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Safety reporting

  • Published: July 6, 2020
  • Last updated: October 18, 2024

When conducting a clinical investigation, the sponsor and the investigator have specific obligations to record and report serious adverse events and device deficiencies in accordance with the applicable rules and practices.

The clinical investigation plan shall describe in detail how subject safety is monitored as well as how adverse events and device deficiencies are documented and reported in the clinical investigation. All adverse events and device deficiencies shall be documented during the conduct of the investigation in accordance with good clinical practice.

The investigator is responsible for recording and reporting the events to the sponsor, who in turn is responsible for reporting to the relevant authorities.

The sponsor shall immediately inform all relevant authorities of events that constitute reportable events in the current investigation. This applies regardless of whether the event affects subjects, users or other individuals involved in the investigation.

In order to ensure timely reporting, the sponsor may, if necessary, submit a preliminary, incomplete report, which is then complemented by a full report. Timelines and detailed requirements for reporting are described in the EU-wide guidance document MDCG 2020-10/1 Rev 1: Safety reporting in clinical investigations of medical devices under the Regulation (EU) 2017/745.

The guidance document are linked further down this page.

Reporting obligations for different actors

How safety reporting is to be conducted, and what constitutes reportable events in the current investigation depends on which of the following three categories the investigation belongs to:

  1. If the investigational device is not CE marked or if it is CE marked but is used outside its intended purpose, safety reporting shall take place in accordance with Section 1 below.
  2. If the investigational device bears the CE marking and is used for its intended purpose but additional invasive or burdensome procedures are added to the investigation, safety reporting shall take place in accordance with Section 2 below.
  3. Where the investigational device bears the CE marking and is used for its intended purpose but no further invasive or burdensome procedures are involved in the investigation, safety reporting shall be carried out in accordance with Section 3 below.

It is important that the sponsor has an agreement with the investigators to promptly report all of these events to the sponsor. Sponsors and principal investigators shall also continuously inform each other in accordance with ISO standard SS EN 14155:2020 and the applicable clinical investigation plan.

Section 1

Safety reporting in clinical investigation with non-CE marked investigational devices or CE marked devices used outside their intended purpose.

For this type of investigations, sponsors are responsible for reporting to the relevant authorities in accordance with the requirements of Article 80(1) to (4) of the MDR, the guidance document MDCG 2020-10/1 rev 1 and national legislation.

This means that sponsors must report the following reportable cases to the Swedish MPA without delay:

  • any serious adverse event (SAE) that has a causal relationship with the investigational device, the comparator or the investigation procedure or where such causal relationship is reasonably possible
  • any device deficiency that might have led to a serious adverse event if appropriate action had not been taken, intervention had not occurred, or circumstances had been less fortunate
  • any new findings in relation to any of the events above.

Safety reporting is done using the form "Clinical investigation summary safety report form" MDCG 2020-10/2 rev 1 which is sent to the Swedish MPA via the Agency’s e-service for SAE reporting. The form and the e-service are linked further down this page.

Reports shall be submitted to the relevant authorities in all countries where the clinical investigation is conducted, not only to the authority of the country where the event occurred.

Section 2

Safety reporting in clinical investigations with CE marked devices used within the scope of their intended purpose, in cases where subjects are exposed to additional invasive or burdensome procedures due to the investigation.

For this type of investigations, sponsors are responsible for reporting to the relevant authorities in accordance with the requirements of Article 80(5)-(6) of the MDR, the guidance document MDCG 2020-10/1 rev 1 and national legislation.

This means that sponsors must report the following reportable cases to the Swedish MPA without delay:

  • any serious adverse event (SAE) for which a causal relationship to the preceding investigational procedure has been established.

Safety reporting is done using the form ‘Clinical investigation summary safety report form’ MDCG 2020-10/2 rev 1 which is sent to the Swedish MPA via the Agency’s e-service for SAE reporting.

The form and the e-service are linked further down this page.

Reporting shall take place to the relevant authorities in all countries where the clinical trial is conducted, not only to the authority of the country where the event occurred.

Since the investigational device is CE marked and used within the scope of its intended purpose, serious incidents and adverse events must also be reported in accordance with the requirements applicable to CE marked devices. This means that for serious incidents and adverse events occurring in Sweden:

  • the manufacturer reports serious incidents to the Swedish MPA
  • healthcare notifies the manufacturer and the Swedish MPA of adverse events and incidents involving medical devices.

Section 3

Safety reporting in clinical investigations with CE marked devices used within the scope of their intended purpose, in cases where subjects are not exposed to any additional invasive or burdensome procedures due to the investigation.

For investigations in Sweden with CE-marked investigational devices used within the scope of the intended purpose defined by the manufacturer, where subjects are not exposed to any additional invasive or burdensome procedures due to the investigation, no investigation-specific safety reporting shall be made to the authority within the framework of the investigation.

However, since the investigational device is CE marked and used in line with its intended purpose, serious incidents and adverse events must be reported in accordance with the requirements applicable to all CE marked devices.

This means that for serious incidents and adverse events occurring in Sweden:

  • the manufacturer reports serious incidents to the Swedish MPA
  • healthcare notifies the manufacturer and the Swedish MPA of adverse events and incidents involving medical devices.

Guidance

Reporting form for investigation specific reporting

The completed form should be submitted to the Swedish MPA via the E-service.

E-service for investigation specific reporting

Do like this:

  • Please choose the “SAE Report Clinical Investigation of Medical Device” option as ‘Recipient’ in the e-service drop down menu.
  • Add your name and email address in the mandatory fields.
  • Attach the file with the report.
  • Indicate both the Swedish MPA reference number and CIV ID of the clinical investigation in the message field.

Contact us

Department of Clinical Trials and Special Permissions
Email: registrator@lakemedelsverket.se
Telephone: +46 (0)18-17 42 69
Phone hours: Monday, Wednesday-Friday 10:00 am to 11:00 am CET. Tuesdays closed.

Phone hours during summer (week 26-32) and Christmas (week 52-2): Tuesday and Thursday 10:00 am to 11:00 am CET.

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