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Summary

Your Post-Market Surveillance (PMS) SOP establishes systematic processes for actively collecting, analyzing, and acting on real-world data about your device’s safety, performance, and quality throughout its entire lifecycle to support continuous improvement and regulatory compliance.

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Why is SOP Post-Market Surveillance important?

Post-market surveillance exists because regulators recognize that real-world performance may differ from controlled study conditions. It demonstrates your commitment to ongoing safety monitoring rather than treating regulatory approval as the end of your responsibility. The systematic collection of field data helps identify previously unknown risks and validates clinical assumptions. Your PMS system transforms scattered customer feedback into actionable intelligence that drives product improvements, informs regulatory decisions, and protects patients. It also provides early warning signals for potential issues before they become serious incidents requiring immediate regulatory action, allowing proactive rather than reactive responses.

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Regulatory Context

  • FDA
  • MDR
Under 21 CFR Part 820 (Quality System Regulation):
  • Must establish feedback systems under Section 820.100(a)
  • Medical Device Reporting (MDR) required under 21 CFR Part 803
  • Design controls must include post-market feedback integration (820.30)
  • Complaint handling required under Section 820.198
  • Management review must include customer feedback analysis
Special attention required for:
  • MDR reporting timelines (24 hours for deaths, 10 days for serious injuries)
  • 510(k) special controls compliance and post-market studies
  • Unique Device Identification (UDI) reporting requirements
  • Software maintenance and cybersecurity monitoring

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Guide

Your PMS SOP establishes proactive monitoring systems that transform real-world data into actionable insights. Focus on creating sustainable processes that provide meaningful intelligence rather than just compliance documentation.

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PMS Plan Development

Create device-specific PMS plans that outline systematic data collection methods, analysis procedures, and decision criteria. Define clear objectives, target populations, data sources, and collection methods appropriate for your device type and risk classification. Include specific indicators and threshold values for triggering actions. Establish systematic procedures for collecting information from multiple sources including customer complaints, scientific literature, vigilance databases, user feedback, and competitive intelligence. Design collection methods that provide representative and meaningful data rather than overwhelming your team with low-value information.

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Data Collection and Sources

Implement multi-channel data collection systems that capture diverse perspectives on device performance. Include direct customer feedback, distributor reports, scientific literature monitoring, regulatory database searches, and social media monitoring where appropriate. Create standardized forms and procedures to ensure consistent data quality. Establish partnerships with key stakeholders including distributors, healthcare providers, and patient advocacy groups to enhance data collection capabilities. Include procedures for validating and verifying collected information to ensure reliability and accuracy.

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Analysis and Evaluation Methods

Develop systematic analysis procedures that transform raw data into meaningful insights. Include trend analysis methodologies, statistical significance testing, and benefit-risk assessment procedures. Establish clear criteria for determining when findings require action versus continued monitoring. Create analysis workflows that involve appropriate subject matter experts including clinical specialists, risk management personnel, and regulatory affairs professionals. Include procedures for documenting analysis methods and results to support regulatory submissions and audits.

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Integration with Quality System

Connect PMS outputs to all relevant quality processes including CAPA, risk management, design controls, and clinical evaluation updates. Establish clear triggers for initiating corrective actions, design changes, or regulatory notifications based on PMS findings. Include PMS data in management review reporting with trending analysis and performance indicators. Use PMS insights to inform strategic decisions about product improvements, market expansion, and risk management priorities.

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Reporting and Communication

Establish systematic reporting procedures that meet regulatory requirements while providing meaningful information to stakeholders. Create templates and workflows for PSUR development, trend reporting, and regulatory submissions that ensure consistency and completeness. Develop communication procedures for sharing findings with relevant stakeholders including customers, distributors, regulatory authorities, and notified bodies. Include procedures for coordinating with other manufacturers when systemic issues affect multiple devices.

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Example

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Scenario

MedTech Solutions implements post-market surveillance for their diabetes monitoring app, collecting data from user feedback, app store reviews, customer support interactions, and clinical literature to monitor real-world performance and identify improvement opportunities.

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PMS System Implementation

PMS Plan Development:
  • Data Sources: App analytics, customer support tickets, app store reviews, clinical literature, competitive intelligence
  • Collection Methods: Automated data extraction, customer surveys, healthcare provider feedback forms
  • Analysis Frequency: Monthly trending analysis, quarterly comprehensive review
  • Threshold Values: >5% increase in crash reports, >3 complaints about accuracy per month
  • Action Criteria: Statistical significance testing for trends, severity-based escalation procedures
Data Collection Implementation:
  1. Technical Performance Monitoring: Automated collection of crash reports, performance metrics, usage patterns
  2. Customer Feedback Systems: In-app feedback portal, quarterly satisfaction surveys, support ticket analysis
  3. Literature Monitoring: Monthly PubMed searches, regulatory database monitoring, competitor analysis
  4. Healthcare Provider Input: Semi-annual provider surveys, clinical outcome data collection
  5. Social Media Monitoring: Automated scanning of relevant platforms for device mentions and issues
Analysis and Response Example: Finding: 8% increase in glucose reading accuracy complaints over 3-month period Investigation: Root cause analysis reveals algorithmic performance degradation with specific phone models Analysis: Risk assessment indicates potential for delayed insulin administration decisions Actions:
  • Immediate: Customer advisory notice with workaround instructions
  • Short-term: Software update addressing compatibility issue
  • Long-term: Enhanced device compatibility testing procedures Follow-up: Monitor complaint resolution and customer satisfaction improvement
PSUR Development Process:
  • Data Compilation: Systematic review of all PMS data collected during reporting period
  • Trend Analysis: Statistical analysis of complaint patterns, performance metrics, usage data
  • Clinical Review: Assessment of real-world performance versus intended use claims
  • Risk Assessment: Updated benefit-risk analysis incorporating new field data
  • Action Planning: Identification of improvement opportunities and regulatory update needs

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Q&A

Include customer complaints, scientific literature, vigilance databases, user feedback, distributor reports, service records, social media monitoring, and competitive intelligence. Focus on sources that provide representative information about real-world device performance and user experiences. Tailor your data sources to your device type and user population.
Use statistical analysis to identify significant increases in incident frequency or severity compared to expected baseline rates. Consider the clinical significance of trends, not just statistical significance. Document your trending methodology in your PMS plan and apply consistent criteria for determining when trends require reporting or action.
Post-Market Surveillance Reports (PMSR) are required for lower-risk devices (Class I/A/B) and focus on general PMS findings. Periodic Safety Update Reports (PSUR) are required for higher-risk devices with specific timing requirements and must include comprehensive safety analysis, benefit-risk assessment, and trend reporting.
Log all complaints related to device performance or safety and evaluate each for significance and trending patterns. Categorize complaints by type, severity, and potential impact. Use complaint data as a key input for trend analysis and include complaint statistics in your regular PMS reporting and analysis.
Initiate CAPA when PMS findings indicate systematic issues, safety concerns, or performance problems that require root cause investigation and corrective action. Use your established CAPA qualification criteria to evaluate PMS findings systematically. Include PMS trend analysis as a potential CAPA trigger in your procedures.
Establish review frequencies based on device risk classification and data volume. Higher-risk devices typically require more frequent monitoring. Include ongoing trending analysis (monthly/quarterly) and comprehensive periodic reviews (annual/biannual). Adjust frequencies based on device performance and market conditions.
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