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CDSCO License for Applicator for prostate remote after loading brachytherapy

Medical Device Information

Device Class
Class C

Intended Use

A remote controlled brachytherapy applicator specifically designed for prostate radiation therapy. It is designed to be temporarily implanted in the prostate gland. It serves as a guide for computer-controlled temporary placement and removal of a single or multiple  therapeutic radiation sources.

Manufacturing License
MD9
Import License
MD15
CDSCO License for Applicator for prostate remote after loading brachytherapy

Introduction: Understanding the Applicator for Prostate Remote After Loading Brachytherapy and Its Regulatory Importance

The Applicator for Prostate Remote After Loading Brachytherapy is a specialized medical device designed to enable precise, computer-controlled placement and removal of therapeutic radiation sources within the prostate gland. This device plays a critical role in prostate cancer treatment by facilitating targeted radiotherapy while minimizing exposure to surrounding tissues.

Given its complexity and critical function, this device is classified as Class C under the Indian medical device regulatory framework. This classification necessitates stringent regulatory controls and licensing processes governed by the Central Drugs Standard Control Organization (CDSCO). For manufacturers and importers, understanding and efficiently navigating the CDSCO approval pathway is essential to successfully market this device in India.

CDSCO Regulatory Framework for Radiotherapy Devices: Applicator for Prostate Brachytherapy

The CDSCO regulates medical devices under the Drugs and Cosmetics Act, 1940, and its subsequent amendments. Devices like the remote after loading brachytherapy applicator, which fall under the radiotherapy category and carry moderate-to-high risk (Class C), require central licensing authority approval via the MD9 license process.

The regulatory framework mandates compliance with quality management systems (ISO 13485:2016), thorough documentation including Device and Plant Master Files, risk management, and product testing in government-approved laboratories. Meeting these requirements ensures safety, efficacy, and performance consistency for this life-critical device.

Risk Classification and License Requirements for Class C Devices

As a Class C device, the applicator is considered to have moderate to high risk, primarily due to its invasive nature and involvement in radiation therapy. Consequently, the licensing process is more rigorous than for Class A or B devices.

Manufacturers of Class C devices must apply for a manufacturing license under Form MD7 (MD9 license), issued by the Central Licensing Authority of CDSCO. This process involves multiple steps, including obtaining a test license, product testing, documentation submission, and an on-site audit by CDSCO inspectors.

Manufacturing License Process (MD9) for Class C Devices

The MD9 license process for this device typically spans 4 to 5 months. The stepwise approach includes:

  1. Test License Application (Form MD13): Obtain a test license to manufacture the device for testing purposes. This generally takes 1.5 to 2 months.

  2. Product Testing: Conduct mandatory product testing at CDSCO-approved government laboratories to validate safety and performance.

  3. Documentation Preparation: Compile comprehensive documentation, including Device Master File, Plant Master File, Risk Management File, Essential Principles Checklist, and quality system records.

  4. License Application (Form MD7): Submit the MD9 manufacturing license application through the CDSCO MD Online Portal.

  5. On-site Audit: CDSCO inspectors conduct a detailed audit of manufacturing facilities and documentation.

  6. Queries Resolution: Address any queries or deficiencies raised during the audit or application review.

  7. License Grant: Upon satisfactory compliance, the MD9 license is issued on Form MD9.

Manufacturing License Documents Required for Applicator for Prostate Brachytherapy

A complete and well-organized submission significantly accelerates approval. Essential documents include:

  • Company Constitution: Memorandum and Articles of Association or partnership deed.
  • Proof of Premises Ownership/Lease: Valid documents confirming manufacturing site ownership or tenancy.
  • Technical Staff Details: Qualifications and experience details of key personnel involved in manufacturing.
  • Fire NOC and Pollution Control Certificate: Compliance certificates from relevant authorities.
  • Device Master File (DMF): Detailed technical specifications, design, and manufacturing process. Our comprehensive Device Master File guide offers practical insights.
  • Plant Master File (PMF): Description of manufacturing facilities, equipment, and quality assurance systems. Refer to our Plant Master File guide for best practices.
  • Essential Principles Checklist: Compliance with Indian and international standards.
  • Risk Management File: Documentation per ISO 14971 standards. Learn more about Implementing Medical Device Risk Management.
  • Test Reports: Certificates from CDSCO-approved laboratories confirming conformity.
  • Labels and Instructions for Use (IFU): Drafts demonstrating user safety and device information.
  • Quality Management System Documents: ISO 13485:2016 certification and related procedures.

Import License Process (MD15) for Class C Devices

If you plan to import the Applicator for Prostate Remote After Loading Brachytherapy into India, an Import License (Form MD14) for MD15 is required. The process is handled by the Central Licensing Authority and typically takes 5 to 6 months.

Key steps include:

  1. Document Preparation: Compile manufacturing license from the country of origin, Free Sale Certificate, ISO 13485:2016, CE Certificate, Device and Plant Master Files, company constitution, wholesale license, and other supporting documents.

  2. Application Submission: File your application via the CDSCO MD Online Portal.

  3. Department Review and Queries: Respond promptly to any queries or requests for additional information.

  4. License Issuance: Post satisfactory review, the MD15 import license is granted.

Import License Documents Required for Applicator for Prostate Brachytherapy

  • Valid Manufacturing License from the country of manufacture
  • Free Sale Certificate or Certificate of Export
  • ISO 13485:2016 Certificate
  • CE Certificate (if applicable)
  • Device Master File and Plant Master File
  • Wholesale License for distribution in India
  • Company Constitution and proof of ownership of premises
  • Detailed product information and labeling

Timeline and Processing Duration

Process StepDuration (Approximate)
Test License (MD13)1.5 to 2 months
Product Testing1 to 1.5 months
Documentation Preparation1 month (parallel)
MD9 License Application Review1 to 1.5 months
CDSCO Audit and Queries1 month
Total Manufacturing License Process4 to 5 months
Import License (MD15) Process5 to 6 months

Government Fees and Costs

For the MD9 manufacturing license relevant to Class C devices like this applicator, the fee structure is as follows:

  • Application Fee: ₹50,000 per application
  • Product Fee: ₹1,000 per product

For import licenses (MD15), fees vary by risk class:

  • Class C & D devices: ₹3,000 per site and ₹1,500 per product

Note that these fees are payable online via the CDSCO portal during application submission.

Common Challenges and Solutions

Challenge 1: Delays in Product Testing

  • Solution: Engage with CDSCO-approved testing labs early. Maintain clear communication and submit comprehensive samples to avoid repeat tests. Refer to the official Testing Laboratories list.

Challenge 2: Incomplete or Poor Documentation

  • Solution: Leverage expertise to prepare Device and Plant Master Files meticulously. Using our detailed Device Master File guide can streamline this.

Challenge 3: Audit Non-Compliance

  • Solution: Conduct mock audits and ensure all manufacturing practices comply with ISO 13485:2016 and CDSCO requirements before the official inspection.

Challenge 4: Resolving Department Queries

  • Solution: Respond promptly with clear evidence and documentation. Maintain open communication channels with CDSCO officials.

Expert Consultation and Support

With over 25 years of experience assisting 500+ companies in navigating CDSCO licensing, we provide end-to-end support tailored to your device and business needs. From initial classification and documentation to audit readiness and query management, our expertise ensures an efficient and successful licensing journey.

Getting Started with Your CDSCO License Application for the Applicator for Prostate Remote After Loading Brachytherapy

  1. Confirm Device Classification: Verify your device as Class C using the Medical Device Classification guide.

  2. Prepare Required Documentation: Begin compiling Device and Plant Master Files, risk management documentation, and quality system certifications.

  3. Apply for Test License (Form MD13): Submit via the CDSCO MD Online Portal.

  4. Coordinate Product Testing: Liaise with CDSCO-approved testing laboratories early to schedule testing.

  5. Apply for Manufacturing License (Form MD7): Once testing is complete, submit your MD9 license application.

  6. Prepare for Audit: Ensure manufacturing site and processes are audit-ready.

  7. Engage with Experts: Consider professional consultancy to navigate complex regulatory requirements seamlessly.

By following this structured approach, you can efficiently obtain your CDSCO license and bring this innovative prostate brachytherapy applicator to the Indian market with confidence and compliance.

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About the Author

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Tails Azimuth
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