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Biological safety is one of the most important parts of medical device compliance under EU MDR.

If a device comes into direct or indirect contact with the human body, manufacturers must prove that the materials are safe for the intended use. This is where ISO 10993 becomes essential.

ISO 10993 is the international standard series used for the biological evaluation of medical devices. It helps manufacturers assess whether device materials, chemicals, residues, degradation products, or manufacturing-related substances may create biological risks.

In simple words, ISO 10993 helps answer one key question:

Is this device biologically safe for the patient or user?

Why ISO 10993 Matters Under MDR

Under EU MDR, biological safety is not just a supporting requirement. It is part of the overall safety and performance evidence for the device.

Manufacturers cannot simply state that a material is “biocompatible.” They need a clear, scientific justification based on the device’s intended purpose, body contact, duration of contact, material composition, manufacturing process, sterilization, packaging, and possible chemical risks.

The current ISO 10993-1:2025 defines biological safety evaluation within a risk management process, which means manufacturers must connect biological evaluation with broader device risk management.

ISO 10993 Is Not Just a Testing Checklist

Many manufacturers make one common mistake. They treat ISO 10993 as a fixed list of tests.

That approach can lead to unnecessary testing, higher cost, and weak documentation.

ISO 10993 follows a risk-based approach. First, the manufacturer should understand the device and its contact with the body. Then the biological risks should be assessed. After that, existing evidence, chemical characterization, toxicological assessment, literature, and testing can be used to support the safety conclusion.

For example, a short-term skin-contact device does not need the same biological evaluation as a long-term implant.

The evaluation should match the actual risk.

The Role of BEP and BER

For MDR technical documentation, manufacturers usually prepare a Biological Evaluation Plan (BEP) and a Biological Evaluation Report (BER).

The BEP explains the biological evaluation strategy. It defines the relevant biological endpoints, available evidence, testing needs, and justification approach.

The BER brings everything together. It explains whether the device is biologically safe and whether any remaining biological risks are acceptable.

Notified Bodies review these documents carefully. If the BEP and BER are unclear, outdated, or not connected with risk management, they may raise questions during review.

What Notified Bodies Expect

Notified Bodies expect a logical and traceable biological safety file.

They want to see that the manufacturer has identified relevant biological risks and addressed them properly. They also expect biological evaluation to align with material data, manufacturing changes, sterilization method, packaging, shelf life, and clinical use.

If the device uses new materials, has prolonged body contact, or contains substances of concern, the level of review becomes stricter.

In short, Notified Bodies do not want generic statements. They want a clear scientific argument.

Why Chemical Characterization Matters

Chemical characterization is becoming more important in biological evaluation.

It helps identify chemicals that may come from raw materials, additives, processing aids, sterilization residues, packaging, or degradation products.

Once these chemicals are identified, toxicological risk assessment can help decide whether patient exposure is acceptable.

This approach can reduce unnecessary testing and make biological safety conclusions stronger.

Common Mistakes MDR Manufacturers Make

One common mistake is using old biocompatibility test reports without checking whether they still match the current device design, supplier, material, manufacturing process, or sterilization method.

Another mistake is missing chemical characterization or toxicological risk assessment when it is needed.

Some manufacturers also prepare biological evaluation as a standalone document. This creates gaps because ISO 10993 expects biological safety to be linked with risk management.

When these gaps appear, Notified Bodies may ask for clarification, additional justification, or further testing.

What Manufacturers Should Do Now

MDR manufacturers should review their ISO 10993 strategy early in the technical documentation process.

They should confirm the correct contact category, review material composition, check process and supplier changes, assess sterilization impact, and verify whether existing test data is still valid.

Most importantly, the BEP, BER, toxicological assessment, and risk management file should tell one consistent safety story.

This makes the submission stronger and reduces the risk of review delays.

Final Thoughts

ISO 10993 is not only about biocompatibility testing.

It is a framework for proving biological safety through a scientific and risk-based approach.

For MDR manufacturers, the goal is not to perform every possible test. The goal is to build a clear and defensible biological safety justification.

A strong ISO 10993 file supports patient safety, strengthens technical documentation, and improves Notified Body readiness.

How Bioexcel Can Help

At Bioexcel, we support medical device manufacturers with ISO 10993 biological evaluation, BEP and BER preparation, toxicological risk assessment, chemical characterization strategy, gap review, and MDR technical documentation alignment.

We help ensure your biological safety evidence is clear, compliant, and Notified Body-ready.

Need support with ISO 10993 biological evaluation under MDR? Partner with Bioexcel for a stronger and safer compliance strategy.