Although these digital IFU are allowed, MD and IVD manufacturers are still obliged to provide an alternative means so clients can obtain paper copies on request. Qarad’s free telephone service guarantees quick and efficient handling of these requests without any burden to the manufacturer.
In Qarad’s experience, manufacturers prefer a website over CD or USB as it is the most accessible option. However, simply allowing digital IFU to be downloaded from a website is not sufficient. One of the most challenging requirements for a compliant eIFU solution is the obligation on a manufacturer to be able to provide their customers with paper copies of IFU on request, free of charge and within a specific timeframe.
Although there are some differences between the requirements for either medical device or IVD manufacturers to fulfill such requests, it is equally challenging.
The MEDDEV rules for IVDs state that a free telephone contact number must be provided so that customers can ask for copies of IFU over the phone. These should then be sent to them via fax, by email or post in ‘a timely manner’.
The MD regulation is more flexible on how that free copy can be requested. It only mentions that a system should be in place, but it does not specify a preferred method for how clients can request paper copies.
However, the regulation for MD is more restrictive when it comes to a deadline when the paper copy should reach the customer. It clearly states that IFUs must be provided either with the order at the time of delivery, or within seven calendar days if the customer asks for it post-order.