Within this blog post, we will highlight IVD-specific issues, including areas of difference between the new MHRA regulations in contrast to EU regulations—and more specifically, the IVDR/MDR. We will also discuss new areas related to innovation/routes to the UK market and processes put in place to ensure that IVD devices are available on the UK market after the implementation date of the UKCA (1 July 2023).
In May 2022, the FDA announced the 510(k) Sterility Change Master File Pilot Program in the Federal Register. Under the Pilot Program, the sterilization provider compiles and submits a Master File to FDA and, in the event the MAF is accepted and the 510(k) holder is granted a right of reference to the MAF, submission of a new 510(k) for the sterilization change may not be required.
On 26 June 2022, the United Kingdom’s Medical Devices and Healthcare Regulatory Authority (MHRA) published the results and conclusions from the consultation process regarding the new Medical Device Regulations for the UK. The final proposals contain comprehensive coverage of the various requirements to be included in the new UK Medical Device Regulations guidance. These new regulations are primarily based on EU Medical Device Regulation (MDR) 2017/745 requirements, but with significant differences in some key areas and new requirements surrounding new and innovative medical devices.
The MDCG 2022-8 is probably one of the most important IVDR guidance documents that has been published in recent months as it finally clarifies what requirements are/are not applicable to legacy IVDs post-IVDR Date of Application (26 May 2022). This guidance discusses: 1) requirements within Chapter VII for post-market surveillance; 2) market surveillance/vigilance for “legacy devices”; 3) other IVDR requirements for “legacy devices”; and 4) IVDR requirements for devices placed on the market prior to 26 May 2022 (“old devices”).
On January 27, 2022, MDCG 2022-2: “Guidance on general principles of clinical evidence for In Vitro Diagnostic medical devices (IVDs)” was published. This document provides information for manufacturers, regulators, investigators, sponsors, Notified Bodies and other industry stakeholders concerning the continuous process for IVD performance evaluation.
At the end of May, a new Medical Device Consortium Group (MDCG) document was published by the European Commission: MDCG 2022-6—“Guidance on Significant Changes Regarding the Transitional Provision under Article 110(3) of the IVDR.” This guidance covers important information regarding the implementation of EU Regulation 2017/746, also known as IVDR and discusses key areas such as timelines, as well as the background and purpose of MDCG 2022-6.