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How should changes to a QMS unrelated to the product be tracked under MDR?

Anonymous 1 comment
3 days ago
During a recent MDR audit, a minor non-conformity was issued because changes to our quality management system (QMS) that are not related to the product (such as changes in company leadership or new lo
Dr. Oliver Eidel

Accepted answer

In my case, I don't have a separate SOP for this type of change, but I mention it in the management SOP and keep a record for tracking process changes

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How is medical device regulation developed and how can its usability be improved for start-ups?

Anonymous 1 comment
5 days ago
I am interested in understanding how medical device regulation, specifically the MDR, is developed and what could be done to improve its usability, especially for small start-ups. From my experience a
Dr. Oliver Eidel

Accepted answer

Regulation like the MDR is developed at the EU level as part of the "new legislative framework" for product safety. The process involves EU institutio

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How should IVDR Annex I, Article 9.1(a) requirements be addressed for SaMD-IVDs in the GSPR?

Anonymous 1 comment
6 days ago
I am preparing the General Safety and Performance Requirements (GSPR) for a software as a medical device (SaMD) intended for in vitro diagnostic (IVD) use and have a question regarding IVDR Annex I, A
Dr. Oliver Eidel

Accepted answer

You're right that not all aspects of Article 9.1(a) make sense for SaMD-IVDs, but it's generally not correct to mark the entire requirement as 'not ap

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Is it necessary to have technical documentation ready before certifying a QMS under MDR for a class IIa medical device?

Anonymous 1 comment
8 days ago
Our company wants to certify its Quality Management System (QMS) as soon as all documentation is ready, but we do not yet have all the technical documentation for our medical device completed. Based o
Dr. Oliver Eidel

Accepted answer

It's generally fine to proceed with certifying your QMS before the technical documentation for your device is complete, especially if you are aiming f

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How do you validate and test your medical device IFU (Instructions For Use)?

Anonymous 1 comment
8 days ago
Our team has previously added one or two tests about the IFU to our usability tests, but this approach felt awkward for testers and did not cover the entire IFU. We are seeking practical methods to va
Dr. Oliver Eidel

Accepted answer

We've written a questionnaire with about 5-6 questions for users to answer after reviewing the IFU. The main focus is whether the instructions are cle

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Is it necessary to have technical documentation ready before certifying the QMS under MDR for a class IIa device?

Anonymous 2 comments
10 days ago
We are preparing to certify our Quality Management System (QMS) but do not yet have all of the technical documentation for our medical device completed. According to MDR 2017/745 (Annex IX, Chapter 1,
Dr. Oliver Eidel

Accepted answer

Certification to ISO 13485 is independent from being a manufacturer under MDR Annex IX. Many certification bodies are not Notified Bodies for MDR, so

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What happens after the Substantive Review and AI response in the traditional 510(k) process?

Anonymous 1 comment
11 days ago
After the Substantive Review in the traditional 510(k) process, and after receiving and responding to the Additional Information (AI) request within the 180-day deadline, is the final 510(k) decision
Dr. Oliver Eidel

Accepted answer

After you submit your response to the AI request, the FDA generally has 30 days to review it and make a decision. If they have additional questions, t

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Is reduced time to triage via telemedicine a clinical benefit under MDR?

Anonymous 2 comments
12 days ago
For telemedicine platforms that act as medical devices by generating data for review by a medical doctor (such as audio recordings of coughing or skin pictures), the goal is often to triage patients:
Dr. Oliver Eidel

Accepted answer

I think you can definitely argue that reduced time to triage is a clinical benefit, since the MDR includes positive impact on patient management in it

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How are feature flags managed under IEC 62304 compliance?

Anonymous 1 comment
18 days ago
I am interested in how feature flags fit into the context of IEC 62304 for medical device software. Specifically, if a feature is deployed but hidden behind a feature flag, does enabling the flag cons
Dr. Oliver Eidel

Accepted answer

Feature flags are generally considered a configuration, not a new release of the software. However, you must ensure that all possible configurations e

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Are there general authentication requirements for patient mobile applications under MDR?

Anonymous 2 comments
19 days ago
Are there any general guidelines or requirements under the Medical Device Regulation (MDR) for authentication in patient-facing mobile applications? I am specifically interested in requirements that w
Dr. Oliver Eidel

Accepted answer

Overall, MDR does not specify detailed authentication requirements for patient mobile applications. The MDCG cybersecurity guidance mainly suggests us

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Is ISO 13485 certification still valid if the medical device is discontinued?

Anonymous 1 comment
20 days ago
What happens to an existing ISO 13485 certification if the medical device it was issued in combination with is discontinued? Is the ISO 13485 certification still valid for the company? Would the compa
Dr. Oliver Eidel

Accepted answer

ISO 13485 certification is company-specific and not tied to a specific device. You can keep your ISO 13485 certification even if you don't have an act

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When is a QMS required for medical device development?

Anonymous 1 comment
21 days ago
At our company, we are preparing to implement a Quality Management System (QMS) and are unsure about the timing. Is a QMS required during the development phase, or only when preparing to put a medical
Dr. Oliver Eidel

Accepted answer

Ideally, you would have your QMS in place before the development phase starts. In reality, most companies implement it during the development phase, s

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Is ISO 13485 certification required before CE marking for medical device software in the EU and Switzerland?

Anonymous 1 comment
22 days ago
Our company is planning to certify our software as a medical device in the EU and Switzerland. We have two questions: • Is it necessary to obtain ISO 13485 certification before pursuing CE marking? Wh
Dr. Oliver Eidel

Accepted answer

One of the requirements for CE marking, depending on the classification of your device, is that you have a certified QMS in place. The MDR requires ma

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Should we send all our developers to multi-day 8-hour "training sessions" for e.g. the ISO 13485?

Anonymous
23 days ago
Our CEO thinks that "quality is really important" and that "we need to show our investors and customers how much we value quality and safety", and has therefore sent everyone in the company to attend
Dr. Oliver Eidel

Short answer: No, none of this makes sense. Your two most likely options are: • Convince the CEO that this is a huge mistake, save the company, and st

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IEC 82304: How Is It Different From The IEC 62304?

Anonymous
updated 7 months ago
We're just getting started with our medical device documentation, and we initially thought that we need to comply with the IEC 62304 regarding our software documentation. Now, someone mentioned the IE
Dr. Oliver Eidel

Accepted answer

Don't worry about it. Auditors won't like me for saying this, but the 82304 doesn't contain much additional content on top of the 62304. Just comply w

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What's The Best QMS Software?

Anonymous
updated 9 months ago
We're looking for QMS software and don't know which one to choose. Which one is the best QMS software?y
Dr. Oliver Eidel

Accepted answer

If you're a startup and don't know much about regulatory compliance yet, postpone that decision for now and learn a bit more about regulatory complian

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Formative vs. Summative Usability Testing - What's The Difference?

Anonymous
updated 9 months ago
What's the difference between formative and summative usability testing?
Dr. Oliver Eidel

Accepted answer

For summative usability testing, you need to do a user test (5 users or more in the EU, 15 in the US). For formative usability testing, you can "what

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When Should We Start Documenting Our Medical Device And QMS?

Anonymous
updated 10 months ago
We are currently developing our software medical device and might be done in 6 months or so. We want to get started with documenting it right now! What can we do?
Dr. Oliver Eidel

Accepted answer

If your software is not done yet, the most efficient approach in 95% of cases is to wait until your first version is done. For some reason, most peopl

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Manual Tests vs. Automated Tests For Medical Device Software

Anonymous
updated 10 months ago
We're developing software as a medical device (SaMD), and we're unsure how to perform testing of our software. Should we set up an automated test pipeline or do manual testing?
Dr. Oliver Eidel

Accepted answer

Do manual testing. I know it sucks, but it's more straightforward for many reasons. Long Answer Let me start off with this: I'm a software engineer m

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Which Notified Body Should We Choose?

Anonymous
updated 10 months ago
Which Notified Body should we choose?
Dr. Oliver Eidel

Accepted answer

DQS, BerlinCert, or maybe one of the lesser-known ones in Eastern Europe, in that order. Avoid BSI and Tüv Süd. Subjective opinion. Long Answer Discl