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General Safety and Performance Requirements (GSPR)

The essential requirements (ER) are the key elements to compliance with MDD and AIMDD. The new regulation EU MDR replaces the essential requirements (ER) by general safety and performance requirements (GSPR).

 

This means the manufacturers must demonstrate conformity with the general safety and performance requirements and other legal requirements, such as those relating to quality and risk management, laid down in this Regulation.

 

General safety and performance requirements (EU MDR) are almost similar to Essential Requirements (MDD), there are some additional requirements and some expanded requirements, and some new topics are introduced in GSPR.

 

For example, Risk-benefit ratio, devices incorporating materials of biological origin, devices without a medical purpose, laypersons use additional requirements in labels, etc.

Know more about IVDR GSPR >>

MDR GSPR

Relevance of GSPR in MDR CE Marking

It should be noted that once a Notified Body is recognized by a Competent Authority, they will be recognized by all the other competent authorities to perform conformity assessment of products for the entire EU. So, a notified body will be notified by only one Competent Authority.

Main Requirements of GSPR

The requirements of GSPR is covered in Annex I of MDR with 3 chapters.

  • Chapter 1 – General requirements
  • Chapter II – Requirements regarding design and manufacture
  • Chapter III – Requirements regarding the information supplied with the device

Major Topics of GSPR in MDR and changes from ER in MDD

The below shows the major topics covered in GSPR

Chapter I - General Requirments.

Clause number 1 to 9 of MDR and Clause Number 1 to 6 in MDD explains the general requirement.

 

  1. Performance and Safety
  2. Reduction of risk
  3. Risk Management System
  4. risk control measures and residual risks
  5. risks related to use error
  6. Performance and lifetime of the device
  7. The characteristics and performance are not adversely affected during transport and storage,
  8. Risk Benefit Ratio- All known and foreseeable risks shall be acceptable when weighed against the benefits to the patient and/or user.
  9. Devices without medical purpose

 

In chapter 1 of MDR some of the additional requirements are risk benefit ratio, special importance to state of art, usability- clause 2 to 5, devices without medical purpose clause 9.

Chapter II - Requirements regarding Design and Manufacture

Clause number 10 to 22 of MDR and Clause Number 7 to 12 in MDD explains the requirements regarding design and manufacture.

 

  1. Chemical, physical and biological properties,
  2. Risks from Contaminants & Residues
  3. Compatibility with Materials & Substances
  4. Substances contained in & Released from the Device
  5. Infection & Microbial Contamination
  6. Devices incorporating a medicinal product or substances absorbed by the human body,
  7. Devices incorporating materials of biological origin,
  8. Construction of devices and interaction with their environment,
  9. Devices with a diagnostic or measuring function,
  10. Protection against radiation,
  11. Electronic programmable systems and software,
  12. Active devices and devices connected to them,
  13. Particular requirements for active implantable devices,
  14. Protection against mechanical and thermal risks,
  15. Protection against the risks posed to the patient or user by devices supplying energy or substances
  16. Protection against the risks posed by medical devices intended by the manufacturer for use by lay persons

 

In chapter II of MDR some of the additional requirements are Chemical, physical and biological properties, Justification regarding the presence of CMR and/or endocrine-disrupting substances, Infection & Microbial Contamination, Devices incorporating a medicinal product or substances absorbed by the human body and Risks of Interaction with the Environment- explosion, radiation, connection/ compatibility Maintenance/ Calibration, Disposal protection from radiation, Electronic Programmable Systems & Software, Active devices and devices connected to them,

Chapter III - Information Supplied with the Device

Clause number 23 of MDR and Clause Number 13 in MDD explains the information supplied with the device.

 

  1. General requirements regarding the information supplied by the manufacturer,
  2. Requirement of information on the label,
  3. Sterile package label requirements,
  4. Information in the instructions for use.

In chapter III of MDR some of the additional requirements are UDI, unambiguous time limit for using/implanting safely, electronic IFU, sterile package label requirements, Labels- human-readable format and may be supplemented by machine-readable information, such as radio-frequency identification (‘RFID’) or bar codes.

GSPR in MDR Technical Documentation / Technical File
US FDA Approval

The manufacturers are supposed to show the evidences of fulfilment of general safety and performance requirements. For this purpose, a checklist for general safety and performance requirements can be made and thus give the justification / records or evidence or a summary of how the requirements are fulfilled of each clause.

 

In the check list clearly mention the below points,

  • Mention the international standard (preferably harmonized) or the Common Specification (CS) applicable.
  • Evidence and summary of how the requirements are fulfilled and demonstrate the conformity with the GSPR. The location of evidence or the records and the supporting documents.
  • Method selected to demonstrate the conformity with GSPR.
  • Justification for the clause is not applicable or not performed, if any.
  • The quality management system should provide the evidence to support relevant GSPR clauses,
  • Verification and validation reports.

Ways to Demonstrate Conformity through GSPR
US FDA Approval

  • The most common way is the use of harmonized standard and use of common specification. For example, use of EN ISO 14971, EN ISO 13485, EN ISO 60601, EN ISO 1223 etc.
  • Clinical evidence,
  • A detailed Risk analysis
  • Relevant certifications or performance test reports complying to any internationally accepted standards,
  • The quality management system should provide the evidence to support relevant GSPR clauses,
  • Verification and validation reports.

MDR GSPR Checklist : 300 USD

Template ID : MDR-GSPR-01




General Safety and Performance Requirements 1

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