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Latest Updates on
Medical Device Regulations in Korea
November 2013
Synex Consulting Ltd.
Seoul, Korea
Young Kim
About Synex
Descriptions Features
Business Consulting company
specialized in healthcare
market access
Established April 2002
Employees 60 full-time employees
Expertise Market Entry Issues
Customer
Industry
Medical device
In-vitro diagnostics
Pharmaceutical
Biologics
Service
Sectors
Regulatory
Device Qualify System
Reimbursement
Clinical Research (CRO)
Market Research
Distribution Set-up
Marketing Compliance
2 © Synex Consulting, Ltd. November 2013
• Korea as a medical device market
• Medical device approval process
Topics
© Synex Consulting, Ltd. November 2013
Korea
as a Medical Device Market
Geography, Population and Economy
Population (2012, Korea Statistics Office)
- 50 million
- 26th Largest population in the world
largest country in the world)
- cf. The Netherlands 16.7 million
- Average life expectancy at birth: 79.1
-Median age: 38
–Increasing Elderly Population
•+65 population: 5.4 million (11.3%
of total population)
Land Space
-98,480km2 (South Korea)
- cf. The Netherlands 41,526㎢
Economy (2012, IMF Estimates)
-GDP per capita: US$23,679
-34th in the world ranking - cf. The Netherlands $41,447
5 © Synex Consulting, Ltd. November 2013
Market Size
KOREA
• The 13th largest market in the World in 2012
• World medical device market in 2012: US$307,735 million
• The 3rd largest market in Asia following
China
• 1.3% of the world device market
Year 2012 US$ millions % Changes
from 2011
Total Market 4,290 Up 6.23%
Local Production 3,656 Up 15.18%
Export 1,966 Up 17.56%
Import 2,600 Up 3.17%
Device Trade Deficits 634
Ranks
Countries US$ Million World
Market Share
1 USA 120,397 39.1%
2 Japan 31,496 10.2%
3 Germany 23,256 7.6%
4 China 13,956 4.5%
5 France 13,315 4.3%
6 UK 8,934 2.9%
7 Italy 8,417 2.7%
8 Canada 6,372 2.1%
9 Russia 5,456 1.8%
10 Spain 4,695 1.5%
11 Australia 4,443 1.4%
12 Brazil 4,417 1.4%
13 Korea 4,075 1.3% 6 © Synex Consulting, Ltd. November 2013
Supply Portfolio: Import vs. Domestic Products
• Imports
• Supply around 60% of supply of medical devices
• Expensive, high-tech devices are mostly supplied by the U.S., EU and Japan.
• Inexpensive, low-tech devices (Class 1, II devices) are increasingly supplied by imports from, e.g., China
• Local manufacturers
• Supply mid-tech devices, mostly Class II devices
• Rapidly improving quality of products and expanding their export markets.
• Korean government is continuously increasing its public R&D grants to support local development of medical devices. Local manufacturers are expected to expand their positions in the market in a longer term.
7 © Synex Consulting, Ltd. November 2013
• 3,528 device business firms (2011) • 1,958 manufacturers • 1,570 importers
• 6,000-7,000 new products approved every year.
Device Suppliers
2006 2007 2008 2009 2010 2011 2012
Notification 3,131 3,604 3,437 3,631 4,341 3,585 3,881
Approval for manufacture 1,008 731 950 1,067 1,312 1,413 1,604
Approval for import 1,355 1,167 1,274 1,362 1,354 1,486 1,496
0
500
1,000
1,500
2,000
2,500
3,000
3,500
4,000
4,500
5,000
8 © Synex Consulting, Ltd. November 2013
Geographical Distribution of Business
• The five largest cities represent
about 60% of total hospital beds in
the country
• Seoul and Kyonggi ( around 38%)
• Pusan (around 9%)
• Daegu (around. 5%)
• Kwangju (around 4%)
• Daijeon (around 4%)
• The Seoul and Kyonggi areas
(called ‘Seoul Metropolitan Area)
represent about 60% of the
imported high technology medical
device market.
Copyright © Synex 2009, All Rights Reserved 9 9 © Synex Consulting, Ltd. November 2013
Healthcare Resources (2011)
• Healthcare Organizations
– University hospitals (tertiary centers): 44
– Medium-size general hospitals: 275
– Small-size hospitals: 2,403 (1,005:Geriatric hospital)
– Clinics: 27,996
– Dental hospitals & offices : 15,409
– Oriental hospitals: 12,686
• All healthcare organizations are reimbursed
by public health insurance in Korea
10 © Synex Consulting, Ltd. November 2013
Supply Portfolio: Import vs. Domestic Products
• Imports
• Supply around 60% of supply of medical devices
• Expensive, high-tech devices are mostly supplied by the U.S., EU and Japan.
• Inexpensive, low-tech devices (Class 1, II devices) are increasingly supplied by imports from, e.g., China
• Local manufacturers
• Supply mid-tech devices, mostly Class II devices
• Rapidly improving quality of products and expanding their export markets.
• Korean government is continuously increasing its public R&D grants to support local development of medical devices. Local manufacturers are expected to expand their positions in the market in a longer term.
11 © Synex Consulting, Ltd. November 2013
End-User Characteristics • The five super-size hospitals targeted for door-opening centers
for new health technologies • Asan Medical Center (AMC) – 2,600 beds
• Samsung Medical Center (CMC) – 2,000 beds
• Seoul National University Hospital (SNUH) – 1,600 beds
• Yonsei Medical Center (YMC) – 1,880 beds
• Catholic St. Mary’s Hospital (CMC) – 1,200 beds
• Doctors • Highly receptive to new technologies
• Doctors at teaching hospitals are mostly trained in the U.S. and they attend almost all international academic conferences
• Most influential on purchasing decisions
• Patients • Highly receptive to new technologies
• Look for hospitals offering latest therapies with advanced equipment
12 © Synex Consulting, Ltd. November 2013
Public Health Insurance System
• National Health Insurance (NHI)
– The sole national insurer in Korea
– Ministry of Health and Welfare (MOHW) operates the NHI system
– All income-earning citizens must contribute a certain percentage of income
every month.
– 5.89% for corporate employees for 2013
– All hospitals and clinics must be reimbursed by the NHI reimbursement plan.
– Free access to healthcare organizations with no geographic limits
– Patients co-pay 20-50% of the published amount of fees for covered services
or products
• Patients pay full costs for uncovered services or products
• Elderly long-term insurance created to support senior citizens
13 © Synex Consulting, Ltd. November 2013
Steps to Korean Market
Select a distributor
or third-party license
holder
Regulatory
Approval
Reimbursement or
non-reimbursement
Approval
Launching
• A Korean legal entity is needed
A license-holder must be a Korean company to
which MFDS grants an import approval.
• All devices are required for pre-market
listing or approvals
No medical devices exempted from pre-market
processes
• Disposables or implanted devices are
mostly reimbursed by government
Devices unreimbursed by government still
must submit an application to government to
get an official announcement as a
unreimbursed item and thus a full patient
charge
14 © Synex Consulting, Ltd. November 2013
Medical Device Approval Process
• Headquartered in O-Song, Chungbuk
- 120 km South of Seoul, capital city of Korea
Ministry of Food and Drug Safety (MFDS)
Seoul • MFDS makes policies
• Its sub-agency called National Institute
of Food & Drug Safety Evaluation
(NIFDS) provides technical reviews on
individual applications
16 © Synex Consulting, Ltd. November 2013
Responsible Offices
17
Cardiovascular Device
Division
Orthopedic & Rehabilitation
Device Division
Oral & Digestive Device
Division
High-Tech Device Division
Medical Device Policy
Division
Medical Device
Management Division
Medical Device Quality
Division
In-Vitro Diagnostics Task Force
Medical Device Safety Bureau
Medical Device Evaluation Dept.
Ministry of Food &
Drug Safety (MFDS) National Institute of
Food & Drug Safety Evaluation
(NIFDS)
17 © Synex Consulting, Ltd. November 2013
Device Classifications
Class
4 Classes based on level of risk
Classification
2,202 Classification including 64 IVD and 16 u-healthcare
device
A full list of product groups and classes are available publicly.
Upcoming Change in 2014! -IVD has been regulation as medical device since 2011 July
- Some manual IVDs regulated as pharmaceutical products currently
(e,g. Pregnancy test kit),
- All IVDs will be regulated as medical device in 2014 except DNA chip and IVD with
radiopharmaceuticals
18 © Synex Consulting, Ltd. November 2013
Pre-market Approval Pathways
Class I
Designated
equivalent product
E-listing to MFDS
Database
MFDS
Review times
Equivalent Product
Novel Product
Technical
Document Review
Technical &
Clinical Document
Review
Class II Technical document
review by third party
review body
Class
III & IV
10 days
• Regulatory pathways determined by class and similarity to
previously approved devices
10 days
80 days
65 days
80 days
25 days
No review
(1-2 months)
(Total timeframe
recommended for company)
(2-3 months)
(3-5 months)
(7-9 months)
(5-7 months)
(7-9 months) 19 © Synex Consulting, Ltd. November 2013
Pre-Market Processes for Class II, III, IV
Importer in Korea
Technical Documents
Review by MFDS
KGMP Certification to
Manufacturing Site by
MFDS
Ready to Sell
Certificate of product
approval by MFDS
Ready to Import
In case importer
and manufacturing
site already
KGMP-certified,
In case the
importer
or
the manufacturing
site is not KGMP-
certified, Upcoming Change in 2014!
KGMP certification must be
completed before product
approval.
20 © Synex Consulting, Ltd. November 2013
Information required for Technical Document
No. Information or test reports
0 Comparison chart to determine substantial equivalency
1 Purpose of use/Product specification /Picture /Drawing
2 Physicochemical properties with test report
3 Electromechanical safety test report
4 Biological safety test report
5 Radiation safety test report
6 Electromagnetic interference test report
7 Performance test report
8 Stability test report
9 Discovery or development processes
10 Clinical study reports
11 Information on uses in other countries, etc.
21
Information requested varies depending on class, regulatory pathway
and product characteristics
© Synex Consulting, Ltd. November 2013
Work Scopes of Third Party Organizations
Organization
Technical
documents
review for class
II devices
KGMP
certification Local testing
Korean Testing Laboratory (KTL) O O O
TUV SUD O X X
Korea Testing Certification (KTC) O O O
Korea Conformity Laboratories
(KCL) O O O
Korea Testing & Research
Institute (KTR) O O O
SGS Korea O X X
22 © Synex Consulting, Ltd. November 2013
• Tests should be selected and conducted against MFDS standards
or recognized international standard, such as ISO
• Test report qualification for biological test
– GLP Test report by GLP certified lab
– ISO 10993
• Test report qualification for Electrical Safety or EMC test
- CB Test report by CB certified lab
- Upcoming change in 2014!
- Requirements for the third edition of IEC 60601-1 to be introduced
• Test report qualification for performance and stability
- ISO 13485-certified manufacturers’ labs
23
Acceptability of Foreign Test Reports
© Synex Consulting, Ltd. November 2013
• No local clinical study is necessary, if foreign clinical reports are convincing for approval
• MFDS has the right to ask for a local clinical study
• Four criteria for accepting clinical reports
• Clinical studies conducted in Korea
– Studies conducted by Korean hospitals designated by MFDS
• Foreign studies
– Reports published in medical journals
– MFDS determines whether studies were conducted according Korean GCP standards
– Clinical information reviewed and approved by OECD country authorities
• Proposed Changes
• MFDA plans to require clinical reports on 68 product groups of class IV devices in 2014.
• Foreign clinical reports are acceptable, but a study should have been conducted with the exact device applied for approval
24
Clinical Reports
© Synex Consulting, Ltd. November 2013
• A new process introduced on April 2012
• Importer (license-holder) applies to MFDS for KGMP
certification
• MFDS reviews quality system of foreign manufacturer
through documents review or site audit
• Certified separately to 26 categories
• KGMP certificate is provided to importer
• Importer’s role is limited as applicant for KGMP audit
on foreign manufacturer and quality control after
importation
• Must be renewed every three years
KGMP Certification to Foreign Manufacturer
25 © Synex Consulting, Ltd. November 2013
Pathways for KGMP certification
Class Manufacturing
site new to Korea
Adding new product
groups to an already
certified
manufacturing site or
a manufacturing site
change
Renewal
of KGMP certificate
Class 1 Document Review
Document Review
Document Review
Class 2 Site Audit by Third
Party Inspector
Document Review
Class 3 Site Audit by Third
Party Inspector and
MFDS
Site Audit by Third Party
Inspector
Class 4 Site Audit by Third Party
Inspector and MFDS
26 © Synex Consulting, Ltd. November 2013
• Length of Inspection Days: 3-5 days
• Number of GMP Inspectors: 2-3
– Third-party inspectors : 1
– MFDS inspectors : 1~2
• Language at on-site inspection: Korean
– Interpreter should be arranged.
– Language problems may significantly influence the results.
• Cost
– Application Fee : 1,400-1,700(US$)
– Travel costs (for site inspection): 5,000~7,000(US$) per
inspector including air fares, accommodation, per diem
KGMP to Foreign Manufacturer Site inspection
27 © Synex Consulting, Ltd. November 2013
Document requested for KGMP Certification
Overview of manufacturer
Number of quality-related staff members
List of medical devices manufactured by the manufacturer
Copies of certificates from other quality systems
Summary of manufacturing facilities
Information on outside vendors
Inspection records from other competent authorities
Copies of quality manuals (including quality policies)
Device master file for the respective product (including processes for sterilization,
software validation, etc.)
Relevant manuals for products requiring installation or after-sales support
Device master file of a representative product (for periodical re-certification only)
Checklist prepared by importer(upon periodical re-certification only)
28 © Synex Consulting, Ltd. November 2013
Post-Market Programs
• Five PMS Programs
• Tracking
• Re-evaluation through PMS study
• Adverse event / safety alert reporting
• Recall
• Re-examination
29 © Synex Consulting, Ltd. November 2013
Upcoming Changes in 2014
• IVD – All IVDs will be regulated as medical device in 2014 except DNA chip and IVD with
radiopharmaceuticals
• KGMP certification must be completed before product approval
Product Approval
KGMP Certification to
Manufacturing
Product Approval
Application
KGMP Certification
Application
2014
Product Approval
Application
KGMP Certification
Application
Product Approval
KGMP Certification to
Manufacturing Site
30 © Synex Consulting, Ltd. November 2013
Upcoming Changes in 2014
• STED for Class IV devices
– Submission of STED (Summary Technical Document) is required
for Class IV approval beginning January 2014
• IEC 60601-1 3rd edition to be implemented
• Clinical reports are required for 68 device groups
– Clinical report is accepted only in case clinical investigation is
conducted with the exact device
• Unique Device Identification (UDI) should be implemented on all
tracked devices
• Hospitals required to notify recalls to patients
31 © Synex Consulting, Ltd. November 2013
For further information, please contact:
www.synex.co.kr
10th Floor Daejong Building
143-48, Samsung-dong, Gangnam-gu
Seoul 135-601, Korea
Phone 82-2-6202-3300
Fax 82-2-2040-6250
Thank you!