement to obtain the sample importation permit for registration was cancelled and replaced by new requirement to submit online notification with information on imported samples. 

3.Enforcement of the Requirement on QMS Inspections for National Registration Procedure

On 1 September 2022, the regulation #135 (link in Russian) is coming into force. This document is establishing rules for the inspection of quality management systems (QMS) for medical device manufacturers and introduces mandatory requirements to perform QMS inspection and submit QMS inspection reports for national Russian registration and amendment procedures for IIA sterile, IIB and III class medical devices.

The regulation established nine months (i.e. until 1 June 2023) transition period. Within this timeline, registration and amendment procedures may be done with submission of ISO 13485 inspection report on condition that postponed inspection to be performed by the Russian component authority within 2 years after approval.

Three Things You Should Know about Medical Device Regulations in Russia and the Eurasian Union – February 2022

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  1. Mandatory notification on all imported medical devices since March 1st, 2022

 March 1st, 2022, is the date of enforcement of regulation #11020 (link in Russian) establishing mandatory requirements to notify authorities for every unit of any medical device imported into Russia, as well as manufactured within the country.

According to the regulation, this notification has to be performed for the purpose of safety monitoring by the regulatory agencies. It should be done by the manufacturer, its authorised representative or the importer of a medical device. Information regarding the name of the medical device and its modification, its serial number, its manufacturing and expiration date and the number and date of registration should be submitted using the Roszdravnadzor electronic system within fifteen days of importation or manufacturing release of a product.

2. New guidance on quality management system requirements for the registration of medical devices

On February 9th, 2022, the Russian government released regulation #135 (link in Russian) and established rules for the inspection of quality management systems for medical device manufacturers. The document introduces mandatory requirements to submit QMS inspection reports using national procedures for any amendment to registration certificates from June 1st, 2023, and provides detailed guidance on the organisation of the QMS audit.

In addition, on February 18th, 2022, the Russian Ministry of Health released regulation #91N (link in Russian) on methods for determining the amount of payment for the provision of services related to the inspection of the production of medical devices. The document provides tools to calculate required human resources and costs for the inspection of quality management systems for the registration of medical devices.

According to the document, the maximum cost for an inspection is limited to 1.274 million rubles including VAT for Russian manufacturers (approximately 13,000 USD) and 2.729 million rubles for foreign manufacturers (approximately 28,000 USD).

3. New guidelines for pre-clinical and clinical testing for medical devices in Russia


March 1st, 2022, is also a date of enforcement of regulation # 885N (link in Russian) with a new revision of the guidelines for technical assessments, toxicology testing and clinical trials as part of the national registration procedure of medical devices. The regulation will replace regulation #2N (link in Russian) that was effective since 2014.
It should be recalled that the possibility of reopening submissions according to national registration rules for another year has been debated since the end of December 2021. However, as of the end of February 2022, this remained impossible.

Three Things You Should Know about Medical Device regulations in Russia July 2021

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Dear colleagues,

Here is my usual selection of highlights in medical device regulatory updates in Russia over the past month:

1. Implementation of new post-market control measures for medical devices in Russia

On 30 July 2021 the Russian government released Resolution 1066 (link in Russian) and implemented new regulations which significantly changed control measures for organizations involved in the turnover of medical devices in Russia (including manufacturers, distributors and customers [medical centres]).

The document implemented changes in the forms and schedules of the control inspections performed by the regulator. The scheduled inspections will be carried out every 4 to 6 years, depending on the risk classification of the organization, and will not be needed for organizations in low risk groups.

In addition to planned inspections, the document introduced additional control measures such as inspection visits, test purchases and random sample checks of medical devices.

2. Update on quality management system requirements for medical device manufacturers

In July 2021 the Russian government released two draft guidelines on the quality management system (QMS) requirements for medical device manufacturers.

The draft regulation “on requirements for the implementation, maintenance and evaluation of the quality management system of medical devices depending on their risk classification” (link in Russian) provides a description of the scope of the QMS assessment including design and development, processes for managing documents and records, final inspection processes, corrective and preventive action, and customer-related processes.

The document refers to Russian standard GOST ISO 13485-2017 and Eurasian Decision #106 as guidelines for implementation of the QMS.

Another document published in July 2021 is a draft regulation on conducting QMS inspections of medical device manufacturers (link in Russian).

The published guidance provides differentiation between three types of QMS audits:
1. Initial QMS inspections that must be performed for all manufacturing sites mentioned for registration application.
2. Scheduled regular QMS inspections that must be performed every 5 years for manufacturing sites selected by the regulator.
3. Unplanned QMS inspections that must be performed in certain cases of registration amendments or after completion of corrective actions.

The draft document provides a matrix for the assessment of the significance of the observations recorded during an inspection, which, according to the rules, must be closed within 30 days of the audit.

The document also provides guidance on calculating the duration of an audit, which may vary from 6 to 13 days depending on the headcount of the manufacturing organization. However, the entire inspection process may not exceed 90 days from the submission of the application.

There are several cases for which the regulations allow performing a QMS audit remotely, conditional upon performing an on-site audit within 2 years

3. New regulatory requirements for certain in-home in-vitro diagnostics

On 15 July 2021 the Russian Ministry of Health published a draft regulation (link in Russian) describing new potential approval routes for, as well as regulatory requirements of, certain in-vitro diagnostic (IVD) products (i.e. ‘in-house/home-brew’ IVD assays) developed and manufactured by individual laboratories.

According to the draft regulations such products may undergo an accelerated approval process via the obtainment of a special 5-year permit for clinical/diagnostic use in particular laboratories without registration. The document provides a detailed description of the approval procedure and requirements for submission of an application package.

The procedure is expected to be applicable for IVD products without registered analogue in Russia both made and intended for use by a specific laboratory or organization and will consider an assessment of the financial cost of registration and any existing need for diagnostics using the product.

Three Things You Should Know about Medical Device Regulations in Russia and the Eurasian Union, April 2021

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Dear Colleagues, 

Welcome to my monthly review of medical device regulatory changes in Russia and the Eurasian region:


1. Suggestions for Multiple Amendments to Russian Medical Device Regulations

In April 2021, multiple amendments made to Federal Law #323 ‘On health care protection’, related to the regulation of medical devices, were discussed by the Russian parliament. The published draft law (link in Russian) related to this initiative, among others, proposed the following significant changes to Russian medical device regulations:

– to amend the list of cases where medical devices are not subject to state registration;

– to implement the procedure for approving the classification of adverse effects of monitoring the safety of medical devices;

– to clarify the definition of ‘poor quality medical device’;

– to establish requirements for the implementation, maintenance and assessment of a quality management system for the production of medical devices;

– to establish a requirement to reissue licenses for the technical maintenance of medical device manufacturers by 31 December 2022;

– to grant the possibility of circulation of medical devices according to technical documentation in cases when registration certificate is expired and after 180 days in case of amendment of the registration certificate.

At the end of April 2021, the document was approved by the Russian parliament and signed by the President, although it has not yet come into force.

2. Discussions on the Simplification of Registration for Russian Manufacturers

Another initiative that was discussed and proposed by the Russian government over the last month was draft regulations (link in Russian), suggesting the simplification of the national registration process (an accelerated one-step registration) for Russian manufacturers. This would be on the condition that performance type testing, overseen by Russian healthcare regulator Roszdravnadzor, is carried out in the testing lab of the expert body.

The same draft proposed the possibility of two additional request/deficiency letters from Roszdravnadzor during the national Russian registration procedure (instead of one request as it stands currently) to minimise the possibility of registration rejections.
By the end of April 2021, the document had reached public discussion.

3. Development of Regulations on Remote Quality Management Audits for Medical Device Manufacturers

On 30 April 2021, the Eurasian Commission published a draft document (link in Russian) on the amendment of the Eurasian Requirements for Quality Management Systems for Manufacturers of Medical Devices (which were previously implemented in the Eurasian Regulation #106).

According to the proposed amendments in the draft document, the quality management audit (required for Eurasian approval of medical devices classed as high risk) may be performed in remote mode with approval from the regulator and on the condition that there will be a standard audit within two years of the virtual inspection.

The draft document is expected to be in public discussion until the end of May 2021.

Earlier in April 2021, the Russian Agency on Technical Regulating and Metrology released the national standard GOST 59424-2021 with guidelines for performing remote analysis of the management system.

The QMS audit is a mandatory step for the approval process of IIb and III class devices, according to Eurasian regulations. Due to travel restrictions caused by the pandemic and a lack of clear guidance, however, switching to Eurasian approvals remains highly uncertain for manufacturers. 

Three Things You Should Know about Medical Device Regulation in Russia and the Eurasian Union, January 2021

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Dear Colleagues,

Welcome to my monthly review of the most important updates in medical device regulation in Russia and Eurasia.

1. New Russian Import Procedures for Medical Device Samples

On 1 January 2021, the Russian healthcare regulator Roszdravnadzor enforced new procedures for the importing of samples for registration of medical devices in accordance with regulation #661n (link in Russian). Henceforward, an import permit is required both for registration and renewal procedures, and documents are submitted in electronic form only.

An import permit is still not needed for the accelerated registration of medical devices and in-vitro products intended for the prevention and treatment of the coronavirus under resolution #430.

2. New Post-Market Requirements for Medical Devices in Russia and Kazakhstan

On January 2021, Russia and Kazakhstan enforced new local post-market requirements for medical devices.

Russian Order #980n (link in Russian): ‘On the procedure for safety monitoring of medical devices’ applicable for medical devices registered in Russia. The regulation describes the criteria for monitoring events and procedure for work on a corrective action plan.

New Kazak regulation (link in Russian): ‘On pharmacovigilance and monitoring of safety, quality and officiate of medical devices’ was enforced early January 2021. The document provides a definition of adverse events, an example of the reporting form, a corrective-action report, and a field safety notice. The timelines for reporting were 2–30 days, depending on the severity of the event.

New requirements implemented in the regulation are mandatory post-registration clinical monitoring and submission of annual safety reports for class III devices and IIB implantable devices.

It is worth noting that both the above regulations apply to medical devices approved by local registration procedures. Meanwhile, post-market requirements for medical devices approved under Eurasian regulation are described in the Eurasian regulation #174.

3. New Registration Inspection Rules for Medical Device Manufacturers in Kazakhstan

On January 2020, Kazakhstan’s Ministry of Health issued new inspection rules for medical device manufacturers. This called for the registration of medical devices under local procedure (link to the regulation in Russian).

According to this document, the quality management system (QMS) inspection is mandatory for registering sterile IIa, IIb and III class medical devices. This applies to manufacturers or manufacturing sites unregistered in Kazakhstan before, or upon, the clinical-trial completion for all class III and class IIb implantable devices. The regulation describes the scope of the QMS inspection based on the international ISO 13485 standard. In certain cases, these new rules permit the remote inspection in form assessment of documents.


Three Things You Should Know About Medical Device Regulations in Russia, September 2020

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Dear Colleagues,

Here is my regular update on the Russian and Eurasian medical device regulations for the last month:


1. Updated Criteria for Medical Devices Exempted from the Registration Requirement

On 1 September 2020 the Russian government released Resolution #1335 (link in Russian) and updated the criteria of medical devices that do not require registration in Russia. The regulator also harmonised these requirements with the Eurasian legislation.

Henceforward, the following medical devices are within the scope of this regulation:
–Medical devices that match the Eurasian criteria listed in Clause 4.11 of the Eurasian Agreement (including medical devices for personal use, medical devices for medical aid on transport or international cultural or sport events, as well as those imported for humanitarian use);
–Custom-made medical devices that are made and intended for a particular patient;
–Medical devices that are intended for use within the territory of the international medical cluster or innovative science and technology centres.

2. First Medical Device Passed Eurasian Quality Management Inspection

Russian healthcare regulator, Roszdravnadzor, announced on 16 September 2020 the approval of the first medical device according to the Eurasian medical device registration procedure including the completed manufacturing inspection of two manufacturing sites (located in Russia) for compliance with the quality management system requirements according to Eurasian Regulation #106.

It should be recalled that since March 2019, after a one-year transitional period, the quality management inspection system became a mandatory step for the Eurasian approval of medical devices of IIB–III risk classes; however, until today, many of the organizational and administrative requirements for such inspections, as well as the list of the organisations that conducted these inspections, were not clear.

In September 2019, the Russian Ministry of Health published a draft policy on determining the QMS inspection fees (link to the document in Russian); the policy elaborates on the inspection’s cost and calculation algorithms.

At the end of September 2020, there are four medical/in-vitro devices in the Eurasian database, all of them manufactured by Russian manufacturers.

3. Upcoming Deadline for the Administrative Replacement of the Obsolete Licences

In September, Roszdravnador reminded the industry that Russian registration certificates for medical devices issued before 2013 and having unlimited validity must be updated according to the special administrative replacement procedure by 1 January 2021; otherwise, after this deadline these licences will be annulled by the regulator.

The requirement to update old licenses was introduced in 2013, when Russia enforced a new medical device regulation system, and, after that, in 2017 the deadline for replacement was prolonged until 2021;

A detailed description of the replacement procedure is provided on the official site of Roszdravnadzor (in Russian) or here.

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Thank you for following my blog, which is the aim of providing timely and clear updates on the development of Russian and Eurasian medical device regulations. For Russian and Eurasian updates you might also be interested in my upcoming seminar or presentation on the MedTech summit.

Three Things You Should Know About Medical Device Regulations in the Eurasian Union, September 2019

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 Dear colleagues:

This is my monthly selection of updates on medical device regulations in the Eurasian region:

  1. Changes to the Eurasian Transition Period for Medical Devices

Here is the long-awaited update on the Eurasian transition period for medical devices. On 5 September 2019, the Eurasian Economic Commission published Decision no. 142 (link in Russian) which contained an approved draft of the proposed changes to a transition period for registration for medical devices. According to this document, if a medical device is approved in a Eurasian member state before 31 December 2021, it may be re-registered <only in this member state> using the local re-registration procedure until 31 December 2026. Such a device can be on sale in this member state <but not the whole Eurasian Union> until the expiry of the registration certificate.

Previously, the Eurasian Agreement on medical devices required re-registration of all medical devices using the Eurasian registration procedure before 31 December 2021. In the last two years, several proposals from Eurasian member states to change these transition deadlines have been discussed.

Registrations of new medical devices before 31 December 2021, can be submitted using either the local registration procedure or the Eurasian registration procedure. After 31 December 2021, all new medical devices should be submitted for registration using the harmonised Eurasian procedure only.

The Eurasian member states must first ratify (within 90 days) the draft of Decision no. 142 (link in Russian) before this comes into effect.

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While the Ministry of Health of Kazakhstan recently reported the first Eurasian approval of a pharmaceutical product,  activity on Eurasian medical device registration is still not too fast: for today there is still minimal information about products submitted for registration. Twenty-five laboratories are accredited to perform registration type testing. However, there is still no clarity as to when the quality management system (QMS) inspection, which is required for registration may begin.

  1. Draft Guidance to Determine the Costs of QMS Inspection in the Eurasian Union

On 2 September 2019, the Russian Ministry of Health published a draft policy for determining the fees for a QMS inspection before registration of the medical device can take place within the Eurasian Union (link to the document in Russian).

According to Regulation no. 106, which came into force in March 2018, the QMS inspection of manufacturing sites is mandatory for the registration of most IIA-III class medical devices in the Eurasian Union. The scope of the QMS inspection includes the assessment of quality sub-systems, i.e. design and development, document and record management, production and output control, corrective and preventive actions, and consumer-related processes.

The document proposes rules for calculating the cost of an inspection which depends on the number of employees of the enterprise and its location. The document also suggests the duration of the inspection is from four to eleven working days, and that the maximum cost is limited to 2,600,000 RUB (approx. 40,000 USD), excluding the cost of translation services.

  1. New Rules for Technical Testing of Medical Devices in Kazakhstan

On 6 September 2019, the Ministry of Health of Kazakhstan released Regulation KR DSM-124 (link in Russian) regarding technical trials for medical devices as part of the national registration procedure. According to the document, technical tests of medical devices (not required for in-vitro diagnostics) are carried out as type testing of samples or as data analysis (e.g. for some large-sized medical devices). These tests include assessment of the parameters provided in the technical or operational documentation, evaluation of the ‘design and operability of a medical device in terms of safety, ease of use, operational and ergonomic characteristics’, and an assessment of the labelling and packaging of a medical device. The duration of technical testing, according to the rules, should not exceed 30 calendar days.

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I would like to thank LIMI Consulting who helped me prepare the update regarding the Kazakhstan regulation in this post.

Three Things You Should Know About Medical Device Regulations in Russia and CIS, March 2018

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Dear colleagues,

Welcome to my monthly newsletter with updates on medical devices legislation in Russia and the Eurasian Union for March 2018.

  1. Eurasian Quality Management System Requirements for Medical Device Manufacturers

On 15 March 2018, Regulation #106 of the Eurasian Commission on the requirements on the quality management system (QMS) for manufacturers of medical devices for the Eurasian Economic Union (EAEU) registration procedure (link in Russian) came into effect.

The published regulation describes requirements to the QMS for medical device manufacturers and requires mandatory scheduled and unscheduled audits of manufacturing sites to demonstrate compliance with these requirements within the EAEU registration process.

The Eurasian Commission notes that, despite the fact that the requirements were developed on the basis of the international standard ISO 13485, the audits will be based on compliance with the requirements of the EAEU QMS regulation but not with requirements of the ISO standard itself.

At the same time, during the transition period until 15 March 2019, the regulation allows the registration in the EAEU of certain classes of products providing certificate ISO 13485 as evidence of an implemented QMS system, but in this case the manufacturers will have to pass an unscheduled inspection of the manufacturing site within two years from the date of registration.

Summary of EAEU medical device regulations for the end of March 2018:

 

  1. Potential Special Registration Route for Certain Medical Devices Manufactured in Russia

In mid-March 2018, the Russian Ministry of Health published a draft (link in Russian) amendment to article 38 of the Federal Law 323 that introduces a special registration route for certain low-risk medical devices manufactured in the Russian Federation.
The amendments will affect medical devices manufactured by Russian manufacturer, intended for use by medical personnel only and included in the list of “high-tech and innovative products”. The published document also establishes special requirements for post-registration safety monitoring for such products. It should be noted that Russian legislation today does not contain the above-mentioned criteria for “high-tech and innovative” products. It is expected that the amendments will come into force on 1 January 2020.

 

  1. New Medical Device Registration Rules in Uzbekistan

On 23 March 2018, the government of Uzbekistan published resolution #213 (link in Russian) with amendments to the registration rules for medicines and medical devices in the country. The resolution establishes the requirements for documents, samples, and fees for registration of medical devices in Uzbekistan and sets timelines for this procedure as 120–150 days. The approval process may also require clinical trials and manufacturing site inspection. The resolution establishes the validity of the registration license for a medical device as five years and contains a list of devices that do not require registration.

Three Things You Should Know about Medical Device Regulations in the Eurasian Union, October 2017

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Dear colleagues and group members,

In October 2017 my usual newsletter will focus on updates in developing harmonised Eurasian medical device regulatory system.

 

  1. Eurasian Quality Management System Requirements for Medical Device Manufacturers

In early October 2017, the Eurasian Commission published decision 134 (link in Russian), which includes what is requirements for a quality management system (QMS) for manufacturers of medical devices.
This decision is the last of the “second level” documents approved in the harmonised Eurasian model.

According to the published regulation, the implementation, development and maintenance of the QMS is becoming mandatory for the registration of  sterile IIA, IIB, III class devices. For low class devices (I and non-sterile IIA class products) QMS maintenance is not formally mandatory,however, it offers the advantage of a simplified amendment/re-registration procedure (notification instead of assessment).

The document contains checklists with requirements for every QMS subsystem: design and development controls, record/document change control, corrective and preventive actions, production and process control and consumer-related processes.

The assessment of the QMS is a mandatory step in the registration process and is carried out by way of an inspection audit of every declared manufacturing site by accredited organisations of Eurasian member states (according to the document, there is a list of accredited organisations maintained by the regulator of each member state, and the manufacturer may apply to any of them).

In addition to the primary “registration” inspection audit periodic post-registration QMS assessment inspections are also requited once every three years, as well as unscheduled inspections in limited cases.

The document introduces a twelve-month transitional period, during which QMS assessment is not mandatory for the registration. During this period, the submission of an ISO 13485 certificate provides a presumption of conformity with quality requirements when the QMS inspection audit is postponed (within a two-year period after registration).

 

  1. Russian Laboratories are Preparing to Start Medical Device Testing According to Harmonised Eurasian Requirements

In early October 2017, the Russian medical device expert centre (VNIIMT (ВНИИМТ) published information about its inclusion in the list of organisations accredited for technical and biological testing for the registration of medical devices according to the Eurasian procedure.

Later, on 27 October, during the seminar on Eurasian medical device testing requirements held by the same organisation, it was confirmed that manufacturers may apply for start testing according to the new requirements.

At the end of October 2017, there are two laboratories accredited for testing according to Eurasian requirements. The list is published on the website of the Russian medical device regulator Roszdravnadzor.

It should be noted that the Eurasian medical device regulation model contains separate requirements for technical (link in Russian) and biological safety (link in Russian) testing, which must be conducted in an accredited laboratory in any Eurasian member state.

 

  1. Eurasian Advisory Committee on Medical Devices

Another document adopted by the Eurasian commission in October is decision 123 (link in Russian) “On the Regulations on the Advisory Committee on Medical Products”. According to the text in the published document the Advisory Committee is a new regulatory body on the Eurasian level which will be responsible for adjusting differences between Eurasian member states (i.e., the reference state and acceptance state) during the process of medical device registration assessment. The committee’s tasks also include consultations on issues in the field of medical devices.

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Thank you for following this blog! My objective here is to make developing Eurasian medical device regulations clearer. You can also follow my updates on Twitter @MedDevRus.