market access market access JULY/08/AUG
market access market access JULY/08/AUG
market access market access JULY/08/AUG
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<strong>market</strong> <strong>market</strong> <strong>access</strong> <strong>access</strong> JulY/<strong>08</strong>/aug<br />
www.us.tuv.com<br />
www.tuv.com<br />
Your KeYs to NatioNal aNd iNterNatioNal CompliaNCe<br />
Global <strong>market</strong> <strong>access</strong><br />
simplifyinG the certification process<br />
at the local level<br />
The Inside View 2<br />
Overview From Our International<br />
Approvals Manager<br />
Cover Story: 3<br />
International Approvals<br />
Global Market Compliance<br />
Late-Breaking News 6<br />
Worldwide Certification Agency<br />
Acquires Unified Testing Services<br />
In Alabama<br />
Product Safety 8<br />
REACH And The Value Of The<br />
Impact Analysis<br />
Medical 9<br />
Update on FDA’s Third Party<br />
Inspection Program And pMAP<br />
Quality 14<br />
Announcing The Monthly Customer<br />
Feedback Survey Winners<br />
Functional Safety Seminar 15<br />
Hardware / Software Design<br />
To IEC 615<strong>08</strong><br />
TÜVRheinland ® Resources 17<br />
Tradeshows / Seminars
<strong>market</strong> <strong>access</strong> JulY/<strong>08</strong>/aug<br />
The Inside View<br />
Dear Valued Customers,<br />
Whether it is a toy, household appliance, machinery, medical,<br />
radio communications or telecommunications equipment,<br />
<strong>market</strong> <strong>access</strong> is heavily regulated in most countries in the<br />
world. The mandatory compliance procedures vary from<br />
a manufacturer’s Declaration of Conformity with <strong>market</strong><br />
surveillance to Mandatory Certification within the country,<br />
accompanied with regular follow-up inspections. Though<br />
steps are taken to harmonize the certification process, the<br />
simple goal of one product, one test, accepted everywhere;<br />
a target of trade liberalization is far from being realized.<br />
Preparing a product for compliance in the global <strong>market</strong><br />
requires understanding and mastering the complexities of<br />
the regulation and requirements specific to each country. In<br />
the electrical and electronic sector for example, aside from<br />
safety and EMC requirements, there are also regulations<br />
for ergonomics, health, hygiene, noise, vibration, waste<br />
disposal, restrictions on the use of chemicals or other<br />
substances, wired and wireless telecommunications and<br />
energy performance. Strong expertise is necessary to be<br />
familiar with and stay abreast of the changing regulations<br />
and requirements, especially when trying to penetrate<br />
multiple countries.<br />
With a global network of 300 locations in 52 countries,<br />
TüVRheinland ® understands the challenges of obtaining<br />
global <strong>market</strong> <strong>access</strong>. In fact, TüVRheinland ® collaborates<br />
with many of the world’s top level companies to keep them<br />
on the cutting edge. The <strong>market</strong> <strong>access</strong> service experts are<br />
trained to deal with worldwide certification issues and keep<br />
abreast of the ever changing requirements.<br />
In this issue of Market Access, the cover story reviews<br />
the global compliance issues for <strong>market</strong> <strong>access</strong> in detail.<br />
You will also find articles on topical issues exploring the<br />
impact of the European REACH regulation and FDA’s Third<br />
Party Inspection Program and pMAP. In addition, discover<br />
timely news items, such as the upcoming Functional Safety<br />
seminar, tradeshows and more.<br />
Sincerely,<br />
Peter Merguerian<br />
International Approvals Manager<br />
Peter Merguerian<br />
InTERnATIOnAl APPROVAlS MAnAGER<br />
TüVRheinland ®
<strong>market</strong> <strong>access</strong><br />
Cover Story<br />
International Approvals<br />
Global Market Compliance<br />
A Local Approach Eases A Complicated Process<br />
Authored by Udo Heinz, (Carlsbad, CA) Division Manager of Industrial Machinery and Sky Mehringer,<br />
(Carlsbad, CA) Senior Technical Coordinator for International Approvals<br />
Helping a product achieve global compliance is<br />
widely considered a complicated and time-intensive<br />
process. To place a product in other countries,<br />
manufacturers must maneuver a complicated maze<br />
of compliance requirements. A single harmonized<br />
worldwide standard does not yet exist.<br />
preparing for Global compliance<br />
Global compliance is required whether a company is<br />
launching a consumer product or installing machinery<br />
in another country. To prepare, there are several key<br />
considerations, starting with the R&D phase.<br />
• First, research the country’s electrical ratings and<br />
design concerns, or hire a compliance agency to<br />
help with that process. Design the product so that<br />
it works overseas by taking into account of each<br />
country’s required electrical ratings.<br />
ConTInUeD on pAge 4<br />
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• Second, if the product is classified for telecommunications,<br />
find out which frequency bands are<br />
allowed.<br />
• Third, contact each country’s local regulatory<br />
authority to determine certification requirements<br />
and procedures. Several consulting companies<br />
like TüVRheinland ® have local contacts for dozens<br />
of countries, and can handle this step more efficiently.<br />
• Fourth, contact a global compliance agency for<br />
product testing and certification. The agency will<br />
work with the local regulatory agencies to test and<br />
certify the product. Depending on the country and<br />
the product in question, certification can be processed<br />
through a local national Certification Body<br />
or must be completed through the local regulatory<br />
(government) agency.<br />
certifying the Written Word<br />
When testing and certifying a product, nothing is<br />
overlooked, including the product’s user manual,<br />
labels, warnings, test reports, schematics, etc. Each<br />
country has varying requirements but they all have<br />
one thing in common: documents must be written<br />
accurately – with no misleading statements.
<strong>market</strong> <strong>access</strong><br />
Cover Story<br />
International Approvals<br />
Global Market Compliance (continued)<br />
In some countries, the product’s associated<br />
documents must be written in the local language.<br />
For example, Taiwan requires Simple Chinese as<br />
opposed to Mandarin Chinese. In some cases, a local<br />
compliance agency can assist with translation or will<br />
accept an English manual for testing and certification<br />
purposes with the guarantee that a local language<br />
manual will be provided with the imported product.<br />
A local compliance agency can translate these<br />
documents for the manufacturer – another benefit of<br />
having a local office.<br />
Additionally, all documents must display the product’s<br />
appropriate warnings and ratings. Rating labels<br />
are reviewed especially closely to ensure it has<br />
the correct ratings, safety warning and certificate<br />
numbers to pass through customs.<br />
budgeting time for the certification process<br />
When launching a product globally, manufacturers must<br />
prepare to work with either the country’s government or<br />
a local regulatory agency. A country can require multiple<br />
preliminary steps for certification, which can extend the<br />
certification process altogether.<br />
ConTInUeD on pAge 5<br />
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The lead time for certifying a product varies<br />
depending on the product, country and whether<br />
certification is through a government authority or<br />
through a national Certification Body with a local<br />
office. Certifying your product can take anywhere<br />
from 1 week to 3 months, sometimes longer if it’s<br />
through a government authority or there are issues<br />
with the product passing.<br />
In China, for example, the manufacturer must<br />
have its product tested for EMC by a government<br />
lab. The manufacturer can submit a safety report<br />
and certificate (CB scheme) to the government’s<br />
regulatory agency. However, the government must<br />
test product samples in its own test laboratories for<br />
the product to receive the China CCC certification<br />
mark. The timeframe for this entire process depends<br />
on the length of the testing cycle and the product’s<br />
ability to pass government testing without issues.<br />
Furthermore, all telecommunications products must<br />
be tested in-country in China for telecom approval.<br />
local expertise<br />
It is a very daunting task to meet compliance in<br />
the global <strong>market</strong>. Even if you have the technical<br />
understanding of the process, certifying a<br />
product worldwide requires familiarity with the<br />
local country’s regulations, processes and even<br />
government contacts. Therefore, in-country<br />
personnel will bring an insider’s approach, helping<br />
smooth the path toward global compliance.<br />
Moreover, in many cases local representation is<br />
required by law to obtain an approval certificate<br />
for a product. Until the day when global compliance<br />
becomes harmonized, taking the local route – one<br />
day and one country at a time – yields the most<br />
success.
<strong>market</strong> <strong>access</strong><br />
Cover Story<br />
International Approvals<br />
Global Market Compliance (continued)<br />
JulY/<strong>08</strong>/aug<br />
A locally affiliated compliance group or office can<br />
ease the path to compliance in numerous ways. Often<br />
staffed by local citizens, these offices hold the top<br />
experts on the country’s regulatory issues, processes<br />
and agencies. These individuals are also familiar with<br />
the local language, dialects, customs and politics.<br />
In many ways, a local contact helps improve overall<br />
cost and time savings. The in-country contact can<br />
communicate directly with the regulatory agency (or<br />
in some cases, government ministry) much more easily<br />
than someone in another time zone. As an <strong>access</strong>ible<br />
liaison to the government, this person can help with<br />
on-site, in-country product inspections. Depending<br />
on the country, a regulatory body will either perform<br />
its own electrical inspections or accept technical<br />
reports from a national Certification Body (nCB), or<br />
the government requires in-country auditors to inspect<br />
the product and coordinate inspections for electrical<br />
compliance. In both cases, a local compliance contact<br />
can help smooth the path toward global compliance.<br />
For more information and to learn more about<br />
compliance regulations in the global <strong>market</strong>, please<br />
call 1-tUv-rheinlanD (1-888-743-4652).
<strong>market</strong> <strong>access</strong><br />
Late-Breaking News<br />
Worldwide Certification Agency Acquires Unified Testing<br />
Services In Alabama<br />
Celebrating new acquisition - Bernie Hrubala, Division Manager<br />
peMT, Don Uptain, president of UTS, Stephan Schmitt president<br />
and Ceo TÜVRheinland ® of north America, Denny Stepp, Vice<br />
president of UTS, Deep Krishnan Vice president of operations,<br />
TÜVRheinland ® of north America.<br />
TüVRheinland ® recently acquired Unified Testing<br />
Services, Inc. (UTS), a full-service testing and<br />
consulting engineering firm based in Woodstock,<br />
Alabama. TüVRheinland ® currently serves many<br />
industry sectors globally and this strategic acquisition<br />
will benefit clients with added expertise, geographic<br />
expansion of coverage and an increase of service<br />
portfolio offerings to additional industry sectors.<br />
The UTS client base includes many diverse groups<br />
including: state departments of transportation;<br />
universities; banking and real estate institutions;<br />
paper and steel mills; power plants; fabrication<br />
and machine shops; automobile industry suppliers;<br />
industrial equipment suppliers; steel fabrication<br />
shops; amusement/theme parks; and state and local<br />
governments.<br />
ConTInUeD on pAge 7<br />
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“This acquisition enhances our ability to serve<br />
additional segments in different industries that we<br />
have not served in north America before. Previously,<br />
we had offered our services in this industry segment<br />
for export to the rest of the world. now we can offer<br />
these services for the north American <strong>market</strong>, which is<br />
huge benefit to our clients. Having this significant local<br />
expertise will complement our global proficiencies<br />
and provide a better network that will benefit local<br />
customers.” says Stephan Schmitt, President and CEO<br />
of TüVRheinland ® of north America.<br />
UTS brings extensive expertise in a wide variety<br />
of testing and inspection services focused on<br />
materials, construction, transportation, facilities and<br />
environmental engineering. Overall, services include:<br />
environmental consulting and testing; destructive and<br />
non-destructive materials testing; and shop fabrication<br />
inspection of structural steel bridges.<br />
In the environmental arena, UTS provides quality,<br />
cost-effective environmental and testing services that<br />
include testing, sampling and analysis of paints for lead<br />
concentration, as well as assessment and observation<br />
of lead–based paint. The staff is trained in a full range<br />
of asbestos identification and management services<br />
consisting of facility surveys and assessments,<br />
abatement design, abatement monitoring and laboratory<br />
analysis. A full range of environmental site assessment<br />
services ranging from “due diligence” assessments<br />
for real property transactions to sampling and testing<br />
can be offered. UTS also has the capability to provide<br />
indoor air quality testing and assessment (covering
<strong>market</strong> <strong>access</strong><br />
Late-Breaking News<br />
both airborne and microbiological contaminant<br />
sampling and analysis); underground – and – above<br />
ground storage tank assessment and management;<br />
and management and storm water permitting.<br />
UTS can greatly aid production part inspection needs<br />
with computed radiography in addition to other nondestructive<br />
testing (nDT) methodologies: visual;<br />
ultrasonic; magnetic particle; and liquid penetrant<br />
inspections to any code or specification. This wide<br />
range of nDT techniques and procedures supports<br />
clients in an industrial atmosphere including “outagetype”<br />
situations. Services include annual boiler<br />
inspections, critical piping and pressure vessel<br />
inspections, or mechanical integrity verification.<br />
Personnel have experience working with pulp and<br />
paper, power plants, chemical refineries and bulk<br />
storage facilities. A full service lab is located near<br />
many automotive manufacturers, as well as, support<br />
industry for defense contractors.<br />
JulY/<strong>08</strong>/aug<br />
Worldwide Certification Agency Acquires Unified Testing Services In Alabama (continued)<br />
Another key element of the merger is a synergistic<br />
view of the importance of quality service. In a recent<br />
customer satisfaction survey, 98% of TüVRheinland ®<br />
customers stated that they were very satisfied with<br />
the service they received. UTS has always shown<br />
a commitment to the highest quality possible in the<br />
services that they provide.<br />
“I am very pleased with our merger with<br />
TüVRheinland ® . We are now part of the premier<br />
global testing and certification company having<br />
offices in over 60 countries. This is remarkable and<br />
says much about the quality of our company. We<br />
can be proud of our past and look forward to our<br />
future with TüVRheinland ® . Over the last 15 years,<br />
UTS faced many challenges and opportunities as<br />
our company grew and our <strong>market</strong>s changed. Our<br />
competitive <strong>market</strong>s will continue to change and now,<br />
as part of TüVRheinland ® we can take advantage of<br />
the opportunities that are coming. We are now more<br />
than a regional Southeastern U.S. company and our<br />
services can be provided throughout the United<br />
States, Canada, and Mexico” says Don Uptain,<br />
President of Unified Testing Services.<br />
This acquisition will be beneficial to all parties, but<br />
most importantly to our collective customers who<br />
will benefit from the added industry solutions we can<br />
now deliver with consistent high quality.<br />
To learn more, please call 1-tUv-rheinlanD<br />
(1-888-743-4652).
<strong>market</strong> <strong>access</strong><br />
Product Safety<br />
REACH And The Value Of The Impact Analysis<br />
Authored by geoffrey Bock, (Detroit, MI) RoHS/Weee Manager<br />
The EU has implemented a new chemicals regulation<br />
called REACH, which stands for Regulation, Evaluation,<br />
Authorization, and restriction of CHemical substances.<br />
The new regulation is replacing over 40 pieces of<br />
existing legislation. Manufacturers, importers and<br />
users will now have the responsibility of managing the<br />
risks posed by chemicals. REACH will be coordinated<br />
and implemented by the European Chemicals Agency<br />
(ECHA) located in Finland.<br />
Manufacturers and importers, up and down the supply<br />
chain will be responsible for registering chemicals.<br />
Chemicals in preparations or articles manufactured or<br />
imported in excess of 1 ton will be required to register.<br />
What does this mean for non-european producers?<br />
Businesses can be adversely impacted by REACH;<br />
supply chains can be disrupted and you can lose<br />
<strong>market</strong> <strong>access</strong> in the EU. Companies that understand<br />
the business implications and impacts of REACH, and<br />
develop strategic action plans, will gain a competitive<br />
edge over those that fail to do so.<br />
Pre-registration will apply to phase-in substances.<br />
There will be a 6-month window from June 1, 20<strong>08</strong> to<br />
november 30, 20<strong>08</strong>. Failure to pre-register will result<br />
in a loss of pre-registration phase-in status; which will<br />
result in a full 12 month registration process.<br />
What tÜvrheinland ® can do for you:<br />
• Comprehensive REACH analysis regarding manufacturer’s<br />
products and how they are impacted by<br />
the current legislation<br />
JulY/<strong>08</strong>/aug<br />
• On-site educational session<br />
• Review of sales channel and products<br />
• Recommendations of supply channels<br />
• Collection of course data required for preregistration<br />
• Written list of responsibilities for each chemical<br />
• Written list of responsibilities for client<br />
• Profile of timelines and deadlines of requirements<br />
pertaining to each chemical<br />
• Recommended approach of terms and conditions<br />
of sale<br />
• Pre-registration prepared for each chemical with<br />
the EU Chemical Agency<br />
• 3 months of on-call monthly consulting from<br />
project start<br />
• Q&A support from experts in global environmental<br />
requirements<br />
how you can benefit from tÜvrheinland ® services:<br />
• Expertise on EU legislation and REACH implementation<br />
• Avoiding withdrawal of product constituents due<br />
to lack of fulfilling registration requirements<br />
• Receive an Impact Analysis of your business situation<br />
and learn how to reduce effort and costs<br />
For more information, please call 1-tUv-rheinlanD<br />
(1-888-743-4652).
<strong>market</strong> <strong>access</strong><br />
Medical<br />
Update on FDA’s Third Party Inspection Program and pMAP<br />
Authored by gregor Dzialas, (Boxborough, MA) Third party Inspection program Manager<br />
The Medical Device User Fee and Modernization<br />
Act of 2002 (MDUFMA) introduced the Inspection<br />
by Accredited Person Program. Under this program<br />
eligible manufacturers of class II and III medical<br />
devices can choose to use an FDA accredited third<br />
party, such as TüVRheinland ® of north America, to<br />
perform inspections to US regulations as an alternative<br />
to the traditional inspection by an FDA official. The<br />
primary benefit for manufacturers to participate in this<br />
voluntary program is to combine FDA inspections with<br />
other conformity assessment inspections, e.g. MDD/<br />
ISO 13485/CMDCAS, which will save time, money and<br />
resources.<br />
The MDUFMA of 2002 established a new subsection of<br />
the US Food, Drug and Cosmetic Act, which required<br />
FDA to accredit third parties to perform inspections of<br />
ConTInUeD on pAge 10<br />
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eligible device manufacturers. The program is referred<br />
to as “Inspection by Accredited Person Program”<br />
or “Third Party Inspection Program”. An Accredited<br />
Person (AP) under the provisions of this Program is a<br />
third party recognized by FDA to:<br />
• Assess the quality system of eligible manufacturers<br />
of Class II and III devices under 21 CFR Part 820<br />
• Determine compliance with other device requirements<br />
in the act and regulations<br />
• Prepare and submit reports to FDA, who makes the<br />
final compliance assessment<br />
By statute the FDA has the mandate to inspect class II<br />
and III device manufacturers every two years. Due to<br />
FDA’s limited resources and the global expansion of the<br />
medical device industry, actual inspection frequency<br />
(especially for lower risk device manufacturers<br />
and foreign manufacturers) is much lower than the<br />
biennial inspection requirement. In a report issued<br />
by the US Government Accountability Office (GAO) in<br />
January 20<strong>08</strong>, it is stated that the FDA estimates that<br />
establishments for medium risk devices have been<br />
inspected every 5 years and foreign establishments<br />
involved with medium risk devices every 27 years. The<br />
AP inspection program will allow the FDA to focus on<br />
higher-risk inspections, and those inspections which<br />
are not within the scope of the program, such as “forcause”,<br />
PMA and bioresearch monitoring inspections.<br />
Conversely, manufacturers with a global <strong>market</strong>ing<br />
presence have been faced with ever increasing<br />
number of regulatory requirements and conformity<br />
assessments. To maintain their <strong>market</strong> presence, they<br />
must undergo numerous separate inspections each
<strong>market</strong> <strong>access</strong><br />
Medical<br />
Update on FDA’s Third Party Inspection Program and pMAP (continued)<br />
year to demonstrate compliance with requirements<br />
that are largely harmonized. Participation in the Third<br />
Party Inspection Program will give manufacturers<br />
the opportunity to reduce the number of inspections<br />
conducted to meet FDA and other countries’ regulations,<br />
and to control the scheduling of inspections.<br />
pmap – pilot multi-purpose audit program<br />
The pilot Multi-purpose Audit Program, which was<br />
developed by Health Canada (HC) in cooperation<br />
with the US Food and Drug Administration (FDA), was<br />
introduced in September 2006. The purpose of the<br />
pMAP is to evaluate the effectiveness of performing a<br />
single third party inspection/audit of medical devices<br />
manufacturers’ quality management systems that<br />
would meet the regulatory requirements of Canada<br />
and the United States. The pMAP builds upon the<br />
regulatory programs of both countries, specifically<br />
those aspects which involve the services of third<br />
party quality system auditing organizations: the FDA’s<br />
Inspection by Accredited Person Program and Health<br />
Canada’s CMDCAS program. FDA and HC are intending<br />
to use the audits/inspections under the pMAP as a<br />
learning opportunity to acquire a better knowledge of<br />
auditing/inspection approaches that support several<br />
regulatory objectives.<br />
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10<br />
While pMAP does not alter or eliminate any previously<br />
established procedures, guidance and regulations of<br />
the AP and the CMDCAS program, it is a program in<br />
itself, which has its own set of rules and requirements.<br />
It is important to note that at the current time, the pMAP<br />
is mandatory for manufacturers who are seeking a<br />
single inspection/audit under the CMDCAS and AP<br />
program.<br />
progress and status of the ap and pmap programs<br />
According to a report by GAO, few inspections of<br />
medical device manufacturing establishments have<br />
been conducted through the AP Inspection Program<br />
and the pMAP. From March 11, 2004 - the date when<br />
FDA first cleared an accredited organization to<br />
conduct independent inspections - through January<br />
20<strong>08</strong>, only five inspections were conducted under the<br />
AP program and two audits under the pMAP. These<br />
numbers seem to suggest a very limited interest in<br />
these programs, but a close look at the history and the<br />
rules of both programs might reveal other reasons for<br />
the low participation.<br />
While the FDA met their objective to initially accredit<br />
15 third parties by October 2003, very slow progress<br />
has been made in qualifying individual inspectors/<br />
auditors in this program. According to the current<br />
program rules, each auditor has to participate in three<br />
joint inspections with the FDA. The demand in joint<br />
inspections is higher than the number of inspections<br />
offered; the FDA assigns the inspections to APs by a<br />
random draw. The availability of training opportunities<br />
is limited by the number of device manufacturers,<br />
who volunteer to host joint inspections. Training is<br />
also limited by the availability of FDA performance<br />
inspectors, who are qualified to monitor AP auditors
<strong>market</strong> <strong>access</strong><br />
Medical<br />
Update on FDA’s Third Party Inspection Program and pMAP (continued)<br />
during joint inspections. The limited availability of<br />
training inspections makes it difficult for APs to plan<br />
the qualification of auditors and subsequently offer<br />
third party inspection services. Today, as a result, only<br />
eight of the 16 accredited third parties are operational<br />
and can offer independent inspections. Of those eight<br />
APs, four are located in the United States; among them<br />
is TüVRheinland ® of north America, Inc.<br />
Another reason for the low participation in the program<br />
could be the restrictive eligibility requirements.<br />
Excluded from participation are device manufacturers,<br />
who have not been inspected by the FDA (baseline<br />
inspection) or whose last inspection has been<br />
qualified as OAI (Official Action Indicated). Also, the<br />
manufacturer must <strong>market</strong> or intend to <strong>market</strong> a device<br />
in a foreign country, in which the AP is accredited or<br />
recognized. Per the FDA website, some APs appear<br />
to be recognized in very few countries. For example,<br />
one of the APs is recognized only in norway. The<br />
pMAP program has further narrowed the eligibility for<br />
manufacturers. Audits that are not acceptable under<br />
the pMAP program are:<br />
• Initial ISO 13485:2003 registration audits under<br />
CMDCAS<br />
• Transfer of registration from one audit organization/registrar<br />
to another<br />
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11<br />
• Audits to support an extension to the existing<br />
scope of registration<br />
• Special “for-cause” audits (e.g. re-audits to follow-up<br />
on major non-conformities)<br />
lastly, while these programs are designed to offer clear<br />
benefits to device manufacturers, participation calls<br />
for a mind-set adjustment relating to FDA inspection.<br />
While manufacturers always had to “invite” CMDCAS<br />
registrars and notified Bodies for an audit in order to<br />
<strong>market</strong> their products in Canada and the EU, this is not<br />
necessary or required in the US: Pre-<strong>market</strong> approval<br />
or pre-<strong>market</strong> notification clearance is sufficient in<br />
order to <strong>market</strong> a product. The FDA decides if and when<br />
to inspect an establishment involved in the product<br />
realization of a device. To invite an FDA/AP inspection,<br />
which otherwise might not be conducted, is a very new<br />
and pro-active approach.<br />
The FDA and HC have realized these challenges<br />
in the AP program and have taken measures to<br />
improve participation. The Medical Device User Fee<br />
and Modernization Act (MDUFMA II) - legislative<br />
Recommendations (April 30, 2007) includes proposals<br />
for the following changes:<br />
• Streamline administrative burdens<br />
- Firms would provide FDA 30 day notice of their<br />
intent to use an AP rather than petitioning FDA<br />
for clearance to use an AP<br />
• Expand participation<br />
- Firms may use an AP for an unlimited number of<br />
consecutive inspections without seeking a waiver,<br />
rather than only two consecutive inspections<br />
- FDA would continue to conduct “for cause” or<br />
follow-up inspections at their discretion
<strong>market</strong> <strong>access</strong><br />
Medical<br />
• Encourage industry to provide FDA with more data<br />
- Firms may voluntarily submit reports by third<br />
parties assessing conformance with appropriate<br />
international quality systems standards, such as<br />
ISO, which FDA would consider in setting our<br />
inspectional priorities<br />
In addition, Health Canada and the FDA undertook<br />
a cooperative effort to identify those device<br />
manufacturers in the US, who are due for an<br />
FDA inspection in 20<strong>08</strong> and at the same time are<br />
registered to ISO 13485 under the CMDCAS program.<br />
Manufacturers who met both criteria received a<br />
mailing with information about the pMAP program<br />
and were encouraged to participate.<br />
Most recently an increase of interest and participation<br />
in the program has been observed. In the Health<br />
Canada CMDCAS RBF (Registration Body Forum)<br />
meeting in May 20<strong>08</strong> it was stated that already five<br />
companies have been successfully assessed under<br />
the pMAP process. Both Health Canada and the FDA,<br />
which also participated in this meeting expressed that<br />
they remain committed to the program and agreed that<br />
a sample size of 10 successful pMAP audits would be<br />
considered “sufficient experience” to assess the results<br />
ConTInUeD on pAge 13<br />
JulY/<strong>08</strong>/aug<br />
Update on FDA’s Third Party Inspection Program and pMAP (continued)<br />
of this pilot program. If the assessment concludes that<br />
multi-purpose audits are valid and acceptable to fulfill<br />
the requirements under the CMDCAS program, then<br />
some of the restrictions for participation might be<br />
eliminated.<br />
Another very promising objective, which came out of<br />
this meeting, is the development of a common audit/<br />
inspection report format. A common report format<br />
would significantly reduce the time needed by the AP/<br />
Registrar to prepare the two submissions and hence<br />
would reduce the additional service fees associated<br />
with AP/pMAP audits.<br />
Who should participate and why?<br />
Manufacturers who are likely to be inspected by the<br />
FDA and who <strong>market</strong> products in foreign countries will<br />
benefit from participation in the AP and pMAP program<br />
because they will reduce the overall number of audits/<br />
inspections conducted at their establishment and they<br />
will gain more control over the timing and planning of<br />
the audit/inspection.<br />
Manufacturers who in the past have not been inspected<br />
at two year intervals might want to consider an AP<br />
inspection for another reason: Historic data shows<br />
that regularly inspected establishments are more<br />
likely to be found in compliance with the regulations.<br />
By requesting an AP inspection on a regular basis,<br />
manufacturers can increase the confidence in their<br />
quality management system and its conformance to<br />
the US regulations.<br />
Finally, manufacturers that are not currently eligible<br />
under the program, or do not wish to participate at<br />
this time, are encouraged to volunteer to host joint<br />
1
<strong>market</strong> <strong>access</strong><br />
Medical<br />
Update on FDA’s Third Party Inspection Program and pMAP (continued)<br />
inspections by the FDA and a Third Party. In particular,<br />
those manufacturers who have received notification<br />
from the FDA that they are due for an inspection can<br />
greatly help to advance this program by allowing a<br />
third party auditor to join on their next FDA inspection.<br />
Manufacturers who decide to volunteer for joint<br />
inspections should contact the FDA and their registrar/<br />
notified body to request that the joint inspection is<br />
conducted by an auditor who works for this particular<br />
manufacturer’s registrar/notified body. This will assure<br />
that independent third party inspections will be a<br />
possibility for them in the near future.<br />
conclusion<br />
The Inspection by Accredited Person Program and the<br />
pilot Multi-purpose Audit Program are operational, and<br />
successful audits/inspections have been conducted<br />
under both programs. However, more participation is<br />
required to keep these programs alive.<br />
FDA and Health Canada remain committed and have<br />
proposed changes and initiatives to promote and<br />
advance both programs.<br />
For more information, please call 1-tUv-rheinlanD<br />
(1-888-743-4652).<br />
references<br />
FDA AP program website:<br />
http://www.fda.gov/cdrh/ap-inspection/ap-inspection.html<br />
FDA guidance document:<br />
“Requests for Inspection by an Accredited Person Under the Inspection by Accredited Persons<br />
Program Authorized by Section 203 of the Medical Device User Fee and Modernization Act of<br />
2002 – Draft, June 3, 2002”<br />
http://www.fda.gov/cdrh/comp/guidance/1532.html<br />
Health Canada website:<br />
Pilot Multipurpose Audit Program (PMAP) - Questions and Answers related to the Pilot<br />
http://www.hc-sc.gc.ca/dhp-mps/md-im/activit/int/md_pmap_qa_im_ppafm_qr-eng.php<br />
JulY/<strong>08</strong>/aug<br />
1
<strong>market</strong> <strong>access</strong><br />
Quality<br />
Congratulations to Weylan Stricklin from nachi<br />
Robotic - the April winner and Mike Benson from<br />
Associated Spring, Barnes Industrial- the May winner<br />
of TüVRheinland ® ’s customer feedback survey drawings<br />
for the Management System Certification (MSC)<br />
Division. Weylan and Mike are proud winners of an<br />
elegant TüVRheinland ® clock, which was recently sent<br />
to them, compliments of TüVRheinland ® .<br />
Providing customer service is critical to the MSC<br />
Division of TüVRheinland ® . A customer feedback<br />
survey is given to all customers at the completion of<br />
their audit and is used to identify the following key<br />
points in providing good customer service:<br />
• Response time of services<br />
• Quality of services<br />
• Communications with staff<br />
• Technical competence<br />
• level of knowledge<br />
• level of courtesy<br />
• Overall impression<br />
• Professionalism of auditor<br />
If you are a quality customer, please take a few moments<br />
to respond to this mutually beneficial survey and qualify<br />
as the winner of TüVRheinland ® ’s monthly prize. Your<br />
satisfaction is important to us. Other response vehicles<br />
are available to TüVRheinland ® customers through an<br />
online feedback form available at www.us.tuv.com.<br />
For any certification, testing or compliance questions,<br />
please call 1-tUv-rheinlanD (1-888-743-4652).<br />
JulY/<strong>08</strong>/aug<br />
Announcing The Monthly Customer Feedback Survey Winners<br />
Management System Certification Response Yields Valuable Prize For<br />
Lucky Contestants<br />
1
<strong>market</strong> <strong>access</strong><br />
Functional Safety Seminar<br />
hardware / software Design according to iec 615<strong>08</strong><br />
target Group<br />
Developers, who are mainly engaged in the development<br />
of programmable electronic safety systems on the basis<br />
of the acknowledged international standard IEC 615<strong>08</strong>.<br />
This training imparts basic knowledge, which enables<br />
developers to transfer the requirements of the standard<br />
IEC 615<strong>08</strong> most effectively.<br />
trainer<br />
Dipl.-Ing. heinz Gall is manager of the business sector<br />
“Automation, Software and Information Technology” of<br />
TüVRheinland ® Industries Service GmbH. His main tasks<br />
refer to consulting of design of safety concepts and the<br />
performance of trainings concerning topics of functional<br />
safety and safety engineering.<br />
Dipl.-Ing. Matthias Haynl is Business Field Manager of<br />
Functional Safety TüVRheinland ® north America. He<br />
has many years of experience - also internationally - as<br />
specialist concerning the area of functional safety of<br />
machinery and safety in the process industry.<br />
contents<br />
Introduction<br />
• Functional safety of electric, electronic and<br />
programmable systems<br />
Safety philosophy<br />
• Definition of risk, principle of risk reduction<br />
• Introduction to various classification systems (SK, SIl)<br />
• Comparison and relation of classification systems<br />
to each other<br />
International Standard IeC 615<strong>08</strong><br />
• General methods and requirements<br />
• Consideration of life cycle aspects of safetyrelated<br />
systems and components<br />
• Requirements concerning management of<br />
Functional Safety<br />
• Requirements for the evaluation/judgment of<br />
Functional Safety<br />
ConTInUeD on pAge 16<br />
JulY/<strong>08</strong>/aug<br />
• Definition of requirements according to the chosen SIl<br />
• Meaning of Safety Integrity level (SIl)<br />
• Consideration of faults and fault models<br />
- Fault: random fault, systematic fault, fault caused<br />
by handling, fault during operation<br />
- Fault models: stuck-at-, DC- and extended DCfault<br />
model<br />
• Definition of measures against faults<br />
- Fault avoidance<br />
- Fault detection and -control<br />
• Comparison “deterministic” and “probabilistic”<br />
method<br />
• Consideration during design-, development- and<br />
production phase<br />
- Safety requirement specification<br />
- Verification- and validation plan<br />
• Examples of<br />
- Hardware-design and verification<br />
- Software-design and verification<br />
• Calculation of the probability of failure on demand (PFD)<br />
- Derivation of Reliability Block Diagram for<br />
different systems<br />
- Derivation of formula for calculation of PFD<br />
- Architectural constraints, Safe Failure Fraction<br />
and diagnostic coverage<br />
- Interpretation of formula from IEC 615<strong>08</strong>-6<br />
- Influence of proof-test-interval, diagnostic-testinterval<br />
on probability figures<br />
- Redundant systems and common cause factor<br />
- Example for PFD calculation<br />
• Constraints and conditions for the phases<br />
- Commissioning, implementation, operation,<br />
maintenance<br />
- Operation<br />
1
<strong>market</strong> <strong>access</strong><br />
Functional Safety Seminar<br />
hardware / software Design according to iec 615<strong>08</strong> (continued)<br />
Application of safety-related Bus Systems<br />
• Application of standards IEC 615<strong>08</strong>, En 954,<br />
ISO13849-1 and En 50159 to the described methods<br />
and measures for bus systems.<br />
• Basic requirements for the application of bus-systems<br />
• Deterministic approach<br />
- Transmission error, random hardware failure,<br />
systematic failure<br />
Topic Overview<br />
agenda<br />
1st Day<br />
1. Introduction, overview of the TüV Functional<br />
Safety Program Day One<br />
2. Introduction into safety Introduction<br />
engineering<br />
3. Application The of the medical international device standard <strong>market</strong> landscape IEC 615<strong>08</strong><br />
Part 1: General requirements and management of<br />
PAL<br />
functional safety<br />
The Japanese Pharmaceutical Affairs Law<br />
JulY/<strong>08</strong>/aug<br />
- Considerations of probability of transmission<br />
faults<br />
- Reliability of data transmission<br />
- Bit-failure rate<br />
- Failure-rate and failure-detection<br />
• Various Bus-Architectures<br />
• Examples for various bus-systems and safety<br />
considerations<br />
4th Day<br />
Summary of training - Questions and answers<br />
Speakers<br />
exam<br />
Duration approx. 3.5 – 4 hours<br />
Start: 11 am | End: approx. 3 pm<br />
Tamas<br />
Borsai<br />
the seminar will be held:<br />
2nd Day<br />
What PAL Means to You<br />
September 22-25, 20<strong>08</strong> (4 days)<br />
1. Examples concerning management of functional Start: 9 am | End: approx. 4.30 pm<br />
Lunch<br />
safety<br />
Courtyard Boston natick<br />
2. Application Gaining <strong>access</strong> of the international to Turkey/Ukraine/Russia/India/ROW<br />
standard IEC 615<strong>08</strong><br />
Title Here<br />
Loren impsom<br />
liab m pgobi<br />
p giua dpfio.<br />
Uhdpf ob dpf<br />
kdfpbj,dfgiab<br />
Part 2: Requirements of E/E/PES<br />
3. Determination and<br />
EU<br />
evaluation<br />
Regulatory<br />
of<br />
Update<br />
safety-related<br />
parameter (practical examples)<br />
MDD<br />
342 Speen Street mp gobi pgiu a dpfio uhdpf obd pf k<br />
natick, Massachusetts 01760 dfp bj, dfgiab mpg obip.pgobi pgiu a<br />
dpfio uhdpf .<br />
Phone: 1-5<strong>08</strong>-655-6100<br />
Break<br />
3rd Day<br />
1. Determination and evaluation FDA Update of safety-related<br />
Fax: 1-5<strong>08</strong>-655-6104<br />
cost:<br />
Michael<br />
Brousseau<br />
Title Here<br />
parameter (practical examples)<br />
2. Application of the international DAY standard 2 IEC 615<strong>08</strong><br />
Part 3: Software requirements Introduction<br />
3. Practical example concerning part 3<br />
4. Requirements of Current tools State for configuration of IEC601 and<br />
parameterization of safety systems<br />
5. Requirements IEC of safety-related 60601 (2005) bus 3rdsystems Editionacc.<br />
$ 3,800.00 - Includes exam, training proceedings, Loren lunch impsom<br />
and refreshments<br />
liab m pgobi<br />
$ 3,400.00 - Without exam<br />
p giua dpfio.<br />
Uhdpf ob dpf<br />
kdfpbj,dfgiab mp-<br />
To register, please visit: gobi pgiu a dpfio uhdpf obd pf k dfp<br />
www.us.tuv.com or call bj, dfgiab mpg obip.pgobi pgiu.<br />
1-tUv-rheinlanD<br />
The to sweeping IEC 615<strong>08</strong>. new approach to medical regulatory compliance (1-888-743-4652)<br />
Lunch<br />
Richard<br />
Morroney<br />
Special guest<br />
IEC 60601 (2005) 3rd Edition<br />
from Clinivation<br />
Loren impsom<br />
1
<strong>market</strong> <strong>access</strong><br />
TÜVRheinland ® Resources<br />
Assisting Your Company With Testing, Certification,<br />
Compliance & More<br />
Tradeshows<br />
To view other tradeshows that TüVRheinland ® will be visiting, please visit http://www.us.tuv.com/news/tradeshows.aspx.<br />
ieee emc 20<strong>08</strong><br />
Cobo Center<br />
Detroit, MI<br />
August 18-22 | Booth #227<br />
iaei southwestern 20<strong>08</strong><br />
International Association of Electrical Inspectors<br />
Monterey Marriott<br />
Monterey, CA<br />
September 7-11 | Booth #TBA<br />
imts 20<strong>08</strong><br />
International Manufacturing Technology Show<br />
McCormick Place<br />
Chicago, Il<br />
September 8-13 | Booth #4795<br />
raps 20<strong>08</strong><br />
Regulatory Affairs Professionals Society<br />
Hynes Convention Center<br />
Boston, MA<br />
September 14-17 | Booth #320<br />
iaei-northwest 20<strong>08</strong><br />
International Association of Electrical Inspectors<br />
Jantzen Beach Red lion Hotel on the River<br />
Portland, OR<br />
September 15-17 | Booth #TBA<br />
Seminars<br />
iaei- Western 20<strong>08</strong><br />
international Association of Electrical Inspectors<br />
Best Western Ramkota Hotel<br />
Rapid City, SD<br />
September 21-24 | Booth #TBA<br />
international public transportation expo 20<strong>08</strong><br />
San Diego Convention Center<br />
San Diego, CA<br />
October 6-8 | Booth #246<br />
pcb carolina 20<strong>08</strong><br />
Raleigh Convention Center<br />
Raleigh, nC<br />
October 7 | Booth #TBA<br />
iaei southern 20<strong>08</strong><br />
International Association of Electrical Inspectors<br />
Hilton Alexandria Mark Center<br />
Alexandria, VA<br />
October 12-15 | Booth #TBA<br />
isa 20<strong>08</strong><br />
Reliant Center<br />
Houston, TX<br />
October 14-16 | Booth #1244<br />
Please visit www.us.tuv.com/seminars for availability, cost and registration options.<br />
tUv functional safety program<br />
hardware/software Design according to iec 615<strong>08</strong><br />
Boxborough, MA<br />
September 22-25, 20<strong>08</strong><br />
(see page 14 for more details)<br />
JulY/<strong>08</strong>/aug<br />
ieee pses 20<strong>08</strong><br />
Austin Marriott north<br />
Austin, TX<br />
October 20-22 | Booth #TBA<br />
pack expo 20<strong>08</strong><br />
McCormick Place<br />
Chicago, Il<br />
november 9-13 | Booth #8316<br />
rsna 20<strong>08</strong><br />
Radiological Society of north America<br />
McCormick Place<br />
Chicago, Il<br />
november 30-December 5 | Booth #7043<br />
1
<strong>market</strong> <strong>access</strong> JulY/<strong>08</strong>/aug<br />
TUV52-IT Ad-Monitor Head 7/3/<strong>08</strong> 11:01 AM Page 1<br />
For the absolute highest definition of product safety, trust TÜVRheinland.<br />
Marketing IT peripherals needs more than a price point; it<br />
needs a vision as well. A vision that's tempered by the kind<br />
of intelligence needed to prevent quality issues and production<br />
delays. Fact is, the category is so “commoditized” that<br />
there’s no room for recall-inducing and margin-reducing<br />
mistakes. That’s why it’s time to reboot your thinking and<br />
take advantage of our GRS program. Simply put, GRS<br />
stands for Global Retail Solutions, a customizable suite of<br />
QC, QA and compliance services so comprehensive they<br />
could only be offered by an industry leader like TÜV. If<br />
you’re tired of screening your testing facilities more carefully<br />
than you screen your production facilities, it's time you gave<br />
us a shot. See for yourself why we're a hit with anyone for<br />
whom the bottom line is top of mind.<br />
TÜVRheinland ®<br />
Precisely Right.<br />
call for a custom consultation:<br />
1-TÜV-Rheinland (1-888-743-4652)<br />
International: 1 (203) 426-<strong>08</strong>88<br />
© 20<strong>08</strong> TÜVRheinland ®<br />
1
<strong>market</strong> <strong>access</strong><br />
traci conroy • managing editor<br />
TüVRheinland ®<br />
12 Commerce Road, newtown, CT 06470 USA<br />
Tel 203-426-<strong>08</strong>88<br />
Fax 203-426-4009<br />
Email tconroy@us.tuv.com<br />
www.us.tuv.com<br />
Market Access is published six times a year by TüVRheinland ®.<br />
Subscriptions are free. This newsletter is published for the<br />
convenience of our customers, clients and professional<br />
associates. Although it is intended to provide accurate and<br />
authoritative information with respect to the subject matter<br />
covered, the information and opinions contained in this<br />
publication are those of the authors and not of the editor or<br />
publisher. The authors, editor and publisher disclaim any liability<br />
for any inaccuracies contained herein. Before any action is<br />
taken based upon the published information, it is essential that<br />
competent and individual professional advice is obtained.<br />
TÜVRheinland®, Inc. is an equal-opportunity/affirmative<br />
action employer.<br />
mission statement<br />
Employees and Leadership<br />
our employees are the most important success factor for the TÜVRheinland ®<br />
group. Their engagement, competence, neutrality and performance are key.<br />
Services and Products<br />
Demonstrable quality marks our services and products. This creates and<br />
secures competitive advantages.<br />
Technology and Safety<br />
We represent responsibly designed technology and set safety standard for<br />
the future.<br />
Customers and Markets<br />
Customers safeguard our existence. The customer must be convinced of the<br />
quality of our services in order for us to achieve success in the <strong>market</strong>place.<br />
Economic Success and a Secure Future<br />
Market-oriented thinking and efficient action secure the strength and<br />
independence of the TÜVRheinland ® group.<br />
Environment<br />
In our work, we demonstrate that environmental protection, technology and<br />
economics can be combined in a sustainable manner. This applies to both our<br />
services and our own product.<br />
The Public<br />
openness, competence, presence and neutrality as an independent third<br />
party determine our actions and shape our public image