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IVDR Requirements (In Vitro Diagnostic Regulation)

Definition

IVDR Requirements refer to the set of regulatory obligations defined under Regulation (EU) 2017/746, which governs the placing on the market and use of in vitro diagnostic medical devices (IVDs) within the European Union. These requirements ensure that IVDs meet high standards of quality, safety, and performance, protecting public health and patient safety.

The IVDR replaces the previous In Vitro Diagnostic Medical Devices Directive (IVDD 98/79/EC) and introduces more stringent compliance obligations, including classification rules, performance evaluation, clinical evidence, and post-market surveillance.

Detailed Explanation

Purpose and Importance of IVDR Requirements

The IVDR was introduced to harmonize the regulatory framework for in vitro diagnostic devices across EU member states and to address significant technological advancements and safety concerns. The regulation aims to:

  • Ensure the safety and performance of IVDs throughout their lifecycle
  • Enhance transparency and traceability of diagnostic devices
  • Strengthen post-market surveillance and vigilance systems
  • Improve the consistency of conformity assessments

Key IVDR Compliance Requirements

Manufacturers, authorized representatives, importers, and distributors must comply with several core requirements under IVDR 2017/746:

1. Device Classification

IVDR introduces a risk-based classification system with four classes: A (lowest risk), B, C, and D (highest risk). Classification determines the level of regulatory scrutiny and the involvement of Notified Bodies.

2. Performance Evaluation

Manufacturers must conduct a comprehensive performance evaluation, including:

  • Scientific validity: Demonstrating the association of an analyte with a clinical condition
  • Analytical performance: Accuracy, precision, sensitivity, specificity, etc.
  • Clinical performance: Ability of the device to yield results correlated with a clinical condition

3. Technical Documentation

Manufacturers must prepare and maintain up-to-date technical documentation that includes:

  • Device description and specification
  • Design and manufacturing information
  • Risk management documentation
  • Performance evaluation reports
  • Instructions for use and labeling

4. Quality Management System (QMS)

Manufacturers are required to implement a robust QMS that complies with IVDR Article 10. This includes processes for design control, supplier management, complaint handling, and corrective/preventive actions (CAPA).

5. Post-Market Surveillance (PMS)

Manufacturers must establish a PMS system to proactively collect and analyze data on device performance once on the market. This includes:

  • Post-market performance follow-up (PMPF)
  • Periodic safety update reports (PSUR)
  • Vigilance reporting of serious incidents and field safety corrective actions (FSCAs)

6. Unique Device Identification (UDI)

To improve traceability, all IVDs must bear a UDI, which must be registered in the European Database on Medical Devices (EUDAMED).

7. Notified Body Involvement

Under IVDR, most IVDs (except Class A non-sterile) require conformity assessment by a Notified Body. The assessment includes audits, technical documentation review, and performance evaluation oversight.

Examples and Contexts of Use

Examples of devices affected by IVDR requirements include:

  • COVID-19 diagnostic test kits (Class D)
  • Pregnancy and fertility tests (Class C)
  • Blood glucose monitoring systems (Class C)
  • Laboratory reagents and controls (Class A or B)

Manufacturers must align their development, registration, and market surveillance processes with IVDR 2017/746 to ensure continued access to the EU market. Failure to comply can result in device withdrawal or legal penalties.

References

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