Medical Device Vigilance Manual

Management of Device Vigilance Information and MIR Workflows

Chapter 5 — Receipt, Assessment, Coding, Investigation & Dispatch

5

1. Four Minimum Validity Criteria

Every incoming report must satisfy all four criteria before processing can begin.

Required

Identifiable Reporter

Healthcare professional, user, patient, or manufacturer representative who reported the event.

Required

Identifiable Patient

Patient or user affected by the event, identifiable by initials, age, gender, or record number.

Required

Suspect Device

Device identified by model number, lot/batch number, serial number, or UDI.

Required

Identifiable Event

Description of the adverse event, incident, or device malfunction observed.

Day 0 Rule: All four criteria must be met at initial receipt. The date of receipt is logged as Day 0, which starts the regulatory reporting clock for all applicable jurisdictions.

2. MIR Workflow — Start to Finish

Five sequential stages from initial receipt through regulatory dispatch.

1

Receipt & Triage

Verify the four minimum validity criteria against the incoming report. Log the date of receipt as Day 0 and start the regulatory reporting clock for all applicable jurisdictions.

Validity Check Day 0 Logging Regulatory Clock Start
2

Reportability Assessment

Conduct a medical and technical review of the event. Determine whether the case qualifies as a serious incident or reportable malfunction. Check for the Weber Effect—an apparent increase in reports during the launch phase of a new device that may reflect heightened awareness rather than true risk elevation.

Medical Review Technical Review Weber Effect
3

Data Entry & Coding

Code medical events using MedDRA terminology (Preferred Terms, HLTs, SOCs). Classify device problems using IMDRF Annex A through G codes. Write structured clinical narratives summarising the event, patient outcome, and device involvement.

MedDRA Coding IMDRF Annex A–G Clinical Narrative
4

Technical Investigation

Evaluate the returned device or available lot/batch data. Identify root cause failure modes such as Material Fragmentation, Software Coding Error, Biocompatibility Reaction, Mechanical Fatigue, or Sterilisation Breach. Document findings for inclusion in the MIR.

Device Evaluation Failure Mode Analysis Root Cause
5

Regulatory Dispatch

Format the completed report according to the target authority: eMDR format for the FDA, MIR XML for the EU. Transmit to the relevant health authorities within the applicable regulatory timeline.

eMDR (FDA) MIR XML (EU) Authority Submission

3. Reporting Timelines Comparison

Key calendar-day deadlines under EU MDR and FDA 21 CFR 803.

EU MDR (2017/745)
2days
Serious public health threat requiring immediate action by the competent authority.
10days
Death or unanticipated serious deterioration in a patient's state of health.
15days
Other reportable serious incidents not covered by the 2- or 10-day timelines.
Reference: EU MDR Article 87, MEDDEV 2.12/1 rev 8
FDA — 21 CFR 803
5days
Events requiring remedial action to prevent an unreasonable risk of substantial harm to public health.
30days
Reports of death, serious injury, or reportable malfunction involving a marketed device.
Reference: 21 CFR 803.50, 803.52, 803.53

4. Electronic Transmission Standards

Layered view of submission formats across major regulatory jurisdictions.

FDA

Form 3500A / eMDR System

Mandatory electronic submission via the FDA eMDR gateway for manufacturers. Uses structured XML based on the HL7 ICSR standard adapted for device reporting.

EU

MIR Form / EUDAMED (Planned)

Currently submitted via national competent authority portals using the MIR form. Full electronic submission through the EUDAMED vigilance module is planned for future deployment.

Both

"Reasonably Known" Information Standard

Manufacturers must provide all information that is reasonably known to them at the time of reporting, including data from complaints, investigations, and post-market surveillance. Follow-up reports are required as new information becomes available.

The MIR is the fundamental unit of device vigilance data. Unlike pharmaceutical ICSRs, the MIR must capture both the clinical outcome (patient injury) and the technical outcome (device failure mode), requiring coordinated input from both medical and engineering teams.