Published on October 25, 2007
Classifying your IVD: Classifying your IVD Robyn Wood Medical Devices Assessment Section Office of Devices Blood and Tissues Risk Associated with IVDs: Risk Associated with IVDs Risks of IVD to patients and users can range from little or no risks to patients and users significant potential risk Hence the level of regulation should be proportional to the level of potential risk, taking account of the benefits offered by the device Risk based classification system based on GHTF guidelines How Potential Risk is Determined: How Potential Risk is Determined the intended use and indications as specified by the manufacturer Specific disorder, condition or risk factor for which the test is intended The technical/ scientific/ medical expertise of the intended user eg lab testing vs home use How Potential Risk is Determined: How Potential Risk is Determined The importance of the information to the diagnosis Sole determinant or one of several The impact of the result (true or false) to the individual and/or to public health How Potential Risk is Determined: How Potential Risk is Determined These guidelines are encompassed in a set of classification rules Rules classify all IVD into 4 different classes The rules are capable of accommodating future technological developments These mirror GHTF rules Why Classify?: Why Classify? The purpose of classification rules is to determine the level of regulatory oversight required The class of device determines the conformity assessment procedure Slide7: Class I no public health risk / low personal risk Class 2 low public health risk / moderate personal risk Class 3 high personal risk / moderate public health risk Class 4 high public health risk Class 1: Class 1 Devices in this class represent no public health risk, or low personal risk Lab equipment intended for use in IVD testing Eg HPLC, automated differential cell counter Culture media Class 2: Class 2 Devices in this class represent a low public health risk, and moderate personal risk Includes those IVD that detect the presence or exposure to infectious agents not easily propagated in Aust and NZ Cause self-limiting disease Not used exclusively in a diagnostic setting An erroneous result rarely puts the individual in immediate danger Class 2: Class 2 Devices in this class represent a low public health risk, and moderate personal risk Includes sodium, ALT, lactic dehydrogenase, ferritin or folate, computerised cervical cytology, tests for Epstein Barr virus, autoimmune tests, and genetic tests for thrombophilia mutation screening, Anti-DNA Abs, Anti-ENA Abs, Anti-GAD Abs, Anti-IAZ Abs, Abs for diagnosing Coeliac disease, Cardiolipin antibodies, anti-TSH receptor, AMA. Class 3: Class 3 Devices in this class represent a moderate public health risk, and high individual risk Includes those IVD that detect the presence or exposure to infectious agents that are easily propagated in Aust and NZ An erroneous result may have a major negative impact on outcome Where the IVD provides the critical or sole determinant for a correct diagnosis Class 3: Class 3 moderate public health risk, high individual risk Includes IVDs used for tests for diseases on the NZ Notifiable Diseases schedules and the Aust Notifiable Diseases list, eg SARS Blood and tissue screening in selected populations. Examples: tests for CMV, malaria, West Nile Virus, Parvovirus B19. Class 3: Class 3 moderate public health risk, high individual risk Includes Detecting the presence of, or exposure to, a serious sexually transmitted agent. Such as Chlamydia trachomatis, Neisseria gonorrhoeae etc. Detecting the presence in cerebrospinal fluid or blood of an infectious agent that constitutes a significant public health risk. Examples: Neisseria meningitidis or Cryptococcus neoformans. Determining infective disease status or immune status, and where there is a risk that an erroneous result will lead to a patient management decision resulting in an imminent life-threatening situation for the patient. Example: Influenza, Haemophilus influenzae B Class 3: Class 3 moderate public health risk, high individual risk Includes Detecting the presence of an infectious agent where there is a significant risk that an erroneous result would cause death or severe disability to the individual or foetus being tested. Examples: Toxoplasma, Varicella Zoster Virus. Screening pre-natal women in order to determine their immune status towards transmissible agents. Examples: Rubella. Class 3: Class 3 moderate public health risk, high individual risk Includes Screening for, or in the diagnosis of, cancer, including cancer staging, where initial therapeutic decisions will be made based on the outcome of the test results. Predictive genetic screening, when the outcome of the test would ordinarily result in a substantial impact on the life of the individual. Examples: Guthrie test for phenylketonuria, Huntington’s Disease, Cystic Fibrosis. Class 3: Class 3 moderate public health risk, high individual risk Includes Monitoring levels of medicines, substances or biological components, when there is a risk that an erroneous result will lead to a patient management decision resulting in an immediate life-threatening situation for the patient. Examples: Cardiac markers, cyclosporine, prothrombin time testing, digoxin, paracetamol, Gentamycin, Tobramycin, potassium, calcium, troponin, glucose, taerolimus, serolimus Class 4: Class 4 Devices in this class represent a high public health risk, and high individual risk Includes all IVDs used for universal screening of the blood supply and organ and tissue donations for pathogens HIV, HCV, HBV, Syphilis, HTLV Includes IVDs for these agents used in a diagnostic role IVDs for these agents intended only for monitoring are captured under a separate role - are Class III Class 4: Class 4 high public health risk, high individual risk Includes IVDs with an intended function of detecting agents used in biowarfare eg anthrax Includes high risk blood grouping tests ABO, rhesus, anti-Kell Points to remember: Points to remember The manufacturer is responsible for applying the classification rules The classification rules are based on the manufacturer’s intended purposes and in some cases, more than 1 rule may apply If this happens the higher classification applies Points to remember: Points to remember The classification must be consistent with the information accompanying the IVD including the label, directions for use, brochures and operating manuals If the intended purpose is not clear, the Joint Agency will assign an intended purpose consistent with purpose generally accepted in clinical practice Points to remember: Points to remember Calibrators and control materials intended to be used with an IVD reagent should be treated in the same class as the IVD itself Software intended to drive or influence the use of the IVD falls under the same classification as the IVD Questions?: Questions?