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Safeguarding public health
BIOABSORBABLE STENTS:
REGULATORY ISSUES
DR SUSANNE LUDGATE
Clinical Director
Medicines and Healthcare products Regulatory Agency, UK
Name MHRA
Date
2006
©
NO CONFLICT OF INTEREST
TO DECLARE
EU REGULATORY SYSTEM
investigation
action, including
recall, safeguard
Notified Body
compliance ERs
safety, performance
provide ifu
• quality systems
• design dossier
• clinical data
• ifu
• pmcf plan
• pms plan
accredit
audit
• clinical investigation
• humanitarian use
European market
Safeguarding Public Health
MHRA
Competent
Authority
• post market surveillance
• vigilance
Slide 3
2006
©
CLINICAL INVESTIGATION
clinical (previous experience, inclusion, exclusion, end points, duration)
radiological (OCT, MSCT) / other investigations
materials (tensile strength, radial force, balloon life, speed deflation)
biological safety (animal studies)
biocompatibility (thrombogenicity, complement, haemolysis)
sterilisation validation
shelf life, special storage conditions
drug
- qualitative, quantitative details
- method of manufacture
- control tests
- stability
- local tolerance
- pharmacokinetics
- clinical data
Safeguarding Public Health
MHRA
Slide 4
2006
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CLINICAL INVESTIGATIONS
end points to demonstrate safety, performance, claims
NOT randomised controlled
numbers
timescales
investigating centres
Safeguarding Public Health
MHRA
Slide 5
2006
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OTHER FACTORS
training
adverse event reporting
CE marking when?
humanitarian use
Safeguarding Public Health
MHRA
Slide 6
2006
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HUMANITARIAN USE
one –off
named patient basis
forms to complete (of course!)
24 hour turn around
Safeguarding Public Health
MHRA
Slide 7
2006
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POST-MARKET
“ …an undertaking by the manufacturer
to institute and keep up-dated a POST
MARKET SURVEILLANCE SYSTEM…”
post market clinical plan
extension clinical trial
cohort study
sub-population studies
registers
adverse incident reporting including ifu
Safeguarding Public Health
MHRA
Slide 8
2006
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CLINICIAN INPUT
is the protocol designed to deliver (short, long term)
meeting/teleconference with MHRA, manufacturer
ensure adequate training
consider humanitarian use
remember post CE marking protocols, collect data
report all adverse events to MHRA
consider carefully off-label use (data collection)
discuss problems early with MHRA
“we’re from the government and are here to help!”
Safeguarding Public Health
MHRA
Slide 9
2006
©