Ger O'Carroll

EU Medical Device Classifications Explained

by Ger O'Carroll

Not all medical devices are the same. Some are non-sterile and pose minimal risk to patients, while others are implanted in the body and carry a high risk. Therefore, regulations for medical devices must distinguish between the different types, setting appropriate requirements for regulatory approval depending on risk. Regulators do this with a classification system.

In other words, understanding the classification that your new medical device falls under is a crucial step in the design and development process. The classification will inform how the development progresses as well as the steps required to obtain regulatory approval.

EU vs US Regulations

In the EU, new EU regulations, known as the new EU Medical Device Regulations, or MDR, are coming into force. One of the main changes in the new regulations involves different rules on the way medical devices are classified.

If you have gone through the process of designing and developing a medical device before, you might find it different with the new EU MDR. For example, the medical device you want to develop might now fall into a higher classification.

If you are going through the process for the first time, however, the changes in EU regulations will have less of an impact. One exception to this is the fact the new EU MDR brings the classification of medical devices in Europe more in line with international regulations. This includes FDA regulations which apply in the US.

There are still some differences, particularly in relation to how you get regulatory approval in the EU compared to the US, but the closer alignment of the two systems has simplified many aspects.

We’ll look at the classification system in the US in more detail in a future blog. The focus here is on medical device classifications in the new EU MDR.

EU MDR Medical Device Classifications

The classification system for medical devices under the new EU MDR is based on risk. The level of risk the medical device presents determines which classification it falls under. This classification then tells you:

  • Whether a conformity assessment is required to ensure it meets MDR requirements; and,
  • If a conformity assessment is required, how that should be done.

If a conformity assessment is required, it must be conducted by a Notified Body, i.e. an independent certification organisation authorised – i.e. notified – by an EU member state.

There are three main classifications for medical devices: Class I, Class II, and Class III. In addition, there are sub-classes such as, for example, Class IIb and Class IIa.

Most medical devices, however, will fall into the following risk classes:

  • Class I – this classification is for the lowest risk medical devices such as wheelchairs, glasses, stethoscopes, etc. Most medical devices in this category do not require a conformity assessment. Instead, they can be self-assessed. The exceptions are Class I medical devices which are reusable surgical instruments, are supplied sterile, or have a measuring function. A notified body is required to certify these types of medical device.
  • Class IIa – this classification is for medium risk medical devices. An example is a surgical clamp. A conformity assessment by a notified body is required for this classification of medical device.
  • Class IIb – this classification is for higher risk medical devices or medical devices classed as a medium-to-high risk. A bone fixation plate is one example. Again, Class IIb medical devices require a conformity assessment.
  • Class III – this classification is for the highest risk medical devices and requires a conformity assessment. Examples include pacemakers and heart valves.

Determining the Classification of Your Medical Device

One of the first things that is required when designing and developing a new medical device for the EU market is to determine its classification. Working with an engineering design and development team with knowledge and experience in this area streamlines the regulatory approval process and ensures the development starts on the right track.

Quality Systems and Design Controls in the New Medical Device Development Process

by Ger O'Carroll

Design controls are essential to ensuring your medical device idea achieves regulatory approval. Without design controls, you won’t be able to launch your product, while the poor implementation of design controls, particularly in the early stages of a project, will delay the launch of your product.

What are design controls?

Design controls are part of the Quality System that you must have in place before regulators will allow your product to enter the market. So, let’s start there.

An Introduction to Quality Systems

All new medical device products need a Quality System to comply with regulations. In the US, this means complying with FDA 21 CFR Part 820. In Europe, it means complying with EU medical device regulations. Most MedTech companies achieve this by meeting the standards set out in ISO 13485:2016.

Both FDA 21 CFR Part 820 and ISO 13485:2016 are similar as there has been a drive by regulators in recent years to harmonise the requirements in different countries and regions. Therefore, it’s possible to take an overall look at what you need in terms of a Quality System.

Importantly, neither the FDA nor EU regulators specify what your Quality System should look like or the procedures you should follow. This is up to you, but there are best practice standards you should follow.

A specialist medical device design company, like Arrotek, can guide you through the process and ensure you meet the requirements of regulators.

Design Controls and Quality Systems

The Quality System you put in place for your medical device product will have a range of different components. This includes management controls, document control, supplier management, and risk management.

This blog, however, focuses on another crucial component of a new medical device Quality System – design controls.

The purpose of design controls in a Quality System is to prove a medical device product is safe, effective, and fit for purpose.

There are three central questions to the above:

  1. Does the product meet user needs – i.e. does it do what you claim it does?
  2. Is the product suitable for its intended uses – i.e. does it diagnose, prevent, treat, cure, or mitigate the disease or condition you specify?
  3. Can you prove it – do you have documentation to prove the above?

Design Control Requirements for the Quality System of a New Medical Device Product

The central component of design controls for a new medical device product is to have a plan or process that describes all the design and development activities that take place to bring your product from the idea stage to the stage of seeking regulatory approval.

This process will produce a document that contains a full history of the product’s design iterations. This document is often called the design history file.

The design history file also includes:

  • Design inputs, i.e. the performance criteria and requirements of the product based on the needs of users
  • Design outputs i.e. all the components the design produces from testing protocols to materials to parts
  • Verification, i.e. verifying the design outputs meet the design inputs
  • Validation, i.e. validating the design
  • Details of design changes and how they were controlled
  • Reviews of design results (or design reviews)
  • How the design was transferred to production documents – drawings, specifications, etc

Beyond Compliance

Design controls offer more benefits than smoothing the path to regulatory compliance. By having design controls in place, you will be more confident your new medical device product will be safe to use in addition to potentially shortening the product design and development timeline.

When you add a DFM (Design for Manufacture) approach to the process, design controls can also help ensure your medical device product can be effectively manufactured for an acceptable cost.

Importance of Implementing Design Controls Early

By meeting the above requirements at the start of the design process, you will save considerable amounts of time compared to doing it retrospectively, i.e. once the product is ready for submission to regulators for approval.

Adopting an approach to product design that is both fluid and flexible helps too.