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3M Infection Prevention Division Medical Textiles & Regulations Infection Prevention TECHNOTEX - 2010 Kulveen Singh Bali November 18th, 2010 © 3M 2007. All Rights Reserved. 3M Infection Prevention Division Regulations and Medical Textile / Products Need to Regulate Need to Standardize Regulations – World View Regulations – India Future 2 © 3M 2007. All Rights Reserved. 3M Infection Prevention Division Need for Regulations Need to Protect Patient An individual inflicted with a disease has a defense mechanism which is burdened / compromised and therefore susceptible to secondary infections. Need to Protect Care Giver and Healthy Individuals Diseases such as SARS and H1N1 have opened our eyes to the importance of controlling the spread of disease. 3 © 3M 2007. All Rights Reserved. 3M Infection Prevention Division Need for Regulations Medical Textiles, directly and Indirectly are used in Diagnosis, Treatment, Mitigation and Prevention of Diseases. Prevention – Masks (N95) Securals – Tapes Wound Management – Dressings Infection Prevention – Drapes, Gowns, Masks, Caps Treatment – Drug Delivery Mechanisms Implants – Grafts, Mesh, Valves & many others…. 4 © 3M 2007. All Rights Reserved. 3M Infection Prevention Division Need to Standardize Specifications Standards help users and manufacturers to comply to the requirements (implied and stated) of the product. Given the intricate nature of medical textiles, it is imperative for standards to be available which ensure Patient Safety while conforming to the intended use. 5 © 3M 2007. All Rights Reserved. 3M Infection Prevention Division Regulations – Drugs vs Medical Devices ‘Drugs’ were regulated by virtue of controlling their manufacture, testing, storage and use along with their development based on clinical trials The need for regulating ‘Medical Devices’ was necessitated by the increasing use of ‘engineered’ products with non pharmacological action. World over, Medical Devices are being increasingly regulated separately. 6 © 3M 2007. All Rights Reserved. 3M Infection Prevention Division Classification of Medical Devices – A Comparison between Economies* List based = U.S and Japan: Rule based GHTF and EU/Aus/CANADA/AHWP GHTF United States European Union [Australia/Canada/ Japan Hong Kong] Class A Class I Class I, Is (sterile), Im (measuring) Class I Miscellaneous [I] Class B 7 Class II Class IIa [II] Class II designated and non-designated Class III, IV Class C Class II Class IIb, [III] Class D Class III and Unclassified Class III, [IV] * This is not an absolute comparison as there are differences © 3M 2007. All Rights Reserved. 3M Infection Prevention Division US FDA Device Classification System List based system in CFR and on the Internet Class I – Low risk to user/patient Class II – Moderate risk to user/patient Class III – High risk to user/patient Unclassified - These device require the manufacturer to check with FDA on how to obtain market clearance 9 © 3M 2007. All Rights Reserved. 3M Infection Prevention Division History of Regulation in India Drugs & Cosmetics Act Gazette notification listing10 Devices as Drugs MOH submits CDA Bill in Parliament 1940 1989 2002 Hypodermic Syringes & Needles, Perfusion Sets 10 © 3M 2007. All Rights Reserved. 2004 MOH forms Expert Comm. to determine regulation for Med. Dev. Oct’ 2005 2006 DST submits MDRA Bill in Parliament 2007 2009 Clarification listing 14 more Devices as Drugs 3M Infection Prevention Division India – Regulatory Status Woven Cotton Bandages and Gauze covered under the Drugs & Cosmetics Act Indian Pharmacopeia, too mentions about cotton and viscose as woven fabrics and does not refer to Non Wovens Though, most of the Medical Textile products are currently regulated as ‘Drugs’ there are some ‘Implants’ which are regulated as Medical Devices. Regulations for Medical Devices are being formulated 11 © 3M 2007. All Rights Reserved. 3M Infection Prevention Division Future of Medical Textile / Products The definition of drug as given in the Drugs & Cosmetics Act of 1940 brings under its purview most of the Medical Textile / products under its purview. The issues raised with the ‘application of Drugs Rules’ on Medical Devices impacts the industry and needs to be addressed. The Ministry of Health & Family Welfare is currently working on bringing in Medical Device specific regulations. 12 © 3M 2007. All Rights Reserved.