azaplas
19th February 2009, 04:16 PM
Hi everyone, I am in the middle of compiling the technical file for our classIIb dental laser. The engineer and I were going through Annex 1 (essential requirements) of MDD 07/47/EC (the updated MDD 93/42/EEC) and we have some questions that I'm hoping you have some insight on.
Annex 1 - Section 6a
Demonstration of conformity with the essential requirements must include a clinical evaluation in accordance with Annex X.
- What are the guidelines to completing a clinical evaluation to conform to Annex X? As I understand it, we can either have a critical evaluation made of scienctific literature (but there would need to be an equivalent product out there that we could compare ours to), or a critical evaluation of the clinical data is required. How much data is required for the clinical evaluation? How did you set up your clinical investigations? What is the simplest way we can come up with a document showing we did one?
Annex 1 - Section 11 - Protection Against Radiation
11.2.1. Where devices are designed to emit hazardous levels of radiation necessary for a specific medical purpose the benefit of which is considered to outweigh the risks inherent in the emission, it must be possible for the user to control the emissions. Such devices shall be designed and manufactured to ensure reproducibility and tolerance of relevant variable parameters.
- Our dental laser has a screen which allows the user to control and wattage of the laser. Does this satisfy this requirement?
11.3.1. Devices shall be designed and manufactured in such a way that
exposure of patients, users and other persons to the emission of unintended, stray or scattered radiation is reduced as far as possible.
- How do we prove that the laser was manufactured to reduce unintended emission? What kind of documentation are they looking for?
Section 12.5
12.5. Devices must be designed and manufactured in such a way as to
minimize the risks of creating electromagnetic fields which could
impair the operation of other devices or equipment in the usual environment.
- Is this related to an FCC ID? Well I guess the FCC ID would probably only apply to USA, but would we be able to use that as evidence? What standard applies regarding electromagnetic fields?
Thanks everyone! I know this is a big post. I really appreciate any help you have to offer!
Annex 1 - Section 6a
Demonstration of conformity with the essential requirements must include a clinical evaluation in accordance with Annex X.
- What are the guidelines to completing a clinical evaluation to conform to Annex X? As I understand it, we can either have a critical evaluation made of scienctific literature (but there would need to be an equivalent product out there that we could compare ours to), or a critical evaluation of the clinical data is required. How much data is required for the clinical evaluation? How did you set up your clinical investigations? What is the simplest way we can come up with a document showing we did one?
Annex 1 - Section 11 - Protection Against Radiation
11.2.1. Where devices are designed to emit hazardous levels of radiation necessary for a specific medical purpose the benefit of which is considered to outweigh the risks inherent in the emission, it must be possible for the user to control the emissions. Such devices shall be designed and manufactured to ensure reproducibility and tolerance of relevant variable parameters.
- Our dental laser has a screen which allows the user to control and wattage of the laser. Does this satisfy this requirement?
11.3.1. Devices shall be designed and manufactured in such a way that
exposure of patients, users and other persons to the emission of unintended, stray or scattered radiation is reduced as far as possible.
- How do we prove that the laser was manufactured to reduce unintended emission? What kind of documentation are they looking for?
Section 12.5
12.5. Devices must be designed and manufactured in such a way as to
minimize the risks of creating electromagnetic fields which could
impair the operation of other devices or equipment in the usual environment.
- Is this related to an FCC ID? Well I guess the FCC ID would probably only apply to USA, but would we be able to use that as evidence? What standard applies regarding electromagnetic fields?
Thanks everyone! I know this is a big post. I really appreciate any help you have to offer!





