The article provides an overview of a checklist outlining the main principles to be considered with respect to medical devices intended to be marketed and used in Australia.

TGA Guidance on Clinical Evidence for Implantable Pulse Generator Systems: Overview

The Therapeutic Goods Administration (TGA), an Australian regulating authority in the sphere of healthcare products, has published a detailed checklist dedicated to the Essential Principles medical devices should meet in order to be allowed for marketing and use in the country. These principles are based on the most important safety-and effectiveness-related considerations, and thus are mandatory for all the products. 

The document is intended to assist medical device manufacturers and other parties involved with ensuring compliance with the applicable regulatory requirements when placing their products on the country’s market. 

The TGA’s Department of Health and Aged Care requires manufacturers to demonstrate compliance with the Essential Principles for medical devices. This involves producing, assessing, and maintaining scientific and clinical evidence that is relevant, sufficient, and robust to prove the device’s compliance with safety and performance standards.

General Principles

According to the guidance, the general principles include the ones related to compliance and safety assurance, device performance, and risk-benefit analysis, namely: 

  • Health and Safety: Devices must not compromise the health and safety of users or patients. Risks associated with the device’s use must be acceptable and offer a high level of health and safety protection.
  • Design and Construction: The design and construction of medical devices must adhere to safety principles, considering the state of the art. Manufacturers must identify and mitigate risks, ensuring inherent safety in design and construction and providing adequate protection measures where necessary.
  • Intended Use: Devices must function as intended and be suitable for defined medical purposes. They should remain effective and safe throughout their specified usage period and not be affected adversely by regular maintenance or environmental conditions like transport and storage.
  • The benefits of using the medical device must outweigh any potential undesirable effects.
FDA on assessing credibility of computational modelling2

Design and Construction Principles

Another section of the document describes the principles related to the design and construction of medical devices. This category covers, inter alia, the principles associated with material and chemical safety, as well as infection and contamination control or environmental and operational safety.

The key principles falling within this category include:

  • Chemical, Physical, and Biological Properties: The selection of materials must consider their chemical and physical properties and their compatibility with biological tissues. The design should minimize risks from contaminants and ensure safety with other materials or substances used alongside the device.
  • Sterilization and Cleanliness: Devices intended to be sterile must be designed, produced, packed, and maintained to remain sterile up to the point of use. Those supplied in a non-sterile state should prevent microbial contamination and be suitable for sterilization before use.
  • Microbial Safety: Devices containing biological materials must comply with safety standards regarding infection and microbial contamination. This includes control over animal-derived substances and ensuring safe handling and processing standards.
  • Compatibility and Interference: Devices must be safe to use in conjunction with other medical equipment, minimizing risks such as physical injury, environmental conditions, and interference with other devices.
  • Electrical and Mechanical Safety: Electrical and mechanical designs must protect users and patients from risks like electric shock, mechanical malfunctions, and unwanted emissions such as electromagnetic fields or radiation.
  • Radiation Safety: Devices that emit radiation must minimize exposure risks and ensure that any emissions are controlled and necessary for the medical purposes intended.
  • Energy Dependence: Devices reliant on power sources must include safety features like alarms to indicate power failures and ensure continuous operation as required for patient safety.

Compliance Documentation

In addition to the above, the document issued by the TGA also outlines the scope of documentation to be provided by the parties involved in order to demonstrate compliance with the applicable regulatory requirements:

  • Documentation: Manufacturers must provide a rationale and documented evidence for each compliance aspect, referencing the Essential Principles and adhering to TGA guidelines and standards. This includes maintaining a quality management system that aligns with regulatory requirements.
  • Conformity Assessment: Completing the Essential Principles Checklist is crucial for applying for Australian conformity assessment certificates and maintaining compliance during post-market activities.

Conclusion

In summary, the present checklist developed by the TGA is intended to assist medical device manufacturers and other parties involved in ensuring compliance with the applicable Essential Principles their products should meet in order to be allowed for marketing and use in the country. The document highlights the key points to be taken into consideration and also emphasizes the importance of having documents evidencing compliance with the key safety- and performance-related principles.

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