Australian Medical Device Essential Principles - Part 2: Proposed alignment with the European Regulation

Closes 13 Nov 2024

Proposal 8: Amend AUS Essential Principle 15 - Principles applying to IVD medical devices only

The proposed changes are included under "more information".  The full legislative text comparison and the proposals are presented together in Attachment 1.

Proposal 8(a). Do you agree with the proposal to adopt the intent of the EU GSPRs, related to AUS Essential Principle 15?

This question excludes proposed changes to AUS Essential Principle 15(4). This clause contains an AUS-specific proposal. Your input is requested under Proposal 8(b).

More information

 

AUS Essential Principle 15 - Principles applying to in vitro diagnostic devices only

AUS EP Reference Related EU GSPR Proposed change/s

EP 15(1,2)

IVDR GSPR 9.1
  • Expand the clarity provided, that analytical performance, includes trueness, precision,  accuracy, limits of detection and quantitation, measuring range, linearity, cut-off, including determination of appropriate criteria for specimen collection and handling and control of known relevant endogenous and exogenous interference, cross reactions.
  • Include clarify that clinical performance; specifically refers to diagnostic sensitivity, diagnostic specificity as well additionally includes positive predictive value, negative predictive value, likelihood ratio, expected values in normal and affected populations.

NEW
(No equivalent)

IVDR GSPR 9.2
  • To clarify that performance characteristics of the device shall be maintained during the lifetime of the device, as indicated by the manufacturer.

While AUS EP 4 covers long-term safety of devices, this principle will be included again under AUS EP 15.

NEW
EP 15(3)

IVDR GSPR 9.3
  • Require metrological traceability of values assigned to calibrators and/or control materials to be assured through suitable reference measurement procedures and/or suitable reference materials of a higher metrological order.
  • Where available, metrological traceability of values assigned to calibrators and control materials shall be assured to certified reference materials or reference measurement procedures.
NEW
(No equivalent)
IVDR GSPR 9.4
  • Require the characteristics and performances of the device to be specifically checked in the event that they may be affected when the device is used for the intended use under normal conditions:
    • for devices for self-testing, performances obtained by laypersons;
    • for devices for point-of-care testing, performances obtained in relevant environments (for example, patient home, emergency units, ambulances).
  IVDR GSPR 10-18

IVDR GSPRs 10-18 are aligned with existing Essential Principles, outside of EP 15:

GSPR 10 – refer to EP 7 (Proposal 3)

GSPR 11-12 – refer to EP 8 (Proposal 4)

GSPR 13 – refer to EP 9 (Proposal 5)

GSPR 14 – refer to EP 10 (No changes)

GSPR 15 – refer to EP 11 (Proposal 6)

GSPR 16 - 18 – Refer to EP 12 (Proposal 7)

EP 15(5, 6)

IVDR GSPR 19.1
  • Expand the scope of both EP 15 (5) and (6) to include devices for point of care testing.
  • Clarify the expectation that characteristics and performance of the device are to be evaluated by the manufacturer to ensure the device performs as intended, taking into account the intended user and intended use environment.
  • Clarify that the information and instructions provided be easy for the user to understand so they can correctly interpret the result provided by the device and to avoid misleading information.
  • Require devices intended for point of care testing, the information and the instructions provided by the manufacturer shall make clear the level of training and/or experience required by the user.

EP 15(7)

IVDR GSPR 19.2
  • Increase the scope to include devices for point of care testing.
  • Clarify the requirement that design and manufacture are to ensure that:
    • the device can be used safely and accurately by the intended user at all stages of the procedure, if necessary, after appropriate training and/or information
    • the risk of error by the intended user in the handling of the device and, if applicable, the specimen, and also in the interpretation of the results, are minimised.

 

MATRIX response option

Please clarify your response to individual proposals below.

Proposal 8(b). AUS-specific: Do you agree to adopt the intention of IVDR GSPR 19.3, but to apply the requirements to all IVD devices?

AUS-specific proposal

This proposal includes alignment with the EU IVDR GSPR 19.3, which in Europe, only applies to devices intended for self-testing or near-patient testing.

AUS-specific proposal

AUS Essential Principle 15(4) currently requires that all IVD devices must, to the extent possible, include provision for the user to verify, at the time of use, that the device will perform as intended. We consider this to be a fundamental requirement of all IVD devices, so we do not propose to amend this requirement to only apply to devices intended for self-testing or point of care testing, as in EU IVDR GSPR 19.3.

Likewise, we consider that all IVD devices must, to the extent possible, include a procedure by which the intended user is warned if the device has failed to provide a valid result. Hence, we propose to include this requirement within AUS Essential Principle 15, to apply to all IVD devices.

More information

Current AUS Essential Principle 15(4)

An IVD medical device must, to the extent reasonably practicable, include provision for the user to verify, at the time of use, that the device will perform as intended by the manufacturer.

EU IVDR GSPR 19.3

Devices intended for self-testing and near-patient testing shall, where feasible, include a procedure by which the intended user:

  1. Can verify that, at the time of use, the device will perform as intended by the manufacturer; and
  2. Be warned if the device has failed to provide a valid result.
Proposal 8(c). If you think other changes are needed for AUS Essential Principle 15, please explain.