CDG Whitepapers

Uptick in Clinical Evaluations

What Do Notified Bodies Want?

A Clinical Device Whitepaper by Nancy J Stark

We've seen an uptick in requests for clinical evaluations recently, and I thought it would be worthwhile to review the requirements. Where you begin depends on where you are now: 1) writing a clinical evaluation for a new, pre-approval device, or 2) writing a clinical evaluation for a device that is already commercial. 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 [1 MDD] or AIMD [2 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 investigation.

Once you believe the data are sufficient, you convince top management to grant a CE Mark and sign the Declaration of Conformity to your previously certified quality management system. Finally, you will discover the truth when the Notified Body comes to make an inspection 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 is overdue or needs updating. They may give you a grace period, but you are expected to get busy. 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.

Resources
To write the report you need a team of at least three individuals: 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. Medline is easy to use, 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.

Date Wheels for Clinical Evaluation Planning

A typical clinical evaluation involves the following steps and durations:
[1] Identify key questions—1 weeks.
[2] Identify databases to search—overlaps.
[3] Identify search scope, keywords, search strings—1 week.
[4] Review abstracts, discard with reasons—1 week.
[5] Acquire articles—2 weeks.
[6] Read articles—1 week.
[7] Weight articles for relevance, discard with reasons—overlaps.
[8] Weight articles for statistical validity—1 week.
[9] Medical writer summarizes literature—2 weeks.
[10] Review sponsored clinical trials, if any—0-2 weeks.
[11] Review risk management system & complaint file—2 weeks.
[12] Write final evaluation—1 week.

Date Wheels are a handy, pocket-sized calendar used by project managers to quickly plan simple schedules. If the clinical evaluation work begins on March 1, you can hope for a final report about three or so months later, or about June 1. Buy them here.

A Three-Legged Stool
First leg
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:
[1] Define the key questions.
[2] Identify the databases to search (Medline, Embase, MAUDE, Cochrane).
[3] Define scope of search and search strategies using a qualified information specialist.
[4] Scan the abstracts to identify articles for review.
[5] Acquire full-texts of articles.
[6] Weight the articles for technical significance, discard anything with a low weight.
[7] Have a statistician weight the articles for statistical significance, discard anything with a low weight.
[8] Review only those articles with the highest weightings; see averages below. 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 clinical evaluation 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.

Second Leg
The second leg of the evaluation is a review any existing clinical investigations 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 evaluation as an annex.

Third leg
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 evaluation as an annex.

The Clinical Evaluation
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 clinical evaluation 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 Notified Body inspector comes.

Recently CDG conducted a poll on the average number of
articles used in a clinical evaluation. Here are the results.
Please add your two cents worth below.

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 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 evaluations. We have medical writers, information specialists, experienced statisticians, a written procedure, a standard template, and a proven process. Clinical evaluations 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.

References
[1] Medical Device Directive 93/42/EEC.
[2] Active Implantable Medical Device Directive 90/385/EEC.
[3] Global Harmonization Task Force, Study Group 5, Clinical Evaluations. http://www.ghtf.org/sg5/sg5-final.html
[4] MEDDEV 2.7.1 rev 3. http://ec.europa.eu/enterprise/sectors/medical-devices/files/meddev/2_7_1rev_3_en.pdf

 
Best Regards,
Nancy J Stark, PhD
President, Clinical Device Group Inc

 

 

 

 

 

 

 

 

Literature Evaluations for Biological Safety

A Whitepaper by Dr. Nancy J Stark

During the course of product development there are three times when you should do a literature evaluation: 1) to justify animal use, 2) to justify a clinical trial design, and 3) to apply for certification and CE Mark or Medicare reimbursement. I've written previous whitepapers about doing literature evaluations as a part of clinical evaluations. In this whitepaper I'll do a brief overview and then look at literature evaluations to justify animal use.

Three literature evaluations
Selective Clinical Evaluations
ISO 14155 requires a clinical evaluation to justify the design of a clinical trial. 0. ISO 14155. A European colleague showed me several literature evaluations that were done for this purpose. The most important point I noted was that they focused only on the selected indication being investigated, and resulted in a relatively short, compact literature review utilizing only 5-10 publications.

 

Comprehensive clinical evaluations
The literature evaluations intended for certification and CE Mark are supposed to be comprehensive, "The clinical evaluation is based on a comprehensive analysis of available pre- and post-market clinical data relevant to the intended use of the device in question…." 1. MEDDEV Clause 5.5.1. However, CDG has been successful with Notified Bodies by averaging ~40 articles per review for Class IIa and IIb devices. The number of articles reviewed depends on the number available, the quality of the articles, the age of the technology, the volume of competition, and other similar factors. I observed one European Class III device that got certification and CE Mark based on a review of only 9 case series and 7 publications.

Literature reviews for Medicare reimbursement application should be larger and will be more persuasive if they follow the examples found at www.ahrq.gov. The Agency for Healthcare Research and Quality (AHRQ) has been publishing technology assessment literature reviews for years. If you look at the technology assessment for negative pressure wound therapy (NPWT) devices, you'll see that 1078 citations were identified, 288 full-text articles retrieved, and 137 articles reviewed. There were also more than 1400 items submitted for review by independent "interested parties". The authors point out that none of the studies compared an NPWT system head-to-head to another system. 2. Negative Pressure.

Similarly, AHRQ recently released for comment a comparative effectiveness review of devices used in diagnosing cardiac disease in women, including stress electrocardiography, echocardiography, single proton emission computed tomography, cardiac magnetic resonance, and computed tomography angiography. A total of 7163 citations were identified, 1452 full-text articles retrieved, and 101 articles (98 studies) reviewed. The authors note that none of the studies were randomized controlled trials. 3. Diagnosing CAD. This review is currently open for public comment and device manufacturers should absolutely submit publications and data based on research they have done.

In 2010 AHRQ received $500,000,000 from the federal government to prepare comparative effectiveness reviews on a wide variety of products. These reviews will surely affect the availability of new and old technologies to the American patient as Medicare revisits its reimbursement decisions based on these reviews. The message to device manufacturers is that we will have to rethink how we design clinical trials and be prepared to submit our own clinical evaluations if we are to obtain reimbursement in the American marketplace.

Literature evaluations for biological safety
I haven't yet written about literature evaluations to justify the use of animals for biological safety testing or preclinical animal testing. The beauty is that the way you un-justify the use of animals is by demonstrating the work has already been done and does not bear repeating—saving you costly resourses and the unnecessary use of animals. Let's look more closely at literature evaluations to justify (or un-justify) animal tests.

How to Write A Clinical Evaluation—CD Workshop

A new CD workshop is now available on "How to Write a Clinical Evaluation". This well-researched presentation takes you step-by-step through the complicated process of writing a clinical evaluation by making it organized and understandable. The 100+ content slides and supporting handouts explain the logistics of clinical evaluations, how to define objectives and key questions, identify and retrieve abstracts, filter and screen abstracts to identify articles, filter again to zone in on the articles that are applicable, assess and weight the literature, and write the evaluation to address the key questions originally posed. The presentation discusses the three major purposes for evaluations, discusses their regulatory foundation, and proposes a strategy to allow each evaluation to build upon the previous ones. Finally, some average metrics are disclosed.

If you want a learning guide to help you write a clinical or literature evaluation, this workshop is the place to turn. A procedure, protocol, and template—meeting the requirements of MEDDEV 2.7.1 r3—are available for a small, additional cost. Click here to purchase or more information.

Authority—who says so
Take out your current copy of ISO 10993-1 "Biological evaluation of medical devices—Part 1: Evaluation and testing within a risk management process" (2009) and turn to Annex C, "Suggested procedure for literature review." 4. ISO 10993-1.

The introduction tells us, "A review and evaluation of the literature is essential for justification and planning of any biological evaluation of a material or a medical device. The aim of such a review is to determine scientific background for the biological evaluation. It also provides essential information for assessing risks/benefits and achieving the ethical conduct of the planned evaluation as required by ISO 10993-2.

NOTE Such a literature review can be helpful to assess whether the relevant data available in the literature are sufficient to demonstrate biological safety of the device in question without the need to generate further data from actual testing or to conclude that the available data are not sufficient.

Performing a literature review is a scientific activity that should be done with rigor and objectivity, and
should allow verification by third parties."

Methodology
[1] Establish a plan
The methodology, taken from Annex C, sounds a lot like the methodology described by GHTF Study Group 5 and MEDDEV 2.7.1 r3. The first step is to establish a plan or protocol for the identification, selection, collation and review of all available studies and data. The plan should be documented in writing and based on recognized practices for the systematic review of the scientific literature.

[2] Define objectives or key questions
The objectives of the literature evaluation should be clearly defined up-front. Sometimes it is easier to phrase the objectives in the form of key questions, for example, which, if any, animal safety tests from the G95-1 Matrix should be performed? 5. FDA BlueBook G95-1. Does the chemical characterization of the materials justify not doing animal safety tests? Do literature data satisfactorily explain the negative outcomes of certain animal tests? Do literature data justify the design of preclinical animal tests, selection of species, route of exposure, duration of exposure or follow-up, or other design parameters?

[3] Document sources and selection criteria
The next step is to identify the sources of literature and other databases that will be searched. The selection will depend on what information you need. For example, you might need evidence regarding the safety of chemicals such as additives or adulterants, information about chemical properties such as glass transition points or vaporization, data about adverse effects related to the device or technology, published studies about in vivo animal use, or information about 'active water' concentration. The type of data you need will influence where you look for it.

You will probably need to contact suppliers directly (called manual searching) to ask for specific information. For example you might need, say, formulation or processing information that isn't published.

In addition, you'll need to specify criteria for the data. For example, you might accept data from rodents but not from fish, you might require data from certain bacterial strains, large mammals, or ex vivo studies. You might need data with a certain sensitivity, such as parts per billion rather than parts per million. I find it easier to specify what I need than what I don't need until I have a feeling for what kind of information is out there.

[4] Assessment of documents
The documents are then valued in such a way as to group them by low, moderate, and high quality, depending on pre-determined assessment criteria; and then the values for each criteria are summed to give the document a weight. It may be that some high quality documents are unfavorable to the objectives, but these documents must be included in the evaluation nonetheless.

A 'document' may be anything from a MAUDE report of an adverse event to a full-text published article to information provided directly by a supplier. Documents might be assigned a value on: 1) the similarity of the device in the document to the device under consideration, based on technology, critical performance, design, and principles of operation; 2) the relevance of the particular experimental animals used in the selected studies for the biological evaluation of the device under consideration; and 3) conditions of use of the material or device in the selected documents and the intended use of the device in question.

Documents might also be valued on, 4) whether the author's conclusions are substantiated by the data, 5) whether the document reflects the current medical practice and state of the art technology, 6) whether documents are taken from recognized scientific publications and whether or not they have been reported in peer reviewed journals, and 7) the extent to which the data were acquired through established scientific literature.

[5] Critical evaluation of the literature
Note that valuation means the act of setting the value of something, while evaluation means a diagnosis or diagnostic study based on those values. 6. Dictionary.com.

Applying these definitions to literature reviews, we can say that we assess a document through the process of assigning it a separate value for each of several criteria, we weight the document by adding up the values, and we evaluate the body of documents (the literature) by determining if they address the key questions, placing the most emphasis on the document with the highest weights. The idea is to evaluate high quality data whether or not it is favorable to our technology.

The hoped-for outcome is to conclude than no new animal testing is justified, but it may be that we identify that new animal testing is indeed needed.

[6] Format and content
The literature evaluation itself may follow the standard format and content of other literature reviews.

[a] A short description of the material and device, including its intended use. I like to include the European and US classification, if known.
[b] Discussion of whether or not the literature supports the objectives or key questions.
[c] Evaluation of the hazards, risks, and appropriate safety measures that should be taken by the manufacturer.
[d] Description of the method of document selection, reasons for omitting documents, and methods of weighting documents.
[e] List of documents (full citations) used in the evaluation and appropriate cross-references.
[f] Conclusion with a justification for whether additional animal testing should be performed or is not necessary. The conclusion should include a discussion of probable risks and benefits, considering the 'state of the art' of the technology. And the conclusion should identify any gaps in evidence regarding safety or performance that should be addressed by future testing.
[g] The printed names, signatures, and responsibilities of the reviewers, and the dates of signature. I recommend attaching a biosketch or curriculum vitae of the reviewers as evidence of their experience.

Conclusion
Literature evaluations for biocompatibility are used to determine the need for animal biological safety testing or preclinical testing. Documents both favorable and unfavorable to the technology should be reviewed, but only those documents of the greatest assessed value need be evaluated. Naturally, the hoped-for outcome is that no further testing is needed.

The more common situation, however, is for the manufacturer to do a bunch of tests and then turn to the literature to defend an unfavorable outcome. While I'm not a proponent of this strategy, it is wiser to turn to the literature to explain an unwanted test result than to do even more animal testing. If you have unfavorable animal test results, find a knowledgable medical device toxicologist to assess what is currently known about your material, technology, or device, and then do whatever testing is still needed.

References
0. ISO 14155 "Clinical investigation of medical devices for human subjects—good clinical practice" (2011).
1. MEDDEV 2.7.1 r3 "Clinical Evaluation: A guide for manufacturers and Notified Bodies," (2009); clause 5.5.1.
2. AHRQ "Negative Pressure Wound Therapy Devices", 2009, http://www.ahrq.gov/Clinic/ta/negpresswtd/references.htm#ref65.
3. AHRQ "Comparative Effectiveness of Noninvasive Technologies for the Diagnosis of Coronary Artery Disease in Women", 2011, http://effectivehealthcare.ahrq.gov/index.cfm/research-available-for-comment/comment-draft-reports/?pageaction=displaydraftcommentform&topicid=202&productid=770&documenttype=draftReport.
4. ISO 10993-1 "Biological evaluation of medical devices—Part 1: Evaluation and testing within a risk management process" (2009).
5. FDA BlueBook Memo G95-1, "Use of International Standard ISO-10993, 'Biological Evaluation of Medical Devices Part 1: Evaluation and Testing'" (1995).
6. Dictionary.com, http://dictionary.reference.com/browse/evaluation.

Best Regards,
Nancy J Stark, PhD
President, Clinical Device Group Inc

 

Medical Device Biocompatibility

A Whitepaper by Dr. Nancy J Stark and Dr. Dan McLain

There are commonly three scenarios in which manufacturers call on CDG for biocompatibility help: a) FDA has raised questions about the safety tests you performed, b) you disagree that you need sensitization, genotoxicity, or carcinogenicity tests, or c) you have a new device and don't have a clue as to what tests to do. Can an expert opinion help?

Materials and the manufacturing process
We usually think about biological safety when selecting the materials for a new device. Many materials may be under consideration for a particular component. The mechanical properties, manufacturability, availability, aesthetics cost, as well as biological safety issues, are all considerations in the material selection process.

Often manufacturers believe they are using "common" material in their medical devices, but when challenged by FDA to give reasonable assurance of the material's safety they cannot offer specifics. You must establish the material is comparable after your manufacturing process. This is why biological safety tests are performed on final manufactured product. Some companies use final manufactured devices, others run a coupon of the material through the manufacturing process to get a material that is representative of the final process.

Back in the day—when one of us started working in the device industry—there were no recognized standards for device biological safety testing. Manufacturers floundered around looking for tests that seemed applicable. I once used US Pharmacopoeia (USP) tests for drug containers when developing a new syringe. Even today, suppliers and manufacturers sometimes assume that materials which meet USP Class V or VI requirements are sufficiently safe for device applications. (1 USP)

 

 

Step Two: "The Matrix"
Because of its long history, most manufacturers base their biological safety testing on "The Matrix". In 1986, regulators from FDA, the UK, and Canada published the Tripartite Biocompatibility Guidance. The guidance built upon standards that had previously been published by AAMI, ANSI, ASTM, and others. It looked at materials based on the type of tissue the material contacted and the duration of that contact. Then a testing category was recommended for each combination of contact and duration. The problem with the Tripartite Guidance was that nearly every category of biocompatibility test was recommended for nearly every combination of material contact and duration (198 out of a possible 240 categories were recommended.) (2 Tripartite) There were other problems too: it didn't tell you how to handle whole devices, and it didn't apply to metals or ceramics.

In 1992, the International Standards Organization (ISO) published ISO 10993 Part 1 "Guidance on selection of tests". The standard was part of a series of biological safety standards, but Part 1 included a matrix similar to the contact and duration matrix of the Tripartite Guidance. The major difference was that far fewer categories of tests were recommended (117 out of 240). (3 ISO 19003-1 Selection of Tests) This matrix was not accepted by FDA.

  

1995 brought us The Matrix as American manufacturers know it today. It is found in FDA's General Program Memorandum G95-1. (4 G95-1) With clairvoyance and foresight FDA modified the matrix presented in a version of the ISO 10993-1 standard that would not be published for another two years. (5 ISO 10993-1 Testing and Evaluation) The goal was to harmonize the agency's biological safety policy with the expectations of the international community. In the modified matrix, an additional 36 categories of tests are "suggested" for manufacturers to consider (for a total of 153 out of 240).

Step One: ISO 10993 Part 18 'Chemical characterization of materials' (2005)
A more ethical and efficient practice is to chemically characterize materials and compare them to materials in existing clinical use before performing animal tests. This is done in conformance to ISO 10993-18 'Chemical characterization of materials' (2005) and it should be done before the matrix is even consulted. (6 ISO 10993-18)

To put it in context, the chemical characterization of materials justify the performance or omission of animal biocompatibility tests, just as clinical evaluations justify the performance or omission of human clinical investigations.

  

Chemical characterization is the accepted method for comparing one finished, manufactured material to another in order to make the argument that they are clinically equal or that one material is no worse than a currently used material. The methodology has been developing over the years and was described in detail in a book by Dr. Stark in 2003. (7 Stark) The characterization is done in the following manner.

[1] Qualitative information
Describe the material and its intended purpose within the device. The description includes qualitative information such as supplier name, common name, chemical name, batch or lot number, visual and physical characteristics such as color, hardness, flexibility, and chemical family, and other specifications. The intended use of the material (type of tissue contact, duration of contact, and function) are also described.

[2] Material equivalence
The new material is compared to an existing material that is used in a device with the same clinical exposure; the device can be a commercial device from your own firm or it can be from your competitor. You can readily visualize a spreadsheet or database listing each material in the device and comparing it to another known material. If you have sufficient information for an expert to make a toxicological risk assessment you can stop here.

$$$$ Offer for Services $$$$

Expert Opinions and Consultation for Biological Safety

Dr. Dan McLain, is an internationally renowned medical device toxicologist. His position as convener of ISO 10993-11 is evidence of his global stature. Dan is available to assist with pre-clinical strategies and chemical risk assessments for your materials and devices. Our style is to work collaboratively with a point-person on your side so that you are involved in the process every step of the way. Phone or email us at 773-489-5721 or cdginc@clinicaldevice.com.

 

[3] Quantitative data
Quantitative data will be needed if a sound risk assessment cannot be made purely on qualitative information. This means a thorough knowledge of the chemical composition, additives, manufacturing residues, and leachables must be obtained through analytical and physical chemistry. The goal is to determine the amount of identified chemicals (such as monomers, anions, radioactive elements, and the like) that are present in the final, manufactured material.

[4] Quantitative risk assessment
In the quantitative risk assessment the amount (in µg, Gy for radiation, or other unit of exposure) of identified chemicals are compared to existing toxicological information, rather than to another material. The objective is to determine which, if any, of the chemicals in the material might be harmful at the calculated exposure.

[5] Estimate clinical exposure
Finally the amount of potentially harmful chemicals, the 'dose', is compared to the clinical dose a patient might receive in a lifetime, a procedure, or other unit of time. Such a comparison seeks to show that the maximum dose of a chemical one might receive is acceptable in light of the lowest dose that could case medical problems. Detailed methods for risk assessments are discussed in ISO 14155-17 'Methods for the establishment of allowable limits for leachable substances' (2008). (8 ISO 10993-17)

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"The Matrix" Is Available as a Mousepad/Notepad

CDG's talented graphic artists have reconfigured The Matrix and printed it on a high-quality mouse-grade paper pad. Now you can always have The Matrix at your workstation, in plain sight where you can find it. You can quickly look up the test categories needed while the boss is quizzing you on the phone. And at ten sheets to the pad, you can take notes on the conversation (or doodle), tear off the sheet, and keep it safe in the technical file.

Find it here, or contact Peggy at 773-489-5706 or cdginc@clinicaldevice.com.

Consider these examples, they are intended to illustrate the kind of issue you'll be addressing: a) Let's say you have a metallic implant that you clean by washing with perchloroethylene. Known to be highly volatile, but also highly toxic, you must ask if enough perchloroethylene remains on the metal implant to preclude its use as a cleaning agent; b) Let's say you make a wound dressing that contains a potassium salt. You know that potassium affects cardiac function and in sufficiently high concentrations could put a patient into cardiac arrest. You must ask if sufficient potassium can leach out of the dressing and into the wound to affect cardiac function.

References
(1 USP) United States Pharmacopeia.
(2 Tripartite) Tripartite Biocompatibility Guidance G87-1, (1987).
(3 ISO 10993-1 Selection of tests) ISO 10993-1 Biological evaluation of medical devices: Selection of tests (1992).
(4 G95-1) "Use of International Standard ISO-10993-1 Biological Evaluation of Medical Devices: Evaluation and Testing", G95-1 (1995).
(5 ISO 10993-1 Evaluation and Testing) ISO 10993-1 Biological evaluation of medical devices: Evaluation and testing (1997).
(6 ISO 10993-18) ISO 10993-18 Biological evaluation of medical devices: Chemical characterization of materials (2005).
(7 Stark) "Biocompatibility Testing & Management" Fourth Edition, Nancy J Stark, Clinical Device Group Inc, 2003.
(8 ISO 10993-17) ISO 10993-17 Biological evaluation of medical devices: Methods for the establishment of allowable limits for leachable substances (2008).

Questions or Comments?
Do you have questions, comments, or additional information? Please post them below.

 

European Medical Device Update

A Few Items of Note about Device Regulation in the European Union

Life keeps moving along in Europe in spite of the snow and closed airports. Here are three important medical device regulatory issues you'll want to address in the new year.

[1] No phase in period for ISO 14155 "Clinical investigation of medical devices in human subjects—good clinical practices"
If the stars align, Jupiter stays in the heavens, and my cat stops catching birds, ISO 14155 may be published in the first quarter of 2011. But don't wait around for the big event. Implementation will be immediate and there is no phase in period!

The convener recommends all sponsors start updating their clinical investigation procedures now. However, updating your procedures is a little bit difficult because the final draft of the standard is not available for purchase on the www.iso.org website. ISO.org lists the standard as being under publication (stage 60.00) but provides no means to add it to your shopping cart.

 

The same is true for the Association for the Advancement of Medical Instrumentation at www.aami.org, which has inexplicably truncated the title to "Clinical investigation of medical devices for human subjects" and left off the declaration of "good clinical practices". AAMI claims identical equivalency to ISO 14155/Ed.3 (edition 3?), and states the draft is not available 'outside of committee'.

CDG can update your clinical procedures to ISO/FDIS 14155

Clinical Device Group is a corporate member of AAMI, a member of ISO TC 194, and has access to the final draft versions of ISO/FDIS 14155 "Clinical investigation of medical devices for human subjects—good clinical practices". While we can't provide you with a copy of the unreleased document, we can review your existing procedures and make recommendations to bring them into conformance. Our style is to work collaboratively with point-person on your side so that you are involved in the process every step of the way. Phone or email us at 773-489-5706 or cdginc@clinicaldevice.com.

 If you don't work for one of the thirty or so firms who pay corporate dues to AAMI, are members of TC 194, and have access to the final draft standard, you will have to figure out another game plan. You might consider hiring a CRO with access to the final draft to update your procedures for you.

2] MEDDEV 2.7/3 Serious adverse event reporting under the amended Directives
The European Commission published MEDDEV 2.7/3 "Serious Adverse Event Reporting under 90/385/EEC and 93/42/EEC" in December 2010. Although the guidance is voluntary, you are strongly urged to follow it. The guidance uses the ISO/FDIS 14155 definitions of adverse events and effects, and recommends that all serious adverse events (SAEs), device deficiencies that might lead to SAEs, and any new findings regarding existing SAEs, be reported to every National Competent Authority (NCA) in which the investigation is being conducted.

Two categories of SAEs
The guidance takes the odd approach of dividing SAEs into two categories: a) those that require prompt remedial action, and b) those that do not.

SAEs that require prompt remedial action to mitigate an imminent risk of death, serious injury, or serious illness should be reported immediately but no more than 2 (two) calendar days to the NCAs using the Reporting Form provided in the guidance Appendix. SAEs that do not require prompt remedial action should be reported no more than 7 (seven) calendar days. The MEDDEV 2.7/3 guidance and an Excel spreadsheet of the Reporting Form are provided on CDG's website.

Observations
A serious adverse event that occurs at a US site should be reported to every European NCA in which the investigation is also being conducted. CDG recommends that investigations in the US and EU be administered and managed as separate studies because: 1) it is difficult to meet the reporting requirements of two different regulatory entities in the same investigation, and 2) it is difficult to justify pooling data given the differences in medical practice. Patients in countries with socialized medicine tend to be farther along in the disease process before receiving medical care than patients from countries with for-profit medical care.

The guidance makes no mention of reporting serious adverse events to Ethical Committees. It doesn't discuss sharing of data between National Competent Authorities. It doesn't address setting up a European database of serious adverse events. And it doesn't address making the SAE reports available to the public. As much as we have complained about a lack of transparency and organization at FDA in recent whitepapers, Europe has a long way to go before it catches up.

[3] MEDDEV 2.7/4 Clinical investigations: A guide for manufacturers and Notified Bodies
The European Commission also published MEDDEV 2.7/4 "Guidelines on Clinical Investigation: A Guide for Manufacturers and Notified Bodies" in December 2010. Again the guideline is not legally binding, but it reflects the thinking of the European Commission and what manufacturers can reasonably expect from their Notified Bodies.

Distinctions
The guideline tries to clarify the European distinctions between clinical data, clinical evaluation [reports], and clinical evidence. The logic is not obvious, so I've designed a graphic to help sort it out.

 

Clinical data are numbers, values, measurements, and the like, taken from the literature, sponsored clinical investigations, and other reports such as complaint history files and risk management systems.

Clinical data are assessed, analyzed, and written up in clinical evaluation reports.

Clinical evidence is both the original clinical data (numbers and values) and the clinical evaluation report.

If the clinical evidence is sufficient to establish the safety and performance of a device for its intended use, then the manufacturer may declare conformity to the essential requirements and proceed to market the device. If the clinical evidence is insufficient to establish safety and performance, the manufacturer may withdraw the claim or proceed to a new clinical trial in an effort to generate data to substantiate the claim.

Differences between US and EU
The fundamentals of good clinical practices haven't changed and are not much different between the US and EU. The new ISO 14155 standard was written to harmonize as close as possible with the existing ICH-GCPs; so if you are an experienced clinical research professional there will be no surprises. But there are some differences in implementation.

The first difference is the heavy level of adverse event reporting in Europe. Even for European Class I and IIa devices, all adverse events are reportable to sponsors, Ethics Committees, and NCAs; and all serious adverse events—device related or not—are reportable to NCAs within 2-7 days. In the States, for significant risk devices, only adverse device effects are reportable to sponsors, IRBs, and FDA (unless FDA requires more for a particular investigation); and for non-significant risk devices, adverse device effects are only reportable to sponsors and IRBs.

The second difference will be the increased emphasis on risk management in the clinical investigation process and figuring out how to apply ISO 14971 "Application of risk management to medical devices" to clinical investigations.

Got feedback?
If you have comments, disagreements, or additional information, please post them below. I look forward to hearing from you.

Happy New Year,

Nancy J Stark, PhD
President, Clinical Device Group Inc
cdginc@clinicaldevice.com

 

 

A Plan for EU Clinical Evaluation Reports

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.

Resources
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
First leg
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:
[1] Define the key questions.
[2] Identify the databases to search (Medline, Embase, MAUDE, Cochrane).
[3] Define scope of search and search strategies using a qualified information specialist.
[4] Scan the abstracts to identify articles for review.
[5] Acquire full-texts of articles.
[6] Weight the articles for technical significance, discard anything with a low weight.
[7] Have a statistician weight the articles for statistical significance, discard anything with a low weight.
[8] 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.

Second Leg
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.

Third leg
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.

Buffet approach
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.

Contact us
Phone or email us at 773-489-5721 or cdginc@clinicaldevice.com.

ISO/FDIS 14155 "Clinical Investigations of Medical Devices in human subjects—good clinical practices" (2010)

New Rules for International Device Trials
A Whitepaper and Workshop by Nancy J Stark, PhD
Wednesday, 22 September 2010, 11 AM Central; or OnDemand soon after. 

Sweeping changes to ISO 14155
The international standard for medical device clinical research is about to undergo sweeping changes. The first and most evident change is the change in title; the standard is now known as ISO/FDIS 14155 " Clinical investigations of medical devices in human subjects—good clinical practices". Harmonized with the ICH-GCPs, 'Good clinical practices' was added to the title to signal to the world the Working Group's intention that this is now the standard to be followed for international medical device investigations.

There are other significant changes as well. The mechanical, physical, and engineering nature of devices are taken into account with the integration of the normative reference ISO 14971 "Application of Risk Management to Medical Devices". The contents of Investigator's Brochures looks like a document that reflects a mechanical device rather than a chemical drug, while the requirements for recording and reporting device deficiencies alongside adverse events complements the essential requirements of the MDD and AIMD.

All studies are created equal
Possibly the hardest thing for Americans to grasp is that there is no risk-based categorization of clinical trials in the standard. The concept of non-significant risk studies versus significant risk studies does not exist—all the rules apply equally to all clinical investigations.

An international standard written by international experts
The new standard was written by a team of experts from the US, Europe, and Japan. The team consisted of industry representatives, consultants, and regulators to assure that it was achievable, consistent with country regulations, and in keeping with accepted ethical and organizational practices. It did not come easily; the working group and editing committee met fourteen times, with a dozen or so teleconferences sprinkled in between the meetings.

One result is a standard that will be an an economic leveler—it will be neither easier nor more difficult to conduct a trial in one country over another. Another result is a standard that will be an ethical leveler—it will be neither easier nor more difficult to conduct trials in developing countries than developed countries.

Format and approach
The Part 1 and Part 2 standards from 2003 are now combined into single, comprehensive, 65-page document. The strategy was to approach clinical investigations from a project management perspective. A look at the layout gives an idea of the breadth and depth of the standard.

First, there are four administrative sections:
[1] Scope.
[2] Normative references.
[3] Terms and definitions.
[4] Ethical considerations.
The scope tells us that "the principles ...apply to all other clinical investigations...." The statement has no legal precedence but was clearly important to the Europeans. The scope also makes it clear that the standard does not apply to in vitro diagnostic devices.

"Normative" is ISO-speak for required. It is the one, small sentence under normative references that elevates ISO 14971 to importance. Being listed as a normative reference means that the sponsor is, de facto, non-compliant with ISO 14155 if they are not compliant with ISO 14971. Scattered throughout the document are the many ways in which Risk Analysis Reports are integrated into clinical investigations.

These are followed by three project planning sections:
[5] Clinical investigation planning.
[6] Clinical investigation conduct.
[7] Suspension, termination, and close-out.
It is not that there is anything new in the project management sections, but there is so much more detail and instructive language. If you have never done a clinical study before, you will find these sections to be a welcome reference.

The need for a Clinical Evaluation Report performed according to the principles of GHTF Study Group 5 to justify the design of the clinical protocol is another example of a requirement included to meet the essential requirements of EU Directive 93/42/EEC on medical devices (MDD) and EU Directive 90/385/EEC on active implantable medical devices (AIMD).

These are followed by two responsibilities sections:
[8] Responsibilities of the sponsor.
[9] Responsibilities of the principal investigator.
Sponsor and principal investigator responsibilities follow closely with FDA's new guidance "Investigator Responsibilities—Protecting the Rights, Safety, and Welfare of Study Subjects" and the ICH-GCPs. Principal investigators (aka "investigators" in the States) are still required to sign final reports under ISO, but investigators (aka "co-investigators" or "sub-investigators" in the States) are off the hook.

While much of the detail is laid out in five annexes:
Annex A (normative)—Clinical investigation plan.
Annex B (normative)—Investigator's Brochure.
Annex C (informative)—Case report forms.
Annex D (informative)—Clinical investigation report.
Annex E (informative)—Essential clinical investigation documents.
Annex F (informative)—Adverse event classification decision tree.
Annexes A and B on Clinical Investigation Plans (i.e. protocols) and Investigator's Brochures are required for compliance, the remaining annexes are for the reader's information. They contain extremely valuable information on organizing case report forms, writing a final report, and understanding the relationships between adverse events and effects.

Other extensive changes
Each section was expanded to include sufficient narrative to teach a new sponsor how to conduct a clinical investigation. This controversial move is meant to educate as well as to set a performance bar. Some notable examples of additions or changes include:
[1] Clearer definitions of adverse events, adverse device effects, and unanticipated device effects.
[2] A new definition, recording, and reporting requirements for device deficiencies.
[3] Requirements for recording and reporting adverse device effects in persons other than subjects.
[4] Implied requirement for a clinical research quality management system.
[5] Requirement for Risk Analysis Report.
[6] Requirement for a Clinical Evaluation Report to justify the study design.
[7] Required content for a protocol (clinical investigation plan).
[8] Required content for an Investigator's Brochure.
[9] Suggested content and organization for case report forms.
[10] Discussion of data monitoring committees.
[11] Requirements for document and data control.
[12] Requirements for electronic data systems.
[13] Auditing recommendations.
[14] Procedures for suspension or premature termination of a trial.
[15] Procedures for working with vulnerable populations.
[17] An extensive list of the documents essential for a clinical trial.
[18] Omission of the annex discussing how to do a literature review.
[19] And, very importantly, two differing attempts at adverse event classification.

The publication plan
FDIS stands for 'final draft international standard'. While the document is in the final draft stage it is being translated into French and German. Once this is complete the FDIS will be presented to the ISO members (Standards Bodies from each member country) for a final vote, but the only changes allowed at this stage will be spelling, punctuation, or grammar. After publication by ISO in 2011, each member Standards Body will adopt the standard into its own system; so in the US the standard will be re-issued as an ANSI (American National Standards Institute) standard of the same number.

Oddly enough, a member Standards Body is free to modify the standard, before issuing it under its own name if it wishes. So buyer beware, the French version may be different from the British version or from the US version!

If you liked the whitepaper, take the workshop
The learning objective of this five-hour workshop is to review the changes from the old, 2003 standards to the new, 2010 FDIS. The recording is available by OnDemand or CD at http://www.clinicaldevice.com/mall/Workshops.aspx.

You will receive, we will discuss
[x] PowerPoint slides.
[x] A 5 hour presentation.
[x] Hints for writing Clinical Evaluation Reports and their role in clinical investigations.
[x] Hints for writing Risk Analysis Reports and their role in clinical investigations.
[x] The required contents of clinical investigation plans (i.e. protocols).
[x] The required contents of investigator's brochures.
[x] Steps in planning clinical investigations.
[x] Steps in implementing clinical investigations.
[x] Steps in closing-out clinical investigations.
[x] The monitor's role in clinical investigations.
[x] Responsibilities of sponsors and investigators.
[x] A 30-minute quiz to reinforce your learning experience.
[x] CEUs and certificate of attendance.

Who should attend
[x] Clinical research professionals who estimate study costs.
[x] Project managers who want better planning and reporting from their group.
[x] CROs who want to improve their proposal skills.
[x] Executives who are planning the future of their company.

Presenter
Dr. Nancy J Stark has been a member of Working Group 4 since 2001 and was an active participant in shaping the coming ISO 14155 standard. She is President and Founder of Clinical Device Group, a CRO and consulting firm that has been in business since 1990. Her curriculum vitae can be found at www.nancystark.com.

System requirements
[x] Personal computer.
[x] Internet Access.
[x] Telephone.

Date, time, registration
The 5 hour workshop will be presented on Wednesday, 22 September 2010, at 11:00 Central Time. Event materials will be distributed the day before the workshop. Sign up at registration.

Best Regards,
Nancy J Stark, PhD
President, Clinical Device Group Inc