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ABHI Code of Business Practice. Mike Kreuzer Director Technical & Regulatory - ABHI. International Medical Device Compliance Congress Paris May 2008’. ABHI Code of Business Practice. In 2005 ABHI ‘recommended’ that members adhere to the EUCOMED Code of Practice
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ABHI Code of Business Practice Mike Kreuzer Director Technical & Regulatory - ABHI International Medical Device Compliance Congress Paris May 2008’
ABHI Code of Business Practice • In 2005 ABHI ‘recommended’ that members adhere to the EUCOMED Code of Practice • It was assumed that enforcement was EUCOMED’s responsibility • The issue was extensively debated in EUCOMED in 2006 • 2007: the need for a ABHI complaints adjudication procedure was accepted • Adherence to the Eucomed CoBP is now a condition of ABHI membership International Medical Device Compliance Congress Paris May 2008’
Proposed Way Forward for ABHI • UK favours self-regulation • Two existing enforcement models were considered • SDMA costs c.£ 1-3k pa – PMCPA c.£750k • ABHI needs to start modestly using SDMA model • BUT with one significant change • Panel must be fully INDEPENDENT International Medical Device Compliance Congress Paris May 2008’
Panel of Experts • Panel chair should have a legal background • Independent panellists to be recruited e.g. HCPs • ABHI DG or nominee on panel as observer • Panellists to be chosen by ABHI Council International Medical Device Compliance Congress Paris May 2008’
Complaints Process • Panel to clarify and interpret • Will not have investigative powers • No appeal process (cost) International Medical Device Compliance Congress Paris May 2008’
Other Considerations International Dimension • There will be cross-border issues • Eucomed MUST put their own enforcement in place • This should evolve into an appeals mechanism International Medical Device Compliance Congress Paris May 2008’