>-----Original Message-----
>From: Colgan, Chris [mailto:[email protected]]
>Sent: Friday, October 26, 2001 7:43 AM
>To: '[email protected]'; [email protected]
>Subject: RE: FDA
>
>
>
>The very basic difference is that the FDA are safety related 
>and the FCC EMC
>related.
>
>Both have very comprehensive websites....
>
>http://www.fda.gov/
>
>http://www.fcc.gov/
>
>Regards
>
>Chris Colgan
>Compliance Engineer
>TAG McLaren Audio Ltd
>The Summit, Latham Road
>Huntingdon, Cambs, PE29 6ZU
>*Tel: +44 (0)1480 415 627
>*Fax: +44 (0)1480 52159
>* Mailto:[email protected]
>* http://www.tagmclaren.com


The FDA has several references to non-FCC standards. Here's a couple of
quotes from the FDA site:


"MDS-201-0004, Electromagnetic Compatibility Standard for Medical Devices,
October 1, 1979. This standard was developed under contract from FDA by
McDonnell Douglas, but was not adopted as mandatory; it is considered a
voluntary guideline."

"Over the past 20 years, several standards applicable to medical devices
were developed with EMC requirements, primarily standards for military
products (MIL-STD), the Association for the Advancement of Medical
Instrumentation (AAMI) pacemaker standard, and a 1979 medical device EMC
standard (MDS-201-0004). The latter two standards were written under
contracts from FDA but were not adopted as mandatory; they are considered
voluntary guidance. Recently, the international standards development
process, in which FDA has participated, has developed significant and
appropriate standards. They are not ideal, but when used, they certainly
increase product safety. Appendix B lists examples of available standards.

CDRH encourages manufacturers of electromedical equipment to use the IEC
60601-1-2 standard, a widely recognized standard issued by the International
Electrotechnical Commission, Geneva, Switzerland. [NOTE: IEC recently
renumbered the standards, adding 60000 to all previous numbers, so
investigators may know it as IEC 601-1-2.] It is a collateral standard to
IEC 60601-1, which is a horizontal (product family) standard intended to
apply across many medical disciplines. Other standards such as MIL-STDs or
some industry standards may be appropriate as well. It is the manufacturer's
responsibility to determine the most appropriate specifications and
requirements for their devices. If conformance claims have been made in a
PMA or the labeling, however, the GMP documents should contain documented
evidence consistent with and supporting those claims.

The IEC 60601 series currently includes a general safety standard, four
collateral standards (systems, EMC, diagnostic x-ray protection, and
programmable electrical medical systems), and over 40 particular, or product
specific standards that adapt the general and collateral standards. Related
international standards contain details of the IEC 60601-1-2 requirements
and test methods (e.g., International Special Committee on Radio
Interference (CISPR) standards CISPR 11 and CISPR 16, and IEC 61000-4-x
which supersedes the obsolete IEC 801-x series). FDA investigators may be
aware of IEC 801-2, since many firms have used it to determine requirements
for controlling ESD during manufacturing.

These standards are subject to frequent revisions and many documents have to
be reviewed simultaneously to determine the current requirements. Hence,
manufacturers of the same device, claiming to meet the same standard, may
have differing specifications. Firms may claim partial or complete
conformance to IEC 60601-1-2 or may have alternate test methods or
parameters. Partial conformance may be adequate if the firm substantiates
and/or justifies the deviations.

The IEC 60601-1-2 standard provides various limits on emissions and
immunity. While these limits are clear, the pass/fail criteria are not.
Therefore, CDRH encourages manufacturers to clearly specify all deviations
from the standard, their specific pass/fail criteria, and justifications as
part of their GMP documentation.

(NOTE that IEC 60601-1-2 is not applicable to in vitro diagnostic devices or
sterilizers but may be used.)"


Regards,

Ed


Ed Price
[email protected]
Electromagnetic Compatibility Lab
Cubic Defense Systems
San Diego, CA  USA
858-505-2780  (Voice)
858-505-1583  (Fax)
Military & Avionics EMC Services Is Our Specialty
Shake-Bake-Shock - Metrology - Reliability Analysis

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