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Reportable incidents

Reportable incidents

Economic operators in medical technology are subject to regulatory reporting and notification obligations, which must be fulfilled by institutional bodies at European and national level. This includes manufacturers, importers, and EU authorised representatives (also EC-REP / EAR). 

Reportable includes:

  1. (Serious) incidents
  2. Product recalls
  3. EUDAMED database

1. (Serious) incidents according to Article 2 paragraph 64 & 65

In the event of a malfunction, deterioration of the characteristics or performance of a medical device already placed on the market, including ergonomic handling errors, undesirable side effects as well as inadequacies in the information provided by the manufacturer, the MDR refers to an "incident".

If such an incident leads to, has led to or could lead to (the suspicion or suspected causal link between the product and the incident is already sufficient here) that:

  • the death of a patient, user or third party occurs, or their state of health temporarily or permanently seriously deteriorates,
  • there is a serious risk to public health,

then the MDR speaks of a "serious incident". Article 87 of the MDR sets out corresponding notification deadlines to the relevant competent authorities, for example the Federal Institute for Drugs and Medical Devices (BfArM) in Germany.

 

Type of incident

Reporting deadline

Comment

Serious incident

Immediately, maximum after 15 days

The incident must be reported immediately after the (possible) causal link with the product has been established. In any case, however, the incident must be reported within the maximum period specified.

Serious incident in the event of the death of a patient, user or third party, or of a serious temporary or permanent deterioration in their state of health. 

Immediately, within a maximum of 10 days

Serious risk to public health

Immediately, maximum after two days

2. Recall of medical devices

It is essential to know the regulatory deadlines and to conduct and document the incidents and subsequent information processing in the organisation accordingly. This will ensure that the notification is made correctly and in a timely manner, considering the conclusions reached about the incident, in order to prevent further harm to the organisation.

If you have any queries about any of the following, please do not hesitate to contact us. NEMIUS offers comprehensive, short-term, and authoritative support in:

  • Deciding to classify an incident as an incident, such as a complaint or a user report.
  • Communication with the competent relevant authority, such as the Federal Institute for Drugs and Medical Devices (BfArM).
  • Preparation of the necessary documents, such as the Manufacturer Incident Report (MIR), for submission to the BfArM

3. EUDAMED database

The European Database on Medical Devices (EUDAMED) is a central database for the management of medical devices in the European Union. It was developed to enable the uniform and transparent collection, storage, and provision of information on medical devices. The database serves the EU-wide management of medical devices and supports various aspects, such as the registration of manufacturers and authorised representatives, the surveillance of devices, the reporting of incidents and the provision of information to the public.