What Do Notified Bodies Want?
A Whitepaper by Nancy J Stark, PhD.
We've come a long way in our understanding of what Europe expects in a Clinical Evaluation Report. Where you start depends on where you are: 1) writing a CE Report for a new, pre-approval device, or 2) writing a CE report for a commercial device. In the first case, you are asking the question, "Do I need new clinical data for certification?" In the second case, you are bringing your documentation up-to-date.
Clinical evaluation reports for pre-certification devices
If you're still in the stage of designing your device, you begin by identifying its intended uses. Then you evaluate the existing clinical data to determine if it is sufficient to support safety and performance per the Essential Requirements of the MDD or AIMD, or if you need additional clinical data. If additional clinical data are needed you have the choice of revising the intended use or performing a clinical trial.
Once you believe the data are sufficient, you convince top management to grant a CE Mark and sign the Declaration of Conformity to your quality management system. Finally, you will discover the truth when the Notified Body comes to call.
Clinical evaluation reports for commercial devices
The more common situation is that your device is already on the market in Europe, and the Notified Body has informed you that its clinical evaluation report was due last March. He will give you a grace period, but you are expected to conform. You follow the same process of evaluating the existing data to determine if it is sufficient to support safety and performance for the intended uses. Should the report conclude that the existing data are insufficient you are in a difficult situation: you'll need to suspend sales until additional data are acquired.
Because the consequences of determining the data are not sufficient are so financially significant for your firm, and the consequences of determining the data are satisfactory are so financially favorable, it is wise if the report writers are as far removed from the device designers as possible.
To write the report you need a team of at least three people: 1) a medical writer, 2) an information specialist, and 3) a statistician.
In addition you need a written procedure for how to proceed, a report template (useful, but not required), and access to literature databases such as Medline and Embase. Medline is easy, it is operated by the US National Library of Medicine and is available to anyone with a browser. Medline provides access to 5400 worldwide journals in 39 languages dating from 1947 to the present. And it is free.
Embase, on the other hand, is not free. It provides access to an additional 2000 European medical journals, and so, is indispensable since you want to sell in Europe. But it is owned by Elsevier Publishing. You should be prepared to pay a hefty access fee ($7000 and up per year) or sub-contract the time from a third-party source.
A Three-Legged Stool
The first leg of a Clinical Evaluation Report is an evaluation of the existing literature data. The Global Harmonization Task Force (GHTF) Study Group 5 document "Clinical Evaluation" coupled with MEDDEV 2.7.1 Rev 3, which is slightly easier to read, are the guidances that tell us how to do the literature evaluation.
Here's what the medical writer—working together with you—will do:
 Define the key questions.
 Identify the databases to search (Medline, Embase, MAUDE, Cochrane).
 Define scope of search and search strategies using a qualified information specialist.
 Scan the abstracts to identify articles for review.
 Acquire full-texts of articles.
 Weight the articles for technical significance, discard anything with a low weight.
 Have a statistician weight the articles for statistical significance, discard anything with a low weight.
 Review only those articles with the highest weightings; maybe 5-25 articles per intended use.
The literature data are evaluated to determine if they support safety and performance of the device for its intended use. I like to prepare a separate literature review and attach it to the main CE Report as an annex. The literature review annex has several required elements including the search strings used by the information specialist, a list of abstracts scanned, the articles reviewed, their weights and justification for those weights, and full-text copies of the articles.
The second leg of the CE Report is a review any existing clinical investigation that your firm may have sponsored. These data are reviewed separately from the literature because you have closer access to the details. The writer asks questions such as: "Was the Declaration of Helsinki followed?" or "Were adverse events resolved?" If not, those facts are noted in the report but the data are not used.
Once the writer is satisfied that ethical and administrative requirements were correct, he/she reviews the study results to see if they support safety and performance of the device for its intended use. I like to prepare a separate sponsored study review and attach it to the main CE Report as an annex.
In the third leg, the medical writer comes to the most sensitive step of all; examining the complaint file against the risk management system. They review the file to see if complaint handling, as dictated by the risk management system, supports the safety and performance of the device for its intended use. I like to prepare a separate risk management review and attach it to the main CE Report as an annex.
The CE Report
Finally, the medical writer takes the literature review, sponsored study review, and risk management review altogether and reaches an overall conclusion of whether the existing data support the device's safety and performance for the intended use, or if additional clinical data are needed newly. You know what happens if new clinical data are needed.
The Technical File
If the data are sufficient, the CE Report is filed away in the Technical File, a written procedure describing the writer's strategy is incorporated into your quality management system, and you wait with baited breath until the inspector comes.
How long, how much
There are only two questions in top management's mind: 1) how long will it take, and 2) how much will it cost. The answers are simple: "It depends." Let's say you have a very nice ultrasonic toothbrush and you intend to use it for cleaning roadside burns—the kind of burn you get when your motorcycle crashes and your skin scrapes against the pavement. The toothbrush is used to remove the dirt, grit, and tarmac from the wound. It's an unusual intended use and raises all kinds of questions about potential damage from the bristles, safety features to prevent over-brushing, effects of ultrasound on open wounds, comparing gum tissue to wound tissue, instructions for use, and so on. A clinical evaluation report for cleaning wounds will take longer and cost more than a report for brushing teeth with the same device.
CDG can help
Clinical Device Group is poised and ready to help you with writing your reports. We have medical writers, information specialists, experienced statisticians, access to Embase, a written procedure, a standard template, and a proven process. CE Reports written by our specialists have been reviewed by at least three different Notified Bodies and all have been accepted. We work collaboratively with a point-person on your side so that you are involved in the process every step of the way.
But perhaps you'd like to do your own medical writing in order to keep down costs, but don't have access to an information specialist, an experienced statistician, or Embase. Call us anyway, we like to work flexibly to meet your needs.
Phone or email us at 773-489-5721 or firstname.lastname@example.org.