WEBVTT
Kind: captions
Language: en

00:00:06.970 --> 00:00:17.900
Friends, again welcome to Regulatory Requirement
for Medical Devices and In Vitro Diagnostics

00:00:17.900 --> 00:00:26.079
in India lecture 4 that is Type of Medical
Devices including combination devices. In

00:00:26.079 --> 00:00:34.360
this lecture before we further continue I
want to brief you. In the previous lecture

00:00:34.360 --> 00:00:40.830
we have discussed what what is the regulation
for the medical devices? What type of medical

00:00:40.830 --> 00:00:45.840
devices are under regulation? It is not the
all the type of medical devices are presently

00:00:45.840 --> 00:00:52.740
under regulation in India.
So, only certain medical devices which falls

00:00:52.740 --> 00:00:58.900
under the definition of section 3 b i, section
3 b ii and section 3 b iv. Section 3 b iv

00:00:58.900 --> 00:01:06.790
that is the notified medical devices and we
have also understand how many devices, how

00:01:06.790 --> 00:01:11.170
many categories of the devices. So, far the
Ministry of Health and Family Welfare has

00:01:11.170 --> 00:01:17.510
been notified. And what are the new medical
devices which have been notified recently

00:01:17.510 --> 00:01:24.080
by the Ministry of Health and Family Welfare.
So, we understand how many devices total notified

00:01:24.080 --> 00:01:30.120
to which are under regulation? Also we discussed
in detail classification classification of

00:01:30.120 --> 00:01:35.590
the devices. The classification of the devices
that criteria has already been in prescribing

00:01:35.590 --> 00:01:42.990
the first schedule of the medical device till
in 2017. And in that classification, the classification

00:01:42.990 --> 00:01:49.120
is made based on the intended use of the medical
devices as well as the risk associated with

00:01:49.120 --> 00:01:54.119
the medical devices.
So, based on the risk and their intended use

00:01:54.119 --> 00:02:02.520
the devices is classified and risk based classification,
criteria, parameter have already been given

00:02:02.520 --> 00:02:08.950
based on that the Central Licensing Authority
has classified various medical devices under

00:02:08.950 --> 00:02:25.090
the category of regulated medical devices.
In general, the medical devices can be active

00:02:25.090 --> 00:02:38.091
or statics. The static devices are the simplest
devices having few or no moving parts. Example

00:02:38.091 --> 00:02:52.209
of the static devices are cardiac stent it
holds the tree open by virtue of their shape.

00:02:52.209 --> 00:02:58.040
The active devices are more complex. Some
active medical devices operates throughout

00:02:58.040 --> 00:03:05.110
the application of human movement or by the
effect of the gravity. The example a syringes

00:03:05.110 --> 00:03:12.470
which is a powered by the force applied by
the patient or the medical professionals.

00:03:12.470 --> 00:03:25.930
While an in in while an IV drip is powered
by the gravity. Other devices can be activated

00:03:25.930 --> 00:03:37.700
by a patient's natural body movements, such
as walking or breathing. The active implantable

00:03:37.700 --> 00:03:45.489
medical devices are powered devices that are
inserted into the patient's body, through

00:03:45.489 --> 00:03:53.500
either a natural orifice or by surgical means,
and are intended to remain in the patient's

00:03:53.500 --> 00:04:04.081
body after the procedure. Such devices usually
operated usually poweredby the battery it

00:04:04.081 --> 00:04:12.420
is a battery powered. Example like pacemakers
is one of the example for active implantable

00:04:12.420 --> 00:04:19.769
medical devices.
Non invasive devices are those devices that

00:04:19.769 --> 00:04:28.180
do not involve a break in the skin. There
is no contact with the mucous membrane or

00:04:28.180 --> 00:04:36.520
internal body cavity other than through a
natural or artificial body orifice. The example

00:04:36.520 --> 00:04:50.610
of non invasive medical devices are the BP
apparatus, CT scan, ECG, MRI etcetera. The

00:04:50.610 --> 00:05:02.310
combination medical devices, combination medical
devices is a devices that involve a medical

00:05:02.310 --> 00:05:12.680
devices and or a drugs and or a biologics,
combining any two of these product categories,

00:05:12.680 --> 00:05:25.130
and sometimes even all the three.
These types of the devices will be consider

00:05:25.130 --> 00:05:33.440
as a combination medical devices. The example
of the combination medical devices that is

00:05:33.440 --> 00:05:40.350
one of the example is drug eluting stent,
where is a scaffold coated with the drugs

00:05:40.350 --> 00:05:48.320
to prevent the scar tissue from growing in
an artery. Although in the medical device

00:05:48.320 --> 00:06:00.380
rule the combination devices have not been
clearly defined, but in general the devices

00:06:00.380 --> 00:06:15.170
like drug eluting stent. Wherein the drug
is coated with the stent platform, stent platform

00:06:15.170 --> 00:06:24.280
that is meant for stainless steel or cobalt
chromium will be example of the combination

00:06:24.280 --> 00:06:33.300
medical devices.
In other regulatory systems like USFDA they

00:06:33.300 --> 00:06:42.150
have to define the types of the combination
product. And what types of the combination

00:06:42.150 --> 00:06:52.180
devices are there they have categorized. Some
of the example like convenience kit or co

00:06:52.180 --> 00:06:58.550
package where in drug and devices are provided
as individual constituent part within the

00:06:58.550 --> 00:07:06.680
same package. The prefilled drug delivery
devices or system where in drug is filled

00:07:06.680 --> 00:07:14.440
into or otherwise combined with the device
and the sole purpose of this device is to

00:07:14.440 --> 00:07:21.910
deliver the drugs.
Prefilled drug syringes, transdermal systems

00:07:21.910 --> 00:07:34.940
the example of such devices. The devices coated
impregnated otherwise combined with the drugs.

00:07:34.940 --> 00:07:43.090
The device as an additional functions in addition
to the delivering the drugs. Example of such

00:07:43.090 --> 00:07:52.520
combination devices are the drug eluting stent,
condom with spermicide, antimicrobial coating

00:07:52.520 --> 00:08:03.830
catheters, sutures, bone cements with that
antibiotics. The possible combination based

00:08:03.830 --> 00:08:10.090
on cross labelled of separate products. That
is dug biological products under development

00:08:10.090 --> 00:08:19.539
utilize a devices, but unclear whether the
final product will require that the two be

00:08:19.539 --> 00:08:25.760
cross labelled.
Other type of combination products where in

00:08:25.760 --> 00:08:38.130
drug, device and biological product. Combination
product or not otherwise describes all the

00:08:38.130 --> 00:08:45.550
three articles are combined in a single product.
The example are the prefilled syringes containing

00:08:45.550 --> 00:08:52.730
an antibody drug conjugates So, these are
the various types of the combination devices

00:08:52.730 --> 00:09:04.019
though other reliability authority have defined
were but in and in the medical device around

00:09:04.019 --> 00:09:13.130
2017 this combination device has not been
defined. Although the medical device rule

00:09:13.130 --> 00:09:21.889
2017 includes certain definitions of active
diagnostic medical devices, active medical

00:09:21.889 --> 00:09:37.480
devices, active therapeutic medical devices.
So, in the definition of the chapter 1 these

00:09:37.480 --> 00:09:41.339
devices has been clearly defined.

00:09:41.339 --> 00:09:50.149
The active diagnostic medical devices define
the medical device rule 2017; that means,

00:09:50.149 --> 00:09:58.459
any active medical devices used whether alone
or in combination with other medical devices,

00:09:58.459 --> 00:10:05.959
to supply information for detecting, diagnosis
or monitoring, or to provide support in the

00:10:05.959 --> 00:10:16.220
treatment of any physiological conditions,
state of health, illness or congenital deformity.

00:10:16.220 --> 00:10:25.610
The example in the hepatitis or HIV tests,
clinical chemistry, coagulation test systems,

00:10:25.610 --> 00:10:36.279
urine test strip test. Another definition
for the active medical devices have been included

00:10:36.279 --> 00:10:43.439
in the medical device rule.
Active medical devices means a devices, the

00:10:43.439 --> 00:10:49.989
operation of which depends on the source of
electrical energy or any other source of energy

00:10:49.989 --> 00:10:59.540
other than the energy generated by human or
animal body or gravity. The example of this

00:10:59.540 --> 00:11:06.649
type of active medical devices are cardiac
pacemakers, defibrillators, cochlear implants

00:11:06.649 --> 00:11:14.730
also in the medical device rule 2017.
Active therapeutic medical devices has been

00:11:14.730 --> 00:11:22.060
defined which prescribe that. Active therapeutic
medical devices means any active medical devices

00:11:22.060 --> 00:11:31.989
used either alone or in combination with any
other medical devices to support modify, replace

00:11:31.989 --> 00:11:39.699
or restore biological function or a structure
with a view to the treatment or alleviation

00:11:39.699 --> 00:11:51.009
of any illness, injury or handicap.
Example of such type of medical devices or

00:11:51.009 --> 00:11:59.129
incentive care monitoring system blood gas
analyser used in the open heart surgery. But

00:11:59.129 --> 00:12:05.939
in the medical device rule only the definition
has been defined, but the medical devices

00:12:05.939 --> 00:12:12.350
based on the category notified by the Ministry
of Health and Family Welfare Government of

00:12:12.350 --> 00:12:21.269
India. The products are classified based on
the risk and the parameter as prescribed in

00:12:21.269 --> 00:12:30.189
medical first schedule of medical device rule
2017.

00:12:30.189 --> 00:12:37.730
Also the medical device rule 2017 includes
definition of invasive medical devices, which

00:12:37.730 --> 00:12:45.230
state that invasive devices means a devices
which in whole or part penetrates inside the

00:12:45.230 --> 00:12:53.769
body either through a body orifice or throughout
the surface of the body. Example of this type

00:12:53.769 --> 00:13:03.619
of invasive devices are sutures, hypodermic
needles and syringes. Active implantable medical

00:13:03.619 --> 00:13:08.769
devices also defined in the medical device
rule 2017 active medical devices which is

00:13:08.769 --> 00:13:18.489
intended to be totally or partially introduced,
surgically or medically, into the human body

00:13:18.489 --> 00:13:27.649
or animal body or by the medical intervention
into a natural orifice and which is intended

00:13:27.649 --> 00:13:34.139
to remain after the procedure. Active implantable
medical devices examples are cardiac pacemaker

00:13:34.139 --> 00:13:39.670
and defibrillators people discuss in the previous
slides.

00:13:39.670 --> 00:13:47.160
Active medical devices also defined in the
medical device rule in 2017 which state that

00:13:47.160 --> 00:13:53.480
medical devices, relying for its functioning
on a source of electrical energy or any source

00:13:53.480 --> 00:14:03.339
of power other than that directly generated
by human or animal body or gravity.

00:14:03.339 --> 00:14:10.140
Also then medical device rule 2017 define
implantable medical devices which means, it

00:14:10.140 --> 00:14:19.529
is intended for the medical devices intended
for to be totally or partially introduced

00:14:19.529 --> 00:14:30.410
into the human or animal body or a natural
orifice or to replace an epithelial surface,

00:14:30.410 --> 00:14:38.319
or the surface of the eye by surgical intervention,
and which is intended to remain after the

00:14:38.319 --> 00:14:48.129
procedure for a at least thirty days, and
which can only be removed by the medical or

00:14:48.129 --> 00:14:53.350
surgical intervention.
What type of devices are regulated under which

00:14:53.350 --> 00:14:59.819
category and what will be the classification
of the that medical devices? So, concentrate

00:14:59.819 --> 00:15:07.509
on the lecture which will be given again by
Mister Malay Mitra former the deputy drug

00:15:07.509 --> 00:15:13.319
controller. He will explain all those thing
and concentrate on the lecture and also enjoy

00:15:13.319 --> 00:15:26.299
the lecture thank you very much.
Hi, today we will talk about different types

00:15:26.299 --> 00:15:32.850
of medical devices including combination devices.
We whenever we go to the market or we decide

00:15:32.850 --> 00:15:37.350
to select a medical device to manufacture
or design we find that there are hundreds

00:15:37.350 --> 00:15:43.439
of hundreds of different types of medical
devices available in the market. Andwe are

00:15:43.439 --> 00:15:49.540
we are actually confused as to what kind of
medical device that is whether its combination

00:15:49.540 --> 00:15:54.769
device, it is a single use device or how do
you go about it. So, this short presentation

00:15:54.769 --> 00:16:00.089
will give you a general idea of the types
of medical devices moving in the market including

00:16:00.089 --> 00:16:05.769
combination devices.
A device you must understandthe definition

00:16:05.769 --> 00:16:12.509
of a device actually to get into focus of
combination devices. What is the device? The

00:16:12.509 --> 00:16:16.550
device according to the definition can be
anything from as simple as a walking stick

00:16:16.550 --> 00:16:22.570
to an ultrasound machine. So, you can understand
the huge range a medical device has got. It

00:16:22.570 --> 00:16:29.119
can be a simple device it can be very very
complicated device which is not a accessible

00:16:29.119 --> 00:16:31.470
and usable for a common man.

00:16:31.470 --> 00:16:36.160
However, regulations and controls apply to
devices which are notified in the Gazette

00:16:36.160 --> 00:16:42.489
of India. The regulations applied to manufacture
sale and import of for obvious reasons. In

00:16:42.489 --> 00:16:48.379
India the devices which are controlled are
actually notified in the Gazette of India

00:16:48.379 --> 00:16:57.049
and the whole range of a manufacture, testing,sale
etcetera are controlled under the government.

00:16:57.049 --> 00:17:04.030
And there are 15 types of devices and about
3 or 4 more devices are going to be incorporated

00:17:04.030 --> 00:17:16.649
from2020 and these 15 devices which areactual
medical devices are controlled under the law.

00:17:16.649 --> 00:17:20.110
And this also includes 4 in vitro medical
devices.

00:17:20.110 --> 00:17:25.240
In vitro medical devices the road medical
devices in which are used outside the human

00:17:25.240 --> 00:17:33.440
body for detecting orfinding out a disease
in the human body and these 4 in vitro medical

00:17:33.440 --> 00:17:38.130
devices are basically used for testing of
human blood.

00:17:38.130 --> 00:17:43.130
Let us check the definition of device again
as per the Drug and Cosmetics Act, in 1940.

00:17:43.130 --> 00:17:49.100
This will be useful because we must remember
that as long as we deal with anything concerning

00:17:49.100 --> 00:17:54.009
the control substandard under the Drug and
Cosmetics Act we should keep the definition

00:17:54.009 --> 00:18:00.690
in mind always. This will give a perspective
to the product that we are dealing with. In

00:18:00.690 --> 00:18:09.510
part b drug includes all medicines for internal
or external use of human beings and animals

00:18:09.510 --> 00:18:14.559
and all substances intended to be used for
or in the diagnosis, treatment, mitigation

00:18:14.559 --> 00:18:19.880
or prevention of any disease or disorder in
human beings or animals, including preparation

00:18:19.880 --> 00:18:24.790
applied on human body for the purpose of repelling
insects like mosquitoes.

00:18:24.790 --> 00:18:32.380
This particular definition is actually completely
applied on drugs. Medicines which we call

00:18:32.380 --> 00:18:39.480
them tablet, liquid, capsules etcetera. The
part 2 of of the definition say such substances

00:18:39.480 --> 00:18:46.210
other than food intended to affect the structure
or function of the human body or intended

00:18:46.210 --> 00:18:51.960
to be used in the destruction of vermin or
insect which cause disease in human beings

00:18:51.960 --> 00:18:57.130
or animals or as may be specified from time
to time by central government by notification

00:18:57.130 --> 00:19:02.240
in the official gazette.
So, in this case the part mark red that is

00:19:02.240 --> 00:19:09.050
intended to affect the structure of function
of the human body. Actually refers to a device

00:19:09.050 --> 00:19:13.940
in a way, if you see the function of a device
they are there is sometime affect the structure

00:19:13.940 --> 00:19:18.970
of function of the human body. All substances
the next parts is all substances integrated

00:19:18.970 --> 00:19:23.940
for use of the components of a drug including
empty gelatine capsules etcetera this is also

00:19:23.940 --> 00:19:29.730
applicable to drugs pure drugs.
Forth one is such devices intended for internal

00:19:29.730 --> 00:19:34.760
or external use in diagnosis, treatment, mitigation
or prevention of diseases or disorder in human

00:19:34.760 --> 00:19:39.880
beings or animals, as may be specified from
time to time by the central government by

00:19:39.880 --> 00:19:43.270
notification in the official gazette, after
consultation with the board. This portion

00:19:43.270 --> 00:19:51.460
is completely on medical devices as we know
it. This definition per se is not a comprehensive

00:19:51.460 --> 00:19:56.899
definition of a medical device, but this particular
portion actually refers to medical devices

00:19:56.899 --> 00:20:00.809
that we actually know.
Now, this is actually the gazette replica

00:20:00.809 --> 00:20:05.500
of the gazette which actually just for the
information to tell you that this is what

00:20:05.500 --> 00:20:14.960
a gazette looks like. The medical in the medical
device regulations which came out in 2017

00:20:14.960 --> 00:20:23.570
the 17 regulation there are definitions again
given for medical devices. These are a bit

00:20:23.570 --> 00:20:32.360
more comprehensive to and there are definitions
also which givea focus on the medical device

00:20:32.360 --> 00:20:37.909
as they exist.
It says medical device means rule 3 definition

00:20:37.909 --> 00:20:45.710
ZB medical device means, substances used for
in vitro diagnosis and surgical dressings,

00:20:45.710 --> 00:20:49.919
surgical bandages, surgical staples, surgical
sutures, surgical ligatures, blood and blood

00:20:49.919 --> 00:20:56.410
components, collection bag with or without
anticoagulant covered under sub clause i.

00:20:56.410 --> 00:21:02.539
Now, let us let us look at this one very carefully
substance used in in vitro diagnosis and surgical

00:21:02.539 --> 00:21:12.389
dressing, surgical bandage, surgical staples.
It says surgical dressings and surgical bandages

00:21:12.389 --> 00:21:19.300
we must remember one thing these two items
were also covered in the Indian pharmacopoeia

00:21:19.300 --> 00:21:25.129
as drugs earlier. Now this has been brought
clearly under the medical device definition.

00:21:25.129 --> 00:21:33.639
Similarly, blood collection bag earlier was
not a device, but this has been brought under

00:21:33.639 --> 00:21:39.039
a device. Earlier it was just a container
for collection of whole human blood or components

00:21:39.039 --> 00:21:45.179
orwith a coagulant or an empty bag. These
were not medical devices earlier, but this

00:21:45.179 --> 00:21:49.419
has been clearly covered under the medical
device definition now.

00:21:49.419 --> 00:21:57.330
B says substances including mechanical contraceptives
condoms, intrauterine, tuber rings and disinfectant

00:21:57.330 --> 00:22:03.539
these four items were earlier covered under
the definition of drug and are controlled

00:22:03.539 --> 00:22:09.140
as drug under the Drug and Cosmetics Act.
This is very clearly brought under the medical

00:22:09.140 --> 00:22:16.100
devices by the new regulations. Devices notified
from time to time under sub clause 4 sub of

00:22:16.100 --> 00:22:24.870
clause b of the section 3 of the act. Now
this this particular definition c is is the

00:22:24.870 --> 00:22:31.549
is the defining definition which enables the
government of India to notify medical devices

00:22:31.549 --> 00:22:36.279
as an when required.
So, as I discussed earlier there are 15 medical

00:22:36.279 --> 00:22:41.230
devices covered under the act they have notified
under this section. Explanation for these

00:22:41.230 --> 00:22:46.149
rules substances used for in vitro diagnostic
shall be referred to as in vitro diagnostic

00:22:46.149 --> 00:22:52.990
medical device. So, medical device when it
is in vitro which is which is basically a

00:22:52.990 --> 00:22:59.750
chemical entity or a biological entity for
testing of humanbody outside the human body

00:22:59.750 --> 00:23:04.940
are in vitro medical devices they are also
medical devices, but known as in vitro medical

00:23:04.940 --> 00:23:10.279
devices.
It is therefore, apparent that devices constitute

00:23:10.279 --> 00:23:15.350
a huge variety of items, devices can be as
simple as a walking strip to a compressor

00:23:15.350 --> 00:23:20.639
items that the MRI is software even software
used for analyzing data is a medical device.

00:23:20.639 --> 00:23:26.100
So, if you have got a MRI machine having a
software installed in it and a computer system

00:23:26.100 --> 00:23:32.870
attached to it they are all part of a medical
device. Due to late entry of into the regulatory

00:23:32.870 --> 00:23:37.500
framework, general awareness amongst professionals
in the country is low. This is this is a fact

00:23:37.500 --> 00:23:44.710
thatthe definition of medical device amongst
professionals and a common people are very

00:23:44.710 --> 00:23:48.690
very low.s
Because it has not been invoke legally in

00:23:48.690 --> 00:23:56.210
our country all these years. There has been
some sort of control, but not regular comprehensive

00:23:56.210 --> 00:24:04.090
control. This is been rectified by the government
as an ongoing process by law. What is now

00:24:04.090 --> 00:24:10.549
we come back to combination device. The medical
device regulations in our country, as on they

00:24:10.549 --> 00:24:16.419
do not to defined combination devices, but
it is essential that we know about it.

00:24:16.419 --> 00:24:24.970
USFDA however, has an effective and useful
regulation in CFR 3.2 e which is reproduced.

00:24:24.970 --> 00:24:34.789
It says a product comprised of two or more
regulated component that is drug or device

00:24:34.789 --> 00:24:42.720
or biologic a device, drug or biologic or
drug device biology. That are physically chemically

00:24:42.720 --> 00:24:48.899
or otherwise combined or mixed and produced
as a single entity. That means, a drug or

00:24:48.899 --> 00:24:56.240
a device a biological substance or a device
a drug and a biological substance and a drug

00:24:56.240 --> 00:25:02.070
a biological substance and a medical device.
If they combined together constitute a medical

00:25:02.070 --> 00:25:07.749
devicecombination device. Two or more separate
products package together in a single package

00:25:07.749 --> 00:25:13.070
or a unit and comprised of a drug and device
products device and biological products or

00:25:13.070 --> 00:25:19.950
biological entire product. That is a packaged
kit is also a combination device as for the

00:25:19.950 --> 00:25:26.100
USFDA definitions.
This is not available in ourdefinitions; however,

00:25:26.100 --> 00:25:32.920
there are aspects in the regulations which
covers this separately. A drug or device or

00:25:32.920 --> 00:25:37.049
a biological product packaged separately that
according to its investigational plan or proposed

00:25:37.049 --> 00:25:43.240
labelling is intended for use only with an
approved indigenous specified drug, device

00:25:43.240 --> 00:25:47.809
or biological product where both are required
to to achieve the intended use indication

00:25:47.809 --> 00:25:53.519
of effect. And where upon approval of the
proposed product the labelling of the approved

00:25:53.519 --> 00:25:58.149
product would need to be changed that is reflected
change in the intended use those just form

00:25:58.149 --> 00:26:02.639
strength router registration on significant
change in those.

00:26:02.639 --> 00:26:08.990
This is also a medical device. That means,
we packet separately drug, device or biological

00:26:08.990 --> 00:26:16.570
product which are packed separately and intended
for use with an approved individually specified

00:26:16.570 --> 00:26:24.389
drug for biological product is also a combination
device. You cannot use it without a individual

00:26:24.389 --> 00:26:28.240
product which is required to be used with
that device.

00:26:28.240 --> 00:26:33.779
Now, some of the question and answers about
the are over here with the simple one; however,

00:26:33.779 --> 00:26:40.059
you will be getting much more question and
answers we have to submit later on for assessment.

00:26:40.059 --> 00:26:52.960
So, that is over all.
Thank you very much.

