An Update on the EU’s In-Vitro Diagnostic (IVD) Directive
By E. Smith Yewell
President & CEO, Welocalize
smith.yewell@welocalize.com
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New European Union legislation completing the Medical Device Directive is due to come into force at year’s end, which is bringing added challenges to product compliance in this field. This article looks at the implications of this complex Directive for the multilingual information management of product labeling in different countries and recommends relevant strategies.
New European Union legislation completing
the Medical Device Directive is due to come into force
at year’s end, which is bringing added challenges
to product compliance in this field. This article looks
at the implications of this complex Directive for the
multilingual information management of product labeling
in different countries and recommends relevant strategies.
Localizing products for international
markets is a challenging process, and it can be even
more challenging for Life Sciences companies given
the rules and regulations governing medical products.
The primary set of regulations for Life
Sciences companies to consider is the Medical Device
Directive (MDD). The first two stages of the MDD were
the Active Implantable Medical Device Directive, which
had an implementation deadline of January 1, 1995
and the Medical Device Directive, which had an implementation
deadline of June 13, 1998. The final stage of the
MDD is the In-Vitro Diagnostics Directive (IVDD).
One of the requirements that the IVDD specifies is
that manufacturers’ comply with set language
standards regarding instructions-for-use documents
and labeling.
The IVD Directive, at its core, is purposed
to ensure the safety, quality, and performance of
In Vitro Diagnostic (IVD) products. It is extremely
important for IVD product manufacturers to understand
that after December 7, 2003, all IVD products must
be CE (Conformity European) marked or they will be
prohibited from being sold in the European Union (EU).
Any product lacking the CE Mark after the deadline
will be blocked from entry into the EU.
The IVD Directive applies to reagents
and reagent products, calibrator materials or instruments
including specimen receptacles intended by the manufacturer
for the in-vitro examination of human tissue, blood
or fluid samples for the purpose of providing information
about a patient’s state of health.
As stated earlier, compliance to the
directive includes language translation of labeling,
user instructions, or other key information into local
languages as dictated by each EU Member State. Today,
the European Union includes 15 Member States: Austria,
Belgium, Denmark, Finland, France, Germany, Greece,
Great Britain, Ireland, Italy, Luxembourg, Netherlands,
Portugal, Spain, and Sweden. It is also worth noting
that in 2004, an additional ten countries will likely
join the EU—with more to be added in 2007!
Companies are now faced with the dilemma
of providing the appropriate and required information
in a multilingual format while making the information
readable on a variety of label sizes. The use of internationally
recognized symbols as a substitute for text has been
actively promoted to provide users with a uniform
method of obtaining product information. Yet many
diagnostics companies are struggling with the issues
that surround multilingual label design and international
symbols. For example, the size of many labels will
need to increase in order to support text expansion
in the target language. “In some cases the English
text may need to be rewritten with an eye towards
brevity in order to support reduced space available
for foreign language translation,” said Welocalize
Project Manager, Deniz Gungen.
Some of the standards referenced by
the Directive include EN 980 (medical device symbols),
EN 375 (professional use labeling), EN 376 (self-testing
labeling), EN 1658 (marking of IVD instruments) and
ISO 15223 (medical device symbols). Exceptions among
the EU Member States further complicate matters, since
there are differences in how each Member State adopts
the regulation. Some countries provide exemptions
to local language requirements, while others call
for strict adherence to the Directive and may actually
require that products be in several languages. Being
informed about the national differences enables companies
to determine if participation in a particular market
is justified. (Please refer to the table below for
language requirements for a particular country.)
Welocalize also recommends the use of
specialized consultants for the more complex regulatory,
clinical and compliance issues. “As only one
example, ALQUEST Inc. is a full-service Contract Research
Organization offering regulatory, clinical and compliance
services for medical devices, biologics, and combination
products,” said Welocalize Business Development
Manager, Mitch Bossart.
CE marking IVD products for Europe is
a complex task. And there is confusion about how translation
requirements are related to the CE Mark. Simply stated,
the CE Mark is a European regulatory community sign
and symbolizes the compliance of the product with
the regulations relating to safety, public health,
consumer protection and the environment. Some of the
basic steps to achieve CE Marking are listed here.
For more detailed regulatory information on these
steps, please go to:
http://www.welocalize.com/english/industries/medical2.html
- Verify if the product in question
is an in-vitro diagnostic medical device and then
categorize the device.
- Determine what materials need to
be provided in local languages.
- Contact a Notified Body. The Notified
Body will investigate the device through a series
of questions to the manufacturer, confirm the categorization
of the device, provide a cost and time estimate
for CE marking, and choose the most suitable path
to certification.
- Apply for certification. The Notified
Body will then supply an assessment report, which
may include testing requirements, operations audits,
or other actions that the Notified Body deems appropriate
for certification of a particular product.
The IVDD was created
to establish unified compliance standards throughout
the EU to ensure the safety, quality and performance
of in vitro diagnostic medical devices. Ultimately,
this will make compliance easier and more efficient,
since compliance will be harmonized across all EU
Member States. However, it will take time and qualified
resources to achieve successful compliance.
E.
Smith Yewell is the President &
CEO of Welocalize and leads the company's Life Sciences
Localization/Translation practice. He can be reached
at 800-370-9515 or smith.yewell@welocalize.com.
Reprinted
by permission from the Globalization Insider,
29 July 2003, Volume XII, Issue 3.3.
Copyright
the Localization Industry Standards Association
(Globalization Insider: www.localization.org,
LISA: www.lisa.org)
and S.M.P. Marketing Sarl (SMP) 2004
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