Be prepared for regulatory demands

The European Medical Device Regulation comes into effect on May 26, 2021. Here’s how we prepared for it.

Please read carefully the following 9 main points concerning our final preparations for the MDR era

  • Medical devices vs mere components
  • Medical product families
  • CE-marking and declarations of conformity
  • Labelling
  • Instructions for use
  • Training concept
  • Competent persons
  • Maintanence
  • Distributorship agreement

As you know, functionality and quality have been two core values of Rehadapt products. As the MDR will soon be enforced most products in our portfolio – while not deemed medical devices themselves – are accessories for medical devices and shall comply with the same regulations and abide by the same standards are medical devices. Assuring regulatory compliance was the reason behind restructuring our wheelchair mounts, our emphasis on training and step-by-steps videos, and our recent EN ISO 13485:2016 certification.

Medical devices vs mere components

All Rehadapt products deemed medical devices comply with the regulatory demands of Class I and nothing changes in the way they are purchased and handled. However a lot of effort has been put into our internal files (technical documentation, risk analysis, clinical records, post-market surveillance, etc.). These medical devices are complete mounting solutions with a well-defined intended purpose. This is where they differ from single components.

Our products are well-known for their modularity, and you can use these components not only for replacing parts in existing mounts but also for building mounts from scratch.

Modifying a medical device is strongly discouraged by the MDR. Yet while replacing a component (e.g. swapping a tube for a shorter one) is in fact a modification, it does not affect the intended purpose and can be done when there is no other option. Furthermore, our tests and risk assessments have shown that slightly modified tube lengths, as long as in the standard scope of our offered components, do not jeopardize safety and efficiency of the entire product.

However, when building a mount from a set of loose components, you are “creating a medical product” and become the manufacturer (with all the responsibilities that it entails).

Now let’s talk about specific details and regulatory requirements our products now meet.

Medical product families

Rehadapt products deemed medical devices can be grouped into 6 so-called product families. Each of which with its own Basic UDI-DI.

Product family Basic UDI-DI:
Wheelchair Mounts ++B896WheelchairMountsQB
Floorstands ++B896FloorstandsK5
Table mounts ++B896TableMountsTC
Wall mounts ++B896WallMountsUR
Frame clamps ++B896FrameClampsK3
Keyguards ++B896KeyguardsVW

All individual products included in these product groups have their own UDI-DI, as listed on the table attached.

CE-marking and declarations of conformity

Rehadapt medical devices manufactured from May 26, 2021 will bear the CE-Marking. This means the declarations of conformity for these product families are available upon request.

Labelling

Rehadapt medical devices can be easily identified as such by the MD symbol on the label. These new labels are compliant with the labelling requirements from the FDA and MDR.

Among other things they include the CE Marking of Conformity and the UDI in both human- and machine-readable manner.

See the representative example of Rehadapt labels for the Floorstand Mini on the right.

Instructions for use

The instructions for use for Rehadapt’s medical devices consist of 2 parts:

  1. Assembly and handling instructions, which is merely graphical and is therefore independent from any language. Important information in this booklet or leaflet includes the scope of delivery and technical reference (when appropriate).
  2. General safety instructions and warnings, which are translated into the official languages of all Member States where our devices are currently sold. This includes important information such as the intended purpose, glossary of symbols, maintenance and servicing guidelines, general cleaning and disinfection guidelines, warranty policy, etc.

Please make sure to read these documents carefully and forward them to end users and professionals who handle the products.

You will find the instructions for use of the floorstand mini (14.1100) attached. This is a representative example for the scheme we use with all instructions. All our assembly and handling instructions will be gradually changed to match this template.

Training concept

We are introducing a new remote training concept. It consists of a personalized course with our sales team and a kit with all the parts needed for a hands-on experience. Practicing your mounting skills has never been as easy and can be done from home.

Contact our sales team if would like to know more.

Competent persons

It is important that the persons laying out a mounting solution for a customer are well trained. Installing the mount initially also requires some basic knowledge. We have frequently been asked whether the installation procedure necessarily has to be done by a trained advisor or a service technician.

The planning advisors know the environment parameters and should be able to judge the competencies of the caregivers or healthcare professionals involved. They may come to the conclusion that with proper instructions an installment can be done remotely, without the advisor or technician being on site.

Rehadapt does not generally oppose this, we just want to point out that it is your responsibility to make sure the involved persons are properly instructed.

Maintenance

You will notice on the general safety instructions that we recommend regular servicing every two years. Maintenance sheets will be made available for download on our website. Stay tuned to our newsletter for more information about this.

Distributorship agreement

Finally and to keep in line with this string of documentation, we have drafted a distributorship agreement that you can also find attached. We invite you to read it carefully and we will approach you personally in the next coming weeks in order to bilaterally sign it. This is necessary to document that we mutually fulfil all regulatory demands, it serves both your organization as well as ourselves.

Please address any questions around the agreement to our sales team.

Certified for your benefit

We are proud to announce that we are the first company in our field to be compliant with the ISO 13485 standard!

We are facing a difficult situation due to the global pandemic. So many things that we have taken for granted are now at risk and we certainly don’t want to add the risk of not meeting regulatory demands.

At the same time we constantly want to improve the quality of our products and services to ensure we not only meet but exceed our customers’ expectations.

This means our products fulfill not only the higher standards of quality but also the regulatory requirements for medical devices.

Find out more about how regulatory compliance affects Rehadapt’s portfolio and represents your advantage by ensuring safety and a superior quality level throughout the entire life cycle of your personal mounting solution.

Rehadapt & regulatory compliance

The medical device regulation (MDR) of the European Union and the upcoming requirements of the FDA (the US regulatory body) elevates Rehadapt products to a new

level of quality and reliability. Find out more about how regulatory compliance affects Rehadapt’s portfolio and represents your advantage.

Significant changes ahead!

How regulatory compliance affects Rehadapt’s portfolio and represents your advantage

The new Medical Device Regulation (MDR) will be enforced in the European Union from the coming spring onwards. To ensure compliance with the MDR, we will apply changes to our portfolio across the board. The changes will also meet upcoming requirements of the FDA (the US regulatory body) and will feature many improvements requested by our partners. We will apply the new structures globally, so the changes will be consistent across Europe, the United States and elsewhere.

To put it briefly:

  • All our wheelchair mounting bundles will get updated and receive new product codes.
  • The ordering process for wheelchair mounts will change.
  • These changes will affect the price structure of our products.

The changes will take effect from January 1, 2021

Core changes

Rehadapt wheelchair mount bundles will no longer include any frame clamp by default

Any product following the requirements for a Medical Device must have consistency and be labelled with a Unique Device Identifier (UDI). To achieve this without compromising the needed flexibility to meet individual client demands, we separated wheelchair mount bundles from frame clamps. Please do not forget to order your frame clamp in addition to the wheelchair mount.

All Rehadapt wheelchair frame clamps will have the same price

Frame clamps are treated as independent products following the guidelines for Medical Devices. To make life easier for our customers, we will apply equal pricing to all frame clamps.  This flat rate is an exact average of all previous frame clamp pricing.

Most wheelchair mounts will include lever/bolt variations, and some excess tubes

For the sake of standardization and simplification, some bundles will include more parts than actually needed.   We may include (for some bundles) a choice of tubes of varying length and both lever and bolt variations. Similarly, when delivering QuickShift levers for toolless operation, we may also deliver the corresponding Allen screws – in case setups need to be secured. We are confident the additional tubes and parts will provide more flexibility on the customer end when assembling the mount.

The effort in delivering the excess material is lower than the expenditure of handling individualized items, and we are confident our customers will enjoy the increased flexibility.

Wheelchair mounts will be delivered pre-assembled in standardized packaging

To further simplify the application of our products, we will deliver wheelchair mounts largely pre-assembled. We will switch to using standardized single packages per mount, using hassle-free and eco-friendly materials. The boxes allow for neat storage as well as easy forwarding to end users/customers, as they can be used as shipping containers. Matching outer packaging of boxes allow for safe and efficient delivery of multiples mounts.

Changes take effect January 1, 2021, and legacy commitments will be honored through May 21st 2021

We are aware that any change in our portfolio and processes means a burden to our partners.  Quotations, databases, pricelists and staff routines will undoubtedly be affected. However, we are convinced you will benefit immensely from our new levels of standardization and simplification, while continuing to enjoy the flexibility you have always loved about Rehadapt products.

The attached pricelist is binding from the 1st of January for all new business. However, we do have options to fulfil legacy quotations until the end of May. In case tenders or other commitments require arrangements beyond the enforcement date of MDR (May 26th 2021), please get in touch with us at your earliest convenience.

List of all new products which will replace other products of our current portfolio in 2021

Wheelchair Mounts / Monty 3D

2020 2021
11.1016 Monty 3D replaced 11.3100 Monty 3D
11.2016 Monty 3D S
11.2516 Monty 3D QuickShift
replaced 11.3211 Monty 3D QuickShift
11.3016 Monty 3D K R discontinued
11.3116 Monty 3D K L discontinued
new 11.3311 Monty 3D QuickShift Sturdy
11.2616 Monty 3D EyeControl replaced 11.3312 Monty 3D Plus
11.2916 Monty 3D EyeControl HD replaced 11.4312 Monty 3D Plus HD
11.4000 Monty 2R S
11.4500 Monty 2R QS
replaced 11.2211 Monty 3D TT
11.4600 Monty 2R DC replaced 11.2312 Monty 3D TT Plus
11.4700 Monty 3D Curved M
11.4701 Monty 3D Curved M QS
replaced 11.5311 Monty 3D Curved M
11.4710 Monty 3D Curved L
11.4711 Monty 3D Curved L QS
replaced 11.6312 Monty 3D Curved L
11.4720 Monty 3D Curved XL
11.4721 Monty 3D Curved XL QS
replaced 11.7312 Monty 3D Curved XL

Wheelchair Mounts / Hybrid 3D

2020 2021
13.3053 H3D W/C 3QS replaced 13.4215 Hybrid 3D Long SLS
13.3153 H3D W/C 3QS-U replaced 13.4211 Hybrid 3D Long UDS
13.2153 H3D W/C 3QS-U Special replaced 13.3211 Hybrid 3D Short UDS
new 13.3215 Hybrid 3D Short SLS

Wheelchair Mounts / Light 3D

2020 2021
14.3001 L3D WC 1AK
14.3051 L3D WC 1QS
discontinued
14.3002 L3D WC 2AK
14.3052 L3D WC 2QS
replaced 14.2015 Light 3D TT SLS
14.3003 L3D WC 3AK
14.3053 L3D WC 3QS
replaced 14.3215 Light 3D QuickShift SLS
14.3101 L3D WC 1AK-U
14.3151 L3D WC 1QS-U
discontinued
14.3102 L3D WC 2AK-U
14.3152 L3D WC 2QS-U
replaced 14.2211 Light 3D TT UDS
14.3103 L3D WC 3AK-U
14.3153 L3D WC 3QS-U
replaced 14.3211 Light 3D QuickShift UDS
14.1000 L3D WC 2AK 1 Switch
14.1050 L3D WC 2QS 1 Switch
replaced 14.2415 Light 3D Headrest 1 Switch
new 14.2515 Light 3D Headrest 1 Switch Flex
14.2000 L3D WC 2AK 2 Switch
14.2050 L3D WC 2QS 2 Switch
replaced 14.3415 Light 3D Headrest 2 Switch
new 14.3515 Light 3D Headrest 2 Switch Flex

Table Mounts / Table Clamps / Light 3D

2020 2021
14.4001 L3D TC 1AK
14.4051 L3D TC 1QS
replaced 12.1780 TC L3D 1QS SLS
14.4002 L3D TC 2AK
14.4052 L3D TC 2QS
replaced 12.1781 TC L3D 2QS SLS
14.4003 L3D TC 3AK
14.4053 L3D TC 3QS
replaced 12.1782 TC L3D 3QS SLS
14.4101 L3D TC 1AK U
14.4151 L3D TC 1QS U
replaced 12.1783 TC L3D 1QS UDS
14.4102 L3D TC 2AK U
14.4152 L3D TC 2QS U
replaced 12.1784 TC L3D 2QS UDS
14.4103 L3D TC 3AK U
14.4153 L3D TC 3QS U
replaced 12.1785 TC L3D 3QS UDS