Post-market surveillance (PMS) is a system that provides continuous feedback on the performance of medical devices on the market, ensuring a high standard of product quality. It is an essential part of regulatory requirements, and the Medical Device Regulation (EU MDR) and IVDR post market surveillance place significant importance on collecting clinical and safety-related data after the approval/CE certification process and market access. The data gathered from medical device post market surveillance serves as critical input for updating technical documents such as clinical evaluation, Risk analysis, usability, etc.
Manufacturers of MD and IVD devices must implement a robust system to gather and review experience from their devices in the post-production phase. Notified Bodies (NB) are responsible for auditing and verifying the effectiveness of the PMS post marketing surveillance system. Such medical device post market surveillance systems are an essential part of a manufacturer’s quality assurance framework. In most cases, these systems already exist to fulfill internal company requirements, function as an integrated part of a manufacturer’s quality system, and comply with third-party regulations. Even in the absence of an approved quality system, manufacturers are still required to maintain an effective post-market surveillance (PMS) system.
Post-market surveillance is an integral part of the requirements laid out by ISO 13485 as well as the EU MDR post-market surveillance guidelines. Post-market surveillance not only ensures ongoing compliance but also helps in identifying new opportunities for improvement related to the medical device, in accordance with ISO 13485. Additionally, it provides valuable input into the design and development change processes, as stipulated by ISO 13485.
The MDR post-market surveillance should be a key component of the company’s Quality Management System (ISO 13485), ensuring continuous monitoring of the device's performance and safety. By analyzing the data on quality, performance, and safety throughout the device’s lifecycle, post-market surveillance enables proactive decision-making. A post-market surveillance report for medical devices is essential for tracking the effectiveness of corrective actions and addressing any identified risks, ensuring the device remains safe and effective in the market.
ISO 13485-QMS | ISO TR 20416-PMS |
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Relationship between ISO 13485 and Post-market surveillance (PMS)
A Post Market Surveillance (PMS) Plan is a documented strategy of the proactive process for the collection of any required information to evaluate the safety and performance of the medical device released in the market.
The PMS plan contains the requirements of Article 84 & Annex III of EU-MDR to be followed for the collection of data, which is directly proportional to the risk associated with the intended use of the medical device.
The EU MDR post market surveillance plan shall address the collection and utilization of available information, in particular:
Additionally, for IVDR post market surveillance, manufacturers must ensure compliance with regulations applicable to in vitro diagnostic devices, ensuring all relevant data is gathered and assessed for performance and safety.
The MDR post market surveillance is designed to ensure continuous monitoring of medical devices after they have been placed on the market, helping to maintain safety standards throughout the device lifecycle.
A proactive and appropriate process to collect any information shall allow a correct characterization of the performance and safety of the devices and enable a comparison to be made between the device and similar or equivalent products available on the market. This is a critical aspect of medical device post-market surveillance (PMS), which ensures ongoing safety and effectiveness.
Methods and protocols to manage the events subject to the trend report for medical devices, including the methods and protocols to be used to establish any statistically significant increase in the frequency of incidents that are not serious or expected undesirable side-effects, which could have a significant impact on the benefit-risk analysis as well as the observation period.