The product is a dental cleaning powder and this is for 93/42/EEC.
One batch is around 60 tons, currently we are testing chemical analysis 1 bag/per batch only.
Is this sufficient?
Thanks for your reply.
Hi,
From a process control perspective it seems a bit too low to me, but I'd be curious to see what the statistics experts would say. I'd expect at least 3 samples from the batch - somewhere at the start, somewhere in the middle and somewhere towards the end.
From a regulatory perspective, the MDD essential requirements say:
7 Chemical, physical and biological properties
(...)
7.2. The devices must be designed, manufactured and packed in such a way as to minimize the risk posed by contaminants and residues to the persons involved in the transport, storage and use of the devices and to the patients, taking account of the intended purpose of the product. Particular attention must be paid to the tissues exposed and to the dura-tion and frequency of exposure.
"Manufactured" includes in-process monitoring & testing.
Since the requirement is quite general, it's up to you to show how your process complies. If there's a vertical standard covering this type of device, it might have something about testing or quality control (this specific area is not my expertise so I don't know if such a standard exists). Either way, you should address the issue in your risk management file (ie what is the risk level imposed by the current sampling / testing practice). At the end of the day it's really down to the details of the device, intended use and the manufacturing process.
Cheers,
Ronen.