PRRC: The 5 Responsibilities of the Person Responsible for Regulatory Compliance under MDR
This article is part of our series of MDR articles that look at the changes coming into play with the new medical device regulations. In this article, we are looking at the role of the Person Responsible for Regulatory Compliance (PRRC).
The role of QP is a familiar one for those working in the Pharma sector, but this is the first time in European medical devices legislation that a person is required to be appointed by a manufacturer to take specific responsibility for regulatory compliance of devices.
What Is The Role of The PRRC -The Person Responsible for Regulatory Compliance?
Article 15 of MDR 2017/745 sets out the detail of the person responsible for regulatory compliance. It requires that manufacturers shall have available within their organisation at least one person responsible for regulatory compliance who possesses the requisite expertise in the field of medical devices. Similar authorised representatives are required to have permanently and continuously at their disposal at least one person responsible for regulatory compliance. The requisite expertise is also detailed in Article 15 and involves either:
- a formal qualification such as a degree in law, medicine, pharmacy, engineering or other relevant scientific discipline and at least one year of professional experience in regulatory affairs or in quality management systems relating to medical devices o
- four years of professional experience in regulatory affairs or in quality management systems relating to medical devices
What are the responsibilities of the Person Responsible for Regulatory Compliance?
- The device conforms to the manufacturers quality system prior to release
- The technical documentation and EU declaration of conformity are properly maintained
- The post-market surveillance obligations are complied with including post market surveillance plan, post-market report and periodic safety update report as applicable
- The reporting obligations are fulfilled for serious incidents, field safety corrective actions and trend reporting
- The statement referred to in Section 4.1 of Chapter II of Annex XV is issued in the case of investigation devices
The Provision to Outsource PRRC
There is a provision within MDR that allows micro and small enterprises to outsource the PRRC role and to have an appropriately qualified person permanently and continuously at their disposal rather than having that person within their organisation. The definition of micro and small enterprises comes from Commission Recommendation 2003/361/EC and relates to number of employees and turnover/balance sheet figures. A small enterprise is defined as an enterprise which employs fewer than 50 persons and whose annual turnover and/or annual balance sheet total does not exceed EUR 10 million. A micro-enterprise is defined as an enterprise which employs fewer than 10 persons and whose annual turnover and/or annual balance sheet total does not exceed EUR 2 million. The outsourced PRRC must then be listed as a critical supplier on the manufacturers quality system and an agreement must be in place between both parties.
Managing the PRRC
Has your organisation considered how you will manage the role of the person responsible for regulatory compliance?
Are you a small or micro-enterprise looking to appoint someone external to your organisation to fulfill this role? Our experts are now assisting medical device companies of all sizes with their MDR readiness.
If you would like to talk to us today about how we might be able to assist you with getting ready for the MDR or if you would like us to act as your PRRC, then please do contact us today. Call us on 00353 52 61 76 706 or complete the form below.
Further MDR Reading from Acorn Regulatory
The clock is ticking for medical device manufacturers distributing in the European Union (EU). The EU is transitioning from the Medical Device Directive (MDD) to the new Medical Device Regulation (MDR). The updated European Medical Device Regulation (MDR) introduced in May 2017 has new, stricter criteria for CER (Clinical Evaluation) reports, such as the basis of establishing an equivalence with another device and the quality of data considered in your clinical evaluation.
We consider the 5 issues that you should consider when creating a Clinical Evaluation Report. Read the article here.
The date of application of MDR of 26th May 2020 has long been recognised as a very ambitious target by many in the medical devices sector. The pressure among stakeholders whether they be economic operators, notified bodies or competent authorities to be ready in time has been intense. The delay of Eudamed and the well-documented issues around capacity in the Notified Body network are just two examples of areas of difficulty in being ready for MDR implementation.
As part of our ongoing MDR series, we are looking at clinical investigations and how they will operate after the MDR has been introduced. We have written extensively on the MDR issues and at the end of this article, you can access our range of whitepapers and other articles that look at the changes that the new regulations will bring about.
Find out more about carrying out a clinical investigation under MDR here.