GROWTH – DEDICATED CALL – 1/00 TOPIC III.23 Biological Evaluation Of Medical Devices 1. CONFORMITY WITH THE WORK PROGRAMME This topic falls under the Competitive and Sustainable Growth Programme, generic activity Measurement and Testing. Specifically, it is related to Objective GROW-20006.3 support to the development of certified reference materials for which expressions of interest have been called. The project clearly meets two of the work programme’s three socio-economic objectives, i.e. mainly pre-normative research and technical support to standardisation, but also improvement of quality. The project clearly meets two of the work programme’s three objectives (6.2 and 6.3) through support to the development and validation of reference materials and generic measurement and testing methods which assist a) in the production of data defining performance, reliability, quality and safety requirements of medical devices, and b) with the provision of improved analytical services supporting mandated European standards and medical device Directives. 2. KEYWORDS Reference materials; standardised test methods; validation; biomaterials; medical devices; physico-chemical characterisation; mechancial characterisation; biological characterisation. 3. SUMMARY OF OBJECTIVES AND JUSTIFICATION Part 12 ‘Sample preparation and reference materials’ of the EN ISO series of standards 30993/10993 ‘Biological evaluation of medical devices’ specifies requirements and gives guidance on the use of reference materials for testing biological evaluation. There is a clear need for a supporting range of well-characterised reference materials, with known surface and bulk compositions, whose responses to appropriate biological environments are quantified and validated. The potential exploitation of medical device (bio)materials is restricted by problems associated with achieving reliable, consistent and quantifiable assessments of biological response. New and/or existing test methods need to be developed and/or standardised. Interested parties will then be able to demonstrate conformity with one or more parts of the EN ISO series. There are also further implications with respect to the new Approach medical device Directives 90/385/EEC and 93/42/EEC. DC 1/00/Topic III.23/ Pg 2 4. BACKGROUND In the late seventies, the United States reviewed progress in developing medical device materials and determined significant gaps in the understanding of blood-material interactions. Expert panels, established to define reliable approaches to this issue, emphasised the need for the production of reference materials for use as negative controls. By the mid-eighties, two materials had been fully characterised physicochemically. However, no associated biological evaluation was carried out. In Europe, CEN/TC 206 (Biological testing of medical and dental materials and devices) shadows most of the ISO work programme, and a limited number of potential reference materials have been identified for both in vitro and in vivo evaluation. Recent activities outside the CEN arena also offer the possibility of a very limited number of additional materials. However, the majority of these potential materials tend only to show a very severe, or no/minimal, biological reaction when tested. Few Member State institutions have yet truly recognised the importance of the role of both reference materials and standardised test methods as the means by which to further understand and develop effective and reliable materials and biological testing techniques. 5. ECONOMIC AND SOCIAL BENEFITS The end of 1992 saw the completion of the Single Market within the European Community (now Union) and with it the removal of all remaining trade barriers currently restricting free movement of goods. European standards are used increasingly and so there is a need to encourage accreditation of test laboratories and adoption by industry of certified quality systems. Reciprocal recognition of test data can only be achieved by increased co-operation between laboratories. Whilst the worldwide market for medical device (bio)materials has continued to rise from its estimated $12 billion in 1992 to an estimated $20-25 billion in 1998, the full potential of some biomaterials has been limited by the inability to achieve reliable, consistent and quantifiable evaluations repeatable both within, and between, laboratories. This problem has been specifically highlighted by both the biomaterials industry and Member States laboratories, and has already begun to manifest itself in the ‘failure’ of specific medical devices with corresponding large social and economic consequences. The presence of reference materials for biological evaluation will impact heavily on every other biological standard where the use of reference materials is to become essential. Rectification of the measurement problems related to this area will also help remove the direct economic significance associated with the means whereby problematic materials can pass successfully through existing procedures of approval. This will result in an increased cohesion of activity within the European Union and will address the imbalance with the United States. DC 1/00/Topic III.23/ Pg 3 6. SCIENTIFIC AND TECHNOLOGICAL OBJECTIVES A. To develop/supply well-characterised reference materials, of known surface and bulk compositions, whose responses to appropriate biological environments are quantified and validated. The reference materials should correlate with the shapes, forms and final treatments of related implants, bearing in mind the test method(s) in which they may have to be used. The reference materials should, wherever possible, cover the various major medical device (bio)material applications: it is envisaged that both ‘stable’ and ‘degradable’ materials will be supplied. Note: it should be noted that degradable materials represent a real challenge due to the continuous interaction between material and biological environment (and vice-versa), no steady state for evaluation of implant reactions being present. Candidate reference materials should be made available for interlaboratory trials with the validation data generated being supplied as data reports and/or certificates (ISO Guide 31) to a suitable office for future storage, distribution and sale of the reference materials, and provision of any associated support to standards. The reference materials and their producers should meet the requirements of the relevant ISO Guides 34 and 35. B. To develop and/or standardise appropriate test methods which fully characterise the physico-chemical, mechanical and biological evaluation of the selected reference materials. Note: this assumes that one generic method for each form of envisaged characterisation will be suitable for each type of reference material selected; it is likely that more will be required for full characterisation purposes. The physicochemical test methods should, wherever possible, be readily available in many laboratories, unless good justification is provided. The induced biological response(s) should neither be too severe nor too low. The test methods should be applicable to the appropriate biological environments of the selected medical device (bio)material end-use applications and be drawn, at least in the first instance, from the existing tests specified in the relevant parts of the EN ISO series of standards, unless good justification is provided. Test method results obtained for the reference materials should, wherever possible, be correlated with the observed material surface and bulk characteristics or other properties. DC 1/00/Topic III.23/ Pg 4 C. To disseminate the information. A suitable dissemination and technology transfer plan for the supplied reference materials and standard operating protocols should be provided. This shall at least include delivery of the project deliverables to the relevant CEN/ISO working groups through relevant national Committee members. 7. TIME SCALE The work is to be completed within 42 months of commencement of the project to allow for both the development and the lengthy validation process by interlaboratory comparisons. This would suggest mid-late 2004 as the project delivery date (allowing for the tender and contractual stages of the process). However, due to the envisaged separate components of the project, reflecting the differences in likely timescales for existing and new materials to be made available, it would be advantageous to submit the individual (certified) reference materials and test methods to CEN/TC 206 as they become available. 8. IMPORTANT ADDITIONAL INFORMATION Result format: The project deliverables shall be presented as (certified) reference materials in line with ISO Guides 31, 33-35 and as test methods in CEN format. They shall be ready for use by manufacturers, enforcement organisations and others to test for conformance to EN ISO 30993/10993 series, particularly Part 12. The methods shall include validation data produced during development. Restrictions: A minimum of three leading European organisations shall directly take part in the development of the (certified) reference materials and test methods. A minimum of five laboratories giving acceptable results shall take part in the validation exercises. Cost The estimated cost of the work to the Measurements and Testing sub-programme is 500,000 Euros. References EN ISO 30993/10993 series of standards, particularly Part 8 ‘Guidance on the selection and qualification of reference materials for biological tests’ and Part 12 ‘Sample preparation and reference materials’ (or preferably current draft revision of Part 12 which incorporates Part 8). European Market for Biomaterials: Perspective and Opportunities, Willems & Van der Wildenberg, 1992. ISO Guide 31 Contents of certificates of reference materials. ISO Guide 33 Uses of certified reference materials. ISO Guide 34 General requirements for the competence of reference material producers. ISO Guide 35 Certification of reference materials – General and statistical principles. DC 1/00/Topic III.23/ Pg 5 Addendum to the supporting document for all topics related to the development of Certified Reference Materials (CRMs) Introduction Research in support of the development of CRMs is an objective of the Growth Programme. The modality for this research is a shared cost action on RTD (cf work programme Competitive and Sustainable Growth). The guidelines for the submission of the proposal are laid down in the Guides for Proposers. In addition to the requirements for research on a specific topic that are laid down in the supporting document*, there are general requirements for the development of CRMs. These requirements are described below and are in addition to the general requirements for shared cost actions, as described in the guides for proposers and the model contract. The requirements have been divided in 2 major parts: I) Description of the work This part concentrates on the technical requirements of the research as well as the reporting requirements in view of the future certification. II) Implementation of the objectives of the research The research on CRMs consists of the development of the ability to produce and certify reference materials that are fit for purpose. The planned exploitation of the results has to aim at the production and certification of the reference material(s) in accordance with prevailing international quality standards. * The dedicated call system enables the Commission to identify priority topics that have been forwarded under the call for the expressions of interest. The supporting document that has been used to evaluate the topic now serves as a reference document to the proposers for the preparation of the proposal. DC 1/00/Topic III.23/ Pg 6 I) Description of the work Research on CRMs consists of the development of the ability to produce and certify reference materials. The actual production of the CRM is not part of the research but is part of the exploitation of the result(s). In the first phase of the research project the certification strategy should be elaborated (development of the materials and methods for characterisation), in the second phase of the research project the ability to produce and certify should be demonstrated and finally the specifications for the final CRM should be set. The development of a CRM normally consists of 4 major parts: 1) development of the know-how required to produce (and package) the future CRM 2) development of the methods needed for future certification of the material 3) demonstration of the feasibility of the CRM production (production of a small batch + mimicking its certification) 4) reporting of detailed and realistic specifications for the future CRM 1. Development of the know-how required to produce (and package) the future CRM specify the sort of material that is most likely to meet both the targets laid down in the supporting document and be suitably homogeneous, stable, safe to handle, and acceptable in cost identify the options available for selecting / preparing such a material take into account special storage and / or transport requirements existing for certain types of materials develop of methods for production / selection and preparation, homogenisation, stabilisation, protection and packaging of material as required, to enable the production of a CRM which will be fit for purpose if a material needs to be altered substantially (e.g. freeze drying), or when it is artificially spiked with the substance of interest, it is necessary to check if the material behaves in the same manner as the routine samples when applying the relevant methods of measurement. Ensure the availability of a suitable reconstitution procedure if a material will need reconstitution DC 1/00/Topic III.23/ Pg 7 2. Development of the methods needed for future certification of the material Certification can be performed according to different criteria. The research will define which certification route, following internationally recognised quality requirements and standards, will be followed. Certification on the basis of pure substances If the CRM is a pure substance the preparation methods should be such that the presence of impurities are reduced to a minimum. Additionally the substance should be tested for impurities by carefully selected methods at least in two laboratories. Certification on the basis of preparation data When dealing with a synthetic CRM and a quantity which is directly related to (or depends in a well-established way on) composition, examine if preparation under metrological conditions and certification on that basis (e.g. using gravimetric data) is possible Identify nevertheless a method of measurement that can be used as an independent check for large errors Certification on the basis of measurements - method-dependent quantities If the quantity to be certified is defined on the basis of a specific (standard) sample treatment or method of measurement, certification will be based on statistical processing of results produced by a sufficient number of laboratories (e.g. 12 - 15), which follow strictly the standard protocol but include all variability which is allowed by the protocol (do not use common sources of calibrants, reagents, ... unless these will be available to the future CRM users and prescribed in the protocol). Such protocol may have to be developed Work may be necessary to achieve an acceptable level of reproducibility Certification on the basis of measurements - method-independent quantities As error-free, matrix-independent, calibration-independent methods are exceptional, the basis for certification will usually be an agreement between different methods and different laboratories, applied under conditions of independence which rule out the risk of a common systematic error. Methods with a high potential for matrixindependence and/or calibration-independence (e.g. IDMS for determining polyisotopic elements) should be included if available it may be necessary to perform a substantial collaborative method improvement (to achieve the required level of agreement between methods and between laboratories), or even research (method development) to achieve the required ability to measure. Guidance for collaborative method improvement is given in the BCR Guidelines* * Guidelines for the production and certification of BCR reference materials, available from the Commission on request (E. Michel, tel: 32/2-295.11.33, fax: 32/2-295.80.72, email: ellen.michel@cec.eu.int ) DC 1/00/Topic III.23/ Pg 8 3. Demonstration of the feasibility of the CRM production prepare a small batch of material, similar to that intended to be prepared as a CRM, using the method intended to be used to prepare the actual reference material Check the fitness for purpose: form, shape or texture of the material; if applicable, contamination (air, moisture, vapours, dust and dirt, micro-organisms etc.) homogeneity stability (the analyte / measurand as well as the matrix) safety of packaging when exposed to shocks, extreme temperatures and other possible causes of damage during storage and transport ease of opening and use lyophilisation and reconstitution procedures Guidance for homogeneity and stability testing is given in the BCR Guidelines. Use the test batch to mimic the certification of a future CRM in a measurement campaign, designed as a certification exercise (see BCR Guidelines) If the results show that a CRM prepared and certified as in the test round is not good enough, then the development work (1. or 2. above) must be recommended 4. Reporting of detailed and realistic specifications for the future CRM The reporting requirements are set in the guidelines for reporting. In addition to the Final Technical Report the coordinator should prepare an overview of all the results, as foreseen in the Technical Implementation Plan. In this report the outcome of the research that sets the boundaries for the future CRM production should be given preferably in the form of a technical data sheet. It should contain the following information: form / type of samples (with preference for individually packed portions for single use) lyophilisation and reconstitution procedures specify bottling, labelling, packing, storage and transport requirements identify any legal restrictions on the transport of such material and need for safety labelling, collect data for material safety data sheets magnitude of the quantity of interest (acceptable range) acceptable uncertainty on the certified value for an individual sample (this includes at least: acceptable uncertainty on the mean value for the entire batch, and acceptable level of inhomogeneity of the batch) method requirements (if the CRM is method dependent) acceptable magnitude of other quantities an estimate of the quantity of CRM that should be produced as well as an estimate of the production costs. DC 1/00/Topic III.23/ Pg 9 II) Implementation of the objectives of the research As for all shared cost contracts the contractors are obliged to exploit the knowledge arising from the project. In the case of research on CRMs the contractors are, among others, obliged to assure that the CRM is produced and certified within a reasonable time limit (article 10 of Annex II General Conditions of model contract). The "Technological Implementation Plan" (TIP), which has to be prepared in any RTD project of the 5th Framework Programme, shall explain the actions planned to assure that results of the project will be exploited. In case of CRMs this TIP has to outline the strategy for the CRM production, certification and marketing within a reasonable time frame, at a reasonable cost and according to internationally recognised quality requirements. A draft TIP has to be available at the project midterm. Options, ranging from production by the consortium to production by a third party or the Commission, will be explored in consultation with the Commission Services.