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IndiaVigilance Guide

# CDSCO Post-Market Surveillance for Medical Devices

Getting your CDSCO import license is only the beginning. Post-market surveillance is an ongoing legal obligation that continues for the entire time your device is sold in India. Failure to report adverse events or maintain vigilance can result in license suspension, recalls, and legal penalties.

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At a glance

PMS obligations

4

PSUR contents

10

AE reporting

15 days

## Post-market surveillance obligations

### Adverse Event Reporting

TimelineWithin 15 days of becoming aware

TriggerDeath, serious injury, device malfunction that could cause death/serious injury

Report ToCDSCO through Materiovigilance Programme of India (MvPI)

### Field Safety Corrective Action (FSCA)

TimelineWithin 24-48 hours for serious risk

TriggerDevice recall, modification, exchange, or destruction for safety reasons

Report ToCDSCO and all affected healthcare facilities

### Periodic Safety Update Report (PSUR)

TimelineEvery 6 months for Class C/D; annually for Class B

TriggerScheduled reporting regardless of incidents

Report ToCDSCO with summary of adverse events and risk-benefit analysis

### Incident Investigation

TimelineWithin reasonable time based on severity

TriggerAny complaint suggesting device did not perform as intended

Report ToMaintain records; report if meets adverse event criteria

## Adverse event reporting hierarchy

01

Healthcare professional or user reports incident to manufacturer/Authorized Agent

02

Authorized Agent evaluates report against adverse event criteria

03

If reportable: submit to CDSCO/MvPI within 15 days via online portal or Form MD-26

04

For FSCA: implement field action and notify CDSCO immediately

05

Submit follow-up reports as investigation progresses

06

Include corrective actions and preventive measures in PSUR

## PSUR contents checklist

01Executive summary of device safety profile

02Cumulative sales data and patient exposure estimates

03Summary of all reported adverse events by type and severity

04Analysis of incident trends and signals

05Risk-benefit evaluation updates

06Summary of any field safety actions taken

07Update on risk management file changes

08Regulatory actions in other countries (if applicable)

09Proposed label changes or IFU updates

10Conclusion and recommendations

## Record retention requirements

Record TypeRetention Period

Adverse event reportsLifetime of device + 2 years

Complaint filesMinimum 5 years

PSUR submissionsIndefinitely

Distribution recordsMinimum 5 years

Field safety action recordsIndefinitely

Risk management file updatesLifetime of device

## Frequently asked questions

### What qualifies as a reportable adverse event?

Reportable adverse events under CDSCO include: (1) Death of a patient, user, or other person; (2) Serious injury to a patient, user, or other person; (3) Malfunction that would be likely to cause or contribute to death or serious injury if it were to recur; (4) Unanticipated serious device-related adverse events. Minor complaints, expected side effects documented in IFU, and user errors unrelated to device design are generally not reportable unless they reveal new risks.

### Do I need to report adverse events that occur outside India?

Yes, CDSCO requires reporting of serious adverse events that occur anywhere in the world for the same device model marketed in India. Global safety signals must be included in your PSUR. If foreign regulatory actions occur (recalls, safety alerts, label changes), you must report these to CDSCO and assess whether similar action is needed in India.

### What is the Materiovigilance Programme of India (MvPI)?

MvPI is India's national medical device adverse event reporting system, coordinated by the Indian Pharmacopoeia Commission. It collects, analyzes, and responds to medical device adverse events. Manufacturers and Authorized Agents report directly to MvPI for centralized data collection. Healthcare facilities can also report through MvPI. The system enables signal detection and national-level safety interventions.

### What happens if I fail to report an adverse event on time?

Delayed adverse event reporting is a serious violation under the Medical Device Rules. Consequences include: show-cause notice from CDSCO, license suspension or cancellation for repeat violations, increased scrutiny of future applications, potential penalties under Drugs and Cosmetics Act, and reputational damage affecting relationships with healthcare providers. Establish robust vigilance procedures to ensure timely reporting.

### Can I use my global post-market surveillance system for India requirements?

Yes, if your global system captures and reports events per Indian requirements. However, you need India-specific elements: Authorized Agent receiving complaints, reporting to MvPI in required format, PSUR submissions on India schedule (which may differ from other countries), and tracking of India-specific field actions. Many multinational manufacturers integrate India into global systems with local customization.

**Disclaimer:** This guide reflects current CDSCO post-market surveillance requirements under Medical Device Rules 2017. Vigilance procedures and reporting formats may be updated. Always verify current requirements with official CDSCO and MvPI notifications.

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