How to place a Custom-made Medical Device on the market?

Apr 17, 2023

Marketing custom-made medical equipment can be a challenging procedure that involves several regulatory regulations and high criteria for quality assurance. The main procedures for releasing a specially created medical device onto the market will be covered in this blog, including design and development, testing and validation, regulatory compliance, and marketing and distribution plans. By being aware of these processes, you can make sure that your specially produced medical gadget satisfies all standards and reaches its target market in a secure and efficient manner.

 

Custom-made Medical device definition:

A custom-made medical device, also known as a custom device or a made-to-order device, is a medical item created and produced specifically for a single patient. Auricular splints, dentures, orthodontic tools, orthotics, and prosthetics are a few examples of custom-made medical equipment. An individual patient's unique medical needs, which are incompatible with typical off-the-shelf medical devices, are to be met by a custom-made medical device.

 

Custom-made medical devices can enhance a patient's mobility or functionality, help treat medical conditions or injuries for which there may be no other effective treatments, and improve the patient's quality of life by designing and manufacturing a device that is specifically suited to their individual anatomical or physiological characteristics. To improve the patient's results, customised medical gadgets can also be applied during operations or as a component of continuous care.

 

Clarification:

A custom-made device is not a normal product; rather, it is a product required by a licensed expert under a written prescription, which is the first thing you need to grasp. You need to clarify the needs and requirements based on which the actual device will be made!

 

Mass-Production:

Medical gadgets that are mass-produced are those that are created in big quantities and are designed to be used by numerous patients. Without being customised for specific patients, these devices are made to a standard specification and are intended to fulfil broad medical demands.

 

Is a 3D printed device considered custom-made?

If a 3D printed equipment is created specifically for a patient based on their particular anatomical or physiological traits, then yes, it may be said to be custom-made. Medical 3D printing involves creating physical reproductions of anatomical structures in order to create medical equipment directly or indirectly. Using MRI, X-Ray CT, and other 3D imaging techniques, you can create digital models of structures for 3D printing. Recently, this approach has become more widely used for clinical and research-based healthcare activities. With 3D printing, it is possible to produce small batch sizes quickly and affordably, which is a significant benefit.

 

Over the following few years, it is projected that as the cost and accessibility of the technology decline, so will its application in medicine. It is anticipated that this development will lead to increased 3D printing use in clinical and educational settings, better regulatory guidance, and more competition among manufacturers of medical devices.

 

Requirements to register a custom-made device:

We can continue when you can attest that your product is indeed a custom-made device. There are two types of specialised equipment:

  • General Custom-made devices
  • Class III implantable Custom-made devices

You must adhere to Annex XIII's standards for generic devices.

  • Make a statement
  • Maintain all conformity-demonstrating documentation in the Competent Authority Archive for 10 years and 15 years for implanted devices.
  • Utilise PMCF to monitor the devices' performance.

 

MDCG 2021-3:

The MDCG group published a guide for custom-made devices in the form of questions and answers. What makes this blog intriguing is the amount of vocabulary it provides, such as:

  • Adaptable medical equipment
  • Patient match devices

We have the following devices within the definition of what constitutes a CMD:

  • Mass-produced items that need to be modified to satisfy the unique needs of any professional user. We refer to these as adaptable gadgets.
  • Devices that are mass-produced using industrial manufacturing techniques, maybe following a written prescription from a qualified individual. The patient match devices can incorporate that.

Therefore, take care to ensure that your product does not fall into one of these categories otherwise it will not be regarded as a custom-made item.

 

Podcast:

You can explore the world of custom-made medical devices, from design and development to regulatory compliance and patient impact, in several podcast episode available online.


The distinction between general custom-made and class III implantable device:

Category General Custom-Made Medical Devices Class III Implantable Medical Devices
Definition Devices designed and manufactured for a specific patient based on their unique anatomical or physiological characteristics, intended for exclusive use. High-risk medical devices that are surgically implanted into the body and intended to stay there for an extended period of time.
Examples Prosthetics, orthotics, hearing aids, dental implants. Heart valves, pacemakers, artificial joints, spinal cord stimulators.
Regulatory Classification Class I (low-risk) or Class II (moderate-risk) medical devices. Class III (high-risk) medical devices.
Regulatory Requirements Must meet relevant regulatory requirements, including design control and quality system requirements. Must undergo rigorous premarket review, including clinical trials, to demonstrate safety and effectiveness.
Manufacturing Standards Must adhere to relevant manufacturing standards, such as ISO 13485. Must adhere to relevant manufacturing standards, such as ISO 13485, and have a validated manufacturing process.
Patient Impact Improves patient quality of life, functionality, and addresses medical conditions or injuries that may not have other treatment options. Can significantly improve patient outcomes and quality of life, but also have potential for serious adverse events or complications.


A podcast called Medical Device Made Easy provides information, advice, and tactics for creating and marketing medical devices. It is hosted by experts and includes conversations with business leaders who discuss various facets of the creation of medical devices.


Documentation requirements:

The statement that you must create is a crucial document for things that are produced to order. There isn't a specific form in existence; only a list of what must be included. The following conditions must be met by this assertion:

 

  • The manufacturer's name, address, and locations of all manufacturing facilities,
  • The name and address of the authorised representative, if relevant,
  • Information allowing the device in question to be identified,
  • A declaration that the equipment is only meant to be used by a specific patient or user, identified by name, abbreviation, or numerical code,
  • The name of the person who wrote the prescription and is permitted to do so under national law due to their professional credentials, as well as, if appropriate, the name of the healthcare facility,
  • The product's precise attributes as specified by the prescription,
  • A declaration that the device in question complies with the general safety and performance standards listed in Annex I and, if appropriate, a list of the requirements that haven't been fully satisfied, along with an explanation of why,
  • If appropriate, a statement stating the device includes or incorporates a medical ingredient, such as a derivative of human blood or plasma, human or animal tissues, or cells, as defined by Regulation (EU) No 722/2012.

 

PRRC - Person Responsible for Regulatory Compliance:

The PRRC is in charge of ensuring regulatory compliance. According to the MDR, your company must have a PRRC, and if you are selling customised goods, this PRRC needs to be informed about those particular goods. If necessary, you can also hire an outside consulting firm, but there are several important prerequisites.

 

Archiving of documents:

If your items are implantable, the documentation must be kept on file for at least 15 years and at least 10 years for medical devices. The archiving component is crucial. It is essential that you can give a copy of the paperwork used to promote the custom items to the appropriate authorities upon request.

 

So, it's important to have a record retention policy. You must specify in your system how long these documents should be retained and ensure that the retention requirements are suitable. Don't undervalue the need for this. Because you should be able to promptly access the document if the competent authority contacts you 10 years from the date you gave your product.

 

Post-production information – PMCF:

The manufacturer of a special equipment should keep learning from the post-production stage. According to Annex XIV Part B, one method that can be utilised for this is PMCF, or Post-market Clinical Follow-up. In accordance with article 87(1) of the MDR 2017/745, the manufacturer is still required to notify the authorities of any difficulties that are discovered. As a result, you shouldn't assume that a custom-made gadget does not adhere to requirements established for generic devices.

 

Quality Management System:

If you are simply working on custom-made devices, unless they are class III implantables, it is not clearly stated that you need a certified Quality System. You should choose a route for class III implantables when a certified QMS is required. We strongly advise using one of the other devices so that some of the requirements can be met more effectively.


For instance (and this is not an entire list):

  • Suitable format for the assertion
  • How-to guide for filling out the form
  • Guidelines for document archiving
  • Review of custom devices included in the post-marketing process

 

If your business is small, you can undoubtedly argue that there aren't many people doing that, but if these employees leave, you lose a lot of expertise. It is preferable to include that in a procedure to ensure that you are following the rules and that everyone is acting in the same way.

 

Decision tree:

●      Identify the need

●      Assess feasibility

●      Evaluate risks

●      Evaluate benefits

●      Consider regulatory requirements

●      Determine design specifications

●      Develop and test prototype

●      Manufacturing and quality control

●      Post-market surveillance

●      Re-evaluate

 

Should I put the CE logo on a Custom-made device?

The quick response is "no". The detailed response is available under "Article 20 - CE marking of conformity" of Medical Device Regulation MDR 2017/745. Devices that are thought to meet the standards of this Regulation, excluding custom-made or experimental devices, must display the CE mark of conformity described in Annex V. Therefore, you are not required to include the CE mark logo if your product is a custom-made or experimental device.

 

Custom-made device (MHRA):

The definition of a Custom-made for the UK market is contained in the UK MHRA's advice on the registration of medical devices in the UK. You must exercise caution because the UK MHRA is currently adhering to MDD 93/42/EC for the UKCA, but because they are working to issue new laws, the information on this advisory is subject to change. If you live outside of the UK and need to register a custom device there, you should ask a UK Responsible person (also known as an Authorised Representative in the EU) to handle it on your behalf.

 

Competent authorities’ registration:

  • Prosthetic limbs that are constructed specifically for each patient's anatomy and functional requirements can be created.
  • Dental implants made to order can be constructed to suit a patient's mouth perfectly and offer the best possible function and appearance.
  • Hearing aids that are manufactured to order can be tailored to a patient's exact hearing requirements and preferences.
  • Patients with illnesses like cerebral palsy or multiple sclerosis can benefit from the support and improved movement that can be provided by specially tailored orthotics.
  • To simplify complicated surgical procedures and enhance patient outcomes, custom surgical equipment might be produced.
  • Devices for assistive technology that are built specifically for a person with a disability can help them carry out daily tasks and enhance their quality of life.
  • To replace or repair damaged bone or tissue in the body, such as in cases of spinal cord injury or joint replacement, custom implants can be manufactured.
  • In order to provide more precise and individualised assessments of a patient's medical status, customised diagnostic instruments might be created.

 

FAQ's:                                                             

  • How do you put a medical device on the market?

    Obtaining regulatory permission, ensuring compliance, and meeting quality and safety criteria are necessary before a medical device can be sold.  

  • Who is responsible for placing a medical device on the market?

    The manufacturer is responsible for placing a medical device on the market and ensuring it meets regulatory requirements.

  • How can I sell medical devices?

    You must first obtain regulatory approval, ensure that all applicable rules are followed, and establish a distribution network or a working relationship with a distributor of medical devices in order to market medical devices.

  • Do custom-made devices need CE mark?

    Yes, custom-made devices require CE marking in the European Union.

  • How do I get FDA approval for a medical device?

    To obtain FDA approval for a medical device, you must submit a premarket notification or premarket approval application and undergo regulatory review.

  • Is FDA approval required for medical devices?

    Most medical devices supplied in the US must have FDA clearance or approval, while some low-risk devices might merely need registration.

  • How long does it take to bring a medical device to market?

    The length of time it takes to bring a medical device to market can range from several months to several years, depending on the complexity of the device, the regulatory process, and other considerations.

  • How profitable are medical devices?

    Medical device profitability varies greatly depending on the market, the level of competition, and other elements. While some devices may not be commercially viable, others can be very successful.



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A Leaders Guide In the modern workplace, leaders must be aware of the subtle cues that signal an employee disengaging – a behaviour referred to as "silent" or "quiet" quitting. Unlike an obvious resignation, silent quitting occurs when employees mentally check out, disheartened by various factors that reduce their commitment to the company. In the era of remote work, leaders face an extra challenge in identifying signs of silent quitting among their distributed teams. The absence of physical presence makes it imperative for leaders to be attuned to subtle cues that may indicate disengagement. Here’s what to look out for: Decreased Visibility An obvious reduction in putting their camera on or offering opinion Refusing to go into the office when the rest of the team are in  Decreased Initiative Observable decline in proactivity and initiative Minimal or no contribution beyond routine responsibilities Withdrawal from Social Activities or Collaboration Reluctance to participate in team discussions or collaborative projects Limited interaction with colleagues, both professionally and socially Lack of Innovation Diminished enthusiasm for proposing and implementing new ideas A decline in creativity and problem-solving efforts Deteriorating Quality of Work Noticeable decrease in the quality and thoroughness of completed tasks. Frequent errors or oversights in work that was previously meticulous. Increased Absenteeism Unexplained absences or a rise in the frequency of sick leave Disengaged employees may use time away as a form of escape Negative Attitude A shift in demeanor marked by increased cynicism or pessimism Lack of enthusiasm for company goals or achievements Strategies to Reignite Engagement More Open Communication Encourage regular feedback sessions to address concerns Create an environment where employees feel comfortable expressing their thoughts Offer Enhanced Professional Development Invest in continuous learning and skill development Show a commitment to employees' long-term growth within the company Acknowledge and Reward Contributions Recognise and celebrate individual and team achievements Implement a rewards system that reinforces positive behaviors Offer More Responsibility Assign exciting, larger projects to try and re-engage employees Assign tasks with added visibility in the company to make the employees feel valued Promote Work-Life Balance Support flexible work arrangements when feasible Recognise the importance of employees' well-being beyond work Clarify Expectations Clearly communicate roles, responsibilities, and expectations Ensure employees understand how their contributions align with overall company Address Issues Promptly Respond swiftly to signs of dissatisfaction or disengagement Work collaboratively to find solutions to underlying problems Cultivate a Positive Company Culture Encourage a culture of trust, respect, and inclusivity Encourage a sense of belonging and shared purpose among the team Recognising the signs of silent quitting requires an astute leadership. By addressing these indicators quickly and implementing strategies to boost engagement, leaders can create a workplace where employees feel valued, motivated, and committed to achieving shared goals.
19 Oct, 2023
Introduction The field of Medical Technology (MedTech) is on the brink of a transformative era. As we approach 2024, it's becoming increasingly clear that this sector is set to redefine healthcare as we know it. With innovations spanning from AI-driven diagnostics to personalized treatments, the Medtech industry is at the forefront of medical breakthroughs. In this blog, we'll take a closer look at the exciting developments expected in the MedTech landscape in 2024 and beyond. 1. Innovative Technologies The year 2024 promises to be a pivotal moment for the integration of cutting-edge technologies in healthcare. Artificial Intelligence (AI) and machine learning will continue to play a central role in the industry, revolutionizing diagnostics, and treatment planning. Through data analysis and pattern recognition, AI-powered systems can assist healthcare professionals in making more accurate and timely decisions, ultimately improving patient outcomes. 2. Personalized Medicine One of the most significant trends in Medtech is the rise of personalized medicine. Thanks to advancements in genomics and precision medicine, treatments are increasingly tailored to the individual. Genetic information, combined with a patient's medical history, will allow healthcare providers to offer therapies that are not only more effective but also less likely to cause adverse reactions. 3. Wearable Health Tech Wearable devices, such as smartwatches and fitness trackers, are becoming integral to healthcare. In 2024, these wearables will continue to evolve, providing real-time health data to users and their healthcare providers. From tracking vital signs to monitor chronic conditions, wearable health tech is empowering individuals to take charge of their well-being. 4. Telemedicine and Remote Monitoring The COVID-19 pandemic accelerated the adoption of telemedicine, and it's here to stay. In 2024, telemedicine will become a standard component of healthcare delivery, offering convenient and accessible options for patients. Remote monitoring, enabled by IoT devices, will enable healthcare providers to keep a close eye on patients' health, especially those with chronic conditions. 5. Regulatory Changes The Medtech industry is subject to rigorous regulations to ensure patient safety. In 2024, we can expect to see new guidelines and standards to keep pace with the evolving landscape. Regulatory agencies like the FDA will continue to adapt to technological advancements, streamlining approval processes for innovative medical devices. 6. Cybersecurity Concerns As Medtech becomes more interconnected, cybersecurity will become a paramount concern. Protecting sensitive patient data and ensuring the security of medical devices will be a top priority. The industry will invest in robust cybersecurity measures to safeguard against potential threats. 7. Market Trends The Medtech market will continue to experience growth, driven by emerging technologies and increasing demand for healthcare solutions. Startups and innovation hubs will play a pivotal role in driving industry growth by developing groundbreaking solutions and attracting investment. 8. Global Health Initiatives 2024 will witness a continued focus on global health initiatives. Collaborations between Medtech companies and organizations working to address global healthcare challenges will accelerate the development and distribution of life-saving technologies worldwide. Conclusion The future of MedTech in 2024 holds promise and potential. From AI-powered diagnostics to wearable health tech and personalized medicine, the industry is poised to reshape healthcare in ways we can only begin to imagine. As these innovations become a reality, the world can look forward to improved patient outcomes, increased access to healthcare, and a brighter and healthier future for all. Stay tuned for more exciting developments in the world of MedTech as we embark on this transformative journey. 
13 Oct, 2023
Introduction In recent years, the healthcare landscape has witnessed a significant shift towards providing care in the comfort of patients' homes. The widespread use of medical devices designed for home healthcare settings has made this evolution possible. While these devices offer many benefits, they also have a crucial responsibility: ensuring compliance with regulatory standards. In this blog, we will explore the importance of medical device compliance in home healthcare settings, the regulatory framework, and steps to ensure that medical devices meet the requirements. The Rise of Home Healthcare The rise of home healthcare has revolutionized the way patients receive medical attention. Patients can now manage chronic conditions, receive post-surgical care, and monitor their health from the convenience of their own homes. Advancements in medical technology have sped up this shift, which has resulted in a wide range of medical devices being designed specifically for home use. Types of Medical Devices in Home Healthcare Medical devices used in home healthcare settings encompass a broad spectrum of products. These include but are not limited to: Monitoring Devices: Blood pressure monitors, glucose meters, and pulse oximeters. Therapeutic Devices: Like home ventilators, nebulizers, and infusion pumps. Diagnostic Devices: Such as home pregnancy tests, thermometers, and home test kits for various medical conditions. Assistive Devices: Including mobility aids, home care beds, and lift chairs. The Regulatory Framework Ensuring the safety and effectiveness of medical devices is paramount in home healthcare. To achieve this, regulatory agencies around the world have established stringent guidelines for the development, manufacturing, and distribution of medical devices. In the United States, the Food and Drug Administration (FDA) plays a central role in regulating medical devices. In the European Union, the European Medicines Agency (EMA) and the Conformity Europeans (CE) marking are vital authorities. Critical Steps for Medical Device Compliance in Home Healthcare Settings Product Classification: Determine the appropriate regulatory class for your medical device. This classification will dictate the level of scrutiny and requirements your device must meet. Categories range from Class I (low-risk) to Class III (high-risk). Quality Management System (QMS): Establish a robust QMS compliant with relevant quality standards such as ISO 13485. This system ensures consistent quality control throughout the device's lifecycle. Clinical Evaluation: Conduct clinical evaluations to assess the safety and performance of your medical device. This involves gathering and analyzing clinical data to show its effectiveness. Labeling and Documentation: Ensure that labeling, instructions for use, and all accompanying documentation are clear, accurate, and compliant with regulatory requirements. This information is crucial for end-users. User Training: Provide training to end-users and healthcare professionals on the proper use and maintenance of the device. This can help prevent misuse and potential safety issues. Risk Management: Implement a comprehensive risk management process to identify, assess, and mitigate potential risks associated with your medical device. This is critical for patient safety. Post-Market Surveillance: Establish a system for monitoring the device's performance and collecting user feedback. This information can make improvements and address any issues. Compliance Testing: Conduct testing and verification to ensure your device meets all relevant safety and performance standards. This may include electrical safety, electromagnetic compatibility, and biocompatibility testing. Regulatory Submission: Prepare and submit a regulatory dossier to the appropriate regulatory agency. This submission should include all necessary documentation and data to support the safety and efficacy of your device. Maintain Vigilance: Stay informed about updates and changes in regulatory requirements. Continuously assess and improve your device's compliance to ensure long-term success in the home healthcare market. Conclusion Medical device compliance in home healthcare settings is a multifaceted process that demands careful planning, adherence to regulatory standards, and an unwavering commitment to patient safety. As the home healthcare industry grows, the need for compliant medical devices will only increase. By following the steps outlined in this blog and staying vigilant in your commitment to compliance, you can contribute to the well-being of patients and the success of your home healthcare device in the market. Compliance isn't just a legal requirement; it's a fundamental aspect of providing safe and effective healthcare at home.
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