Medical devices clinical investigation

As a general rule, clinical data are required as evidence to support conformity with the requirements of the Active Implantable Medical Devices (AIMD) and the Medical Device (MD) directives with regards to safety and effectiveness under the normal conditions of use, evaluation of undesirable side effects, and the acceptability of the benefit/risk ratio. Risk analysis should be used to establish key objectives that need to be addressed by clinical data, or alternatively to justify why clinical data are not required (mainly for Class I devices). The risk analysis process should help the manufacturer to identify known (or reasonably foreseeable) hazards associated with the use of the device, and decide how best to investigate and estimate the risks associated with each hazard. The clinical data should then be used to establish the safety and effectiveness of the device under the intended use conditions, and to demonstrate that any of the residual risks are acceptable, when weighed against the benefits derived from use of the device. 

Studies to investigate the safety and effectiveness of In Vitro Diagnostic (IVD) medical devices under intended use conditions are conducted as performance evaluations. They are considered to present less risk than clinical investigations since, by their nature, studies involving IVDs cannot have any direct impact on the health and safety of trial subjects. 

Figure 10.1 Key requirements for the conduct of clinical investigations with medical devices.

There are several areas of study that will help you understand the research topic. As a first step you will want to read the clinical protocol. The protocol describes the device or medication to be used, the patient populations under study, the statistical plan of the clinical trial, and the details of the disease state. If you want to understand the disease state or indication further, you may want to seek out a clinical investigator of the clinical trial or do some further reading about the disease. Understanding the patient population is a good way to understand the data that you will see and whether there is reason for concern when viewing the data. For example, if you were studying a medication to reduce hypertension, you would not be as worried if patient blood pressure data were elevated at baseline. You would expect to see this because you understand that hypertensive patients have high blood pressure. 

Clinical trials serve to assess the safety and efficacy of any potential new therapeutic intervention in its intended target species. In our context, an intervention represents the use of a new biopharmaceutical. Examples of other interventions could be, for example, a new surgical procedure or a novel medical device. Veterinary clinical trials are based upon the same principles, but this discussion is restricted to investigations in humans. Clinical trials are also prospective rather than retrospective in nature, i.e. participants receiving the intervention are followed forward with time. 

Medical devices are regulated on the basis of a three-level risk classification. The highest risk products are the class 3 products that require premarket applications, almost always with clinical data that demonstrate that the product is safe and effective for the intended use. By default, a novel product is a class 3 product unless there is an approval application for initial approval as a class 2 device (the de novo process). Clinical trials for class 3 products before they are approved usually require an IDE, which is similar to the IND required for investigational drugs. 

Compliance with the requirements relating to clinical investigations (AIMDD Annex VII MDD Annex X) is assisted by adoption of standard EN 540 on Clinical Investigation of Medical Devices for Human Subjects, which is very similar to pharmaceutical GCP. 

Guidance Notes for Manufacturers or Clinical Investigations to be carried out in the UK, Medical Devices Agency, September 1996. 

Selection of Tests for Interactions with Blood Tests for Cytotoxicity - In Vitro Methods Tests for Local Effects after Implantation Ethylene Oxide Sterilization Residuals Clinical Investigation of Medical Devices Degradation of Materials Related to Biological Testing... 

Be thoroughly familiar with the properties of the clinical study medications/devices as described in the investigator brochure... 

Maintain the security and accountability of clinical study supplies, ensure that medications/devices are labeled properly, maintain records of clinical study medication/device dispensing, including dates, quantity and use by study subjects and return or disposition (as instructed by the sponsor/CRO) after completion or termination of the study Archive all CRFs and documents associated with the study for a minimum of 15 years. Notify the sponsor/CRO of any problems with archiving in potential unusual circumstances, e.g. investigator retires, relocates, dies study subject dies, relocates, etc. 

---