national health regulatory authority (nhra) kingdom of bahrain · 2019. 2. 3. · e-mail:...
TRANSCRIPT
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
1
Combined Medical Device Importation Guideline
(Manual Approval)
National Health Regulatory Authority (NHRA)
Kingdom Of Bahrain
Oct 2018
Version 1.0
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
2
Contents
1. Definition ............................................................................................................... 3
2. Introduction .......................................................................................................... 3
3. General Rules ....................................................................................................... 4
4. Classification ......................................................................................................... 5
5. Process ................................................................................................................... 6
6. Requirements ........................................................................................................ 6
7. Glossary ................................................................................................................. 9
8. Annex ...................................................................................................................11
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
3
1. Definition
Combined medical device: Term used in the kingdom of Bahrain to
differentiate between Medical devices with Pharma HS code that requires
manual approval and Active Medical devices HS code. Most of these device are
mixed with pharmaceutical or chemical materials and does not achieve their
action by pharmacological, immunological or metabolic means, used for
prevention of illness. It also covers IVD with pharmaceutical or biological
materials.
IVD (In-Vitro Diagnostic): any Medical Device which is a reagent, reagent
product, calibrator, control material, kit, instrument apparatus, equipment, or
system, whether used alone or in combination, intended by the manufacturer to
be used in vitro for the examination of specimens, including blood and tissue
donations, derived from the human body, solely or principally for the purpose
of providing information:
• concerning a physiological or pathological state, or
• concerning a congenital abnormality, or
• to determine the safety and compatibility with potential recipients, or
• To monitor therapeutic measures.
2. Introduction
This guideline is intended to guide all importers through the process of getting combined
medical device (CMD) importation approval. In order to help planning the importation of
CMD all importers should follow this guideline before placing any order or even
marketing the device in Bahrain market.
The requirements and the process required by NHRA to grant a preapproval for CMD is
highlighted in this guideline whereas, Compliance with international standards of quality
and safety of the devices is one of the main elements to importation pre-approval.
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
4
3. General Rules
1. Pre-approval is required before importation and NHRA regulates the
importation of Medical devices
2. NHRA Regulates the importation of medical devices Class II and III only
3. All Importers should market Medical devices to Healthcare Facilities licensed
by NHRA
4. Importation of Combined medical devices must be done through authorized
representative from the legal manufacturer
5. If the product in the submitted request is registered as a medical device in Saudi
food and drug and has a valid SFDA (Medical Device Marketing authorization)
then it can be replaced for QAC & QMC and the request will be approved directly.
6. One of the following 15 reference countries should classify the product as a medical
device (Saudi Arabia, America, Australia, Canada, Japan, New Zealand,
Switzerland, United Kingdom, France, Ireland, Netherlands, Denmark, and
Belgium).
7. If the product classification is class I, Non sterile and made in one of the
European Countries then a Declaration of conformity document from the
manufacturer should be submitted with the request and can be replaced for QAC
& QMC.
8. Shipments imported for researches and will not be used on patients, will be
approved with only a Declaration of conformity with international quality and
safety standards issued by the manufacturer; if the LPO from the university is
provided
9. NHRA registered CMD importation pre-approval is done by providing only the
invoice with the product registration certificate.
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
5
10. In case of importing Cold chain products, i.e. (2-8 ℃), the temperature data logger
must be provided to NHRA to ensure good storage conditions; from the port of
shipping “the manufacturer”, to Bahrain ports. Conditional Preapproval will be
granted before the shipment arrives, given that the importer does not distribute the
devices until NHRA approves the data logger after the shipment arrives.
11. There are two types of combined medical devices approval:
1. Approval to sell combined medical devices to only healthcare professional
(ex: Filler).
2. Approval to sell combined medical devices with prescription (ex:
injectable hyaluronic acid for joints).
4. Classification
The criteria of Medical devices classification are as below, where product must be in
compliance with all criteria in order to classify the product as medical device:
1-Product is classified in country of origin as medical devices.
2- One of the reference countries classify the product as a Medical device
3-The product is FDA approved or CE marked.
4-Product medical claim falls under the definition of medical device.
5-Product principle intended action is physical or mechanical.
• All Combined Medical devices registered before April 2016 will be reviewed once are
tended to be renewed to match with the new classification requirement
• All registered combined medical devices that were classified by the product
classification team members, can be renewed without reclassification.
For further guidance on classification for the devices that does not fulfill the above
mentioned criteria, please refer to the classification guideline of medical devices on the
NHRA website.
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
6
5. Process
Submission of combined medical device requests is done manually, applicant should
send an email to “[email protected]” to fix an appointment for submitting the
required documents.
Once the appointment is set the documents will be reviewed and assessed at the same
time.
In case there are missing documents the documents will be given back to the applicant
in order to fulfill the requirement.
If the documents are fulfill then the applicant will be contacted within maximum one
week to collect the approval which in this case will be granted manually (NHRA
stamp and signature) on the submitted invoice with the submitted documents.
6. Requirements
All Importers should submit the following required documents manually to get the
importation permit for combined medical devices:
Product should be classified in country of origin as medical devices. this
Document should be from the Regulatory Authority in the Country of origin to the
legal manufacturer, excluding Lab reagents
One of the 15 reference countries classifies the product as a medical device.
Document should be from a Regulatory Authority.
Invoice with clear item description including HS Code/ Manufacturer Name &
Country of Origin.
Importer valid commercial record (CR).
Authorization letter from the legal manufacturer to the authorized representative to
market the device in the kingdom of Bahrain.
Country of Origin Certificate / Free Sale Certificate.
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
7
(GMP) certificates from the Regulatory Authority in the Country of origin to the
legal manufacturer OR Quality management’s system certificates (example: ISO
13485) from a recognized certifying body.
Quality assurance Certificates (example: FDA, CE Mark, ISO 13485) from a
recognized certifying body along with a verification of its validity from the issuer.
Product intended use /Product Art work.
Device Classification based on level of Risk. (I, II, III…).
Product GMDNS* / UMDNS* Code Description
*Global Medical Device Nomenclature System.* Universal Medical Device
Nomenclature System.
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
8
The process of Combined Medical Device Manual Approval can be simplified in the
following flowchart:
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
9
7. Glossary
No. Terminology Definition
1
Manufacturer
Means any natural or legal person with
responsibility for design and manufacture of a
medical device with the intention of making it
available for use, under his name; whether or not
such a medical device is designed and/or
manufactured by that person himself or on his
behalf by another person.
2
Importer
Means any natural or legal person in the supply
chain who is the first to make medical device,
manufactured in another jurisdiction, available in
Bahrain.
3
Authorized Representative
The authorized agent from the manufacturer
through an authorization letter stating that it is the
exclusive distributer in the Kingdom of Bahrain
for marketing the imported medical devices.
4
HS code
The Harmonized Commodity Description and
Coding System generally referred to as
"Harmonized System" or simply "HS" is a
multipurpose international product nomenclature
developed by the World Customs Organization
(WCO).
The Harmonized Commodity Description and
Coding System (HS) is broad and is not structured
for medical devices field.
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
10
No. Terminology Definition
5
SFDA
Saudi Food and Drug Authority, which
regulates, oversee, and control food, drug,
medical devices, as well as to set mandatory
standard specifications thereof, whether they are
imported or locally manufactured.
6
ISO 13485
International Organization for
Standardization Quality management systems
required for regulatory purposes is an (ISO)
standard published for the first time in 1996; it
represents the requirements for a
comprehensive quality management system for
the design and manufacture of medical devices.
7
CE mark
Conformity European which literately means
“European Conformity”. The term initially used
was “EC Mark” and it was officially replaced
by “CE Marking” in the Directive 93/68/EEC in
1993, declaring that the product complies with
the essential requirements of the relevant
European health, safety and environmental
protection legislations.
8
FDA
Food and Drug Administration , it is a federal
agency of the United States Department of
Health and Human Services, one of the United
States federal executive departments. The FDA
is responsible for protecting and
promoting public health through the control and
supervision of food safety, tobacco, dietary
supplements, prescription and over-the-
counter pharmaceutical drugs
(medications), vaccines, biopharmaceuticals, blo
od transfusions, medical
devices, electromagnetic radiation emitting
devices (ERED), cosmetics, animal foods &
feed[4] and veterinary products.
9
Quality Assurance Certificate Verification
Means to check the validity of the quality
assurance certificate by contacting the certifying
body either by sending an email or online
through the website of the certifying body.
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
11
No. Terminology Definition
10
Certifying Body
The role of the certified Body is to conduct a
conformity assessment under the relevant EU
Directives. The conformity assessment usually
involves an audit of the manufacturer’s quality
system and depending upon the particular
classification of the device, a review of the
relevant technical documentation provided by the
manufacturer in support of the safety and
performance claims for the device.
Once the Certified Body has determined a
manufacturer has conformed to the relevant
assessment criteria, it issues a certificate to show
that the products assessed meet the requirements.
8. Annex
Please visit NHRA website for Combined Medical Device Checklist.
www.nhra.bh
E-Mail: [email protected] Website: www.nhra.bh Tel.: 17113299 /P.O. Box: 11464
12