PSUR data collection for consumer product

Vetty007

Involved In Discussions
Hello,

I am currently despairing over the discussion of the requirements for market surveillance of a medical device that is sold through discounters. For the PSUR, I always look at the product reviews on the discounter websites and esp evaluate negative reviews. But if I have a significant proportion of a plausible positive feature, that I can possibly back up with other data, I am happy to use this information for my own product too. At the same time, I look for equivalent products on these websites too.

Now, however, my customer complaints, that I should stop doing this unnecessary work of checking the respective websites as it would be utter nonsense to use such information - The argument was, that if it was a justified and serious complaint, the people affected would have contacted the retailer or manufacturer indicated on the packaging and not writte something on the product website. I absolutely don't share this opinion at all, it's the easiest way for the user, and not everyone will use it either, as it also requires effort and then the product will be simply thrown away without anyone knowing that there was an undesirable effect. In this respect, I think that undesirable effects are generally under-reported in products sold to lay people this way, but the website at least provides the best insight, or maybe also the pages of other large online shops.

I was asked to ignore all of these data or quote, where the requirement to do this (check the product websites for reviews and then use them) is clearly given. There are such requirements given in detail, but they relate more to equivalent products - the reference to databases was of no help here, as it is believed that this only refers to the national database with the recall reports, which I have already checked. However, there will be hardly any lubricants listed, that don't glide, but stick or cause skin irritation. I would have said, that this is due to the nature of such products and that individual reactions are not necessarily an incident and thus published in the national database. But nevertheless gives me information to improve my product or evalutate if I have missed a risk, which is the fundamental reason to perform the PSUR and thus is for me reason enought to check these product ratings.

So if anyone has a good reason (MDR or guidance citing), why such website product evaluations should be used for the PSUR, I would be very grateful :)
I would also be happy to hear your opinion on this or which data sources do you use for medical products for use by laypeople that are sold via discounters?
 

O'meara

Registered
So if anyone has a good reason (MDR or guidance citing), why such website product evaluations should be used for the PSUR, I would be very grateful :)
I would also be happy to hear your opinion on this or which data sources do you use for medical products for use by laypeople that are sold via discounters?

Hello Vetty007

The requirements for the PSUR lean more towards serious incidents than feedback, the best guidance on this is within MDCG 2022-21 that states "A list of collected data from other sources of clinical data in the post-market phase should be provided. Safety and performance data generated from these activities should be used also for comparison to other similar devices with the same intended purpose." and "All feedback from users, distributors and importers and complaints not reported in the Vigilance section"

As leaving feedback on social networks and product review pages is now standard practise these days I would suggest it would be hard to convince your NB that lots of negative feedback can be ignored because it did not come through your preferred communication channel. especially if you are selling an over the counter device used by the general public that are not familiar with vigilance reporting.

There is also the requirement so summarise PMCF data in the PSUR, PMCF requires much more in-depth data collection directly from the users and so I would argue this data is relevant as it is directly reported from the end user.

MDCG 2022-21 also states "Justification for inclusion of these groups of complaints and exclusion of those not presented" so weather the data is included or not you must justify the decision.

Your client stated the complaints were not serious enough to be reported to the retailer so can be ignored. I have had experience of my NB saying they did not believe we had received so few complaints and when I stated we only list the justifiable ones they replied ALL must be listed with the justification presented. Because the NB may not agree with your assessment of a serious or justifiable complaint.
 
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