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Global trends in post-market surveillance of high-risk medical devices: An empirical analysis based on regulatory data
For correspondence: Dr Manjuladevi M, Department of Chemistry, SNS College of Technology, Coimbatore 641 035, Tamil Nadu, India e-mail: hod.chem@snsct.org
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Received: ,
Accepted: ,
Abstract
Background & objectives
To analyse post-market surveillance (PMS) trends for high-risk medical devices (Class IIb and III) in different geographic regions and evaluate the effectiveness of field safety corrective actions (FSCAs) in mitigating device-related risks.
Methods
This study utilised 2024 data from EUDAMED (European Database on Medical Devices), BfArM (Bundesinstitut für Arzneimittel und Medizinprodukte), and MAUDE (Manufacturer and User Facility Device Experience (FDA database)) to identify recurring incidents, associated device types, and the outcomes of FSCAs. A quantitative analysis was conducted to evaluate the frequency and severity of reported incidents, focusing on hardware failures, software malfunctions, and calibration issues. The impact of recalls, software updates, and field modifications on incident recurrence was also assessed.
Results
Orthopaedic implants, infusion pumps, and cardiac monitoring devices reported the highest number of incidents, primarily due to hardware failures and software issues. FSCAs involving hardware modifications significantly reduced recurrence rates, particularly for high-risk devices like pacemakers and ventilators. In contrast, software-driven devices exhibited persistent issues despite corrective actions, highlighting challenges in maintaining long-term reliability.
Interpretation & conclusions
The findings underscore the importance of robust PMS systems and tailored corrective actions in mitigating risks associated with high-risk medical devices. While FSCAs have demonstrated effectiveness in addressing hardware-related failures, enhancements in regulatory frameworks are necessary to improve the management of software-driven devices.
Keywords
Class IIb devices
class III devices
EUDAMED
field safety corrective actions (FSCAs)
medical device incidents
medical device regulation
post-market surveillance
The rapid advancement of medical technology has revolutionised patient care. As medical devices become more sophisticated, they are also prone to complex risks, including software malfunctions, hardware degradation, and systemic failures, particularly in high-risk categories such as Class IIb and Class III devices1. These risks, if not adequately addressed, can compromise patient safety, treatment efficacy, and public trust in healthcare technologies.
In response to these challenges, regulatory frameworks have evolved globally, placing increased emphasis on post-market surveillance (PMS) systems. In the European Union (EU), the introduction of Regulation (EU) 2017/745 (MDR) represents a significant shift from the earlier Medical Device Directive (MDD), embedding proactive and continuous surveillance across the product lifecycle2. The MDR (Medical Device Regulation (EU)) mandates each manufacturer to establish a PMS plan that integrates real-world data collection, trend analysis, and field safety corrective actions (FSCAs), facilitating timely intervention when safety signals emerge3. Similar regulatory advancements are observed globally, with systems like the FDA’s MAUDE (Manufacturer and User Facility Device Experience) and Brazil’s BrFaM (Bundesinstitut für Arzneimittel und Medizinprodukte (Federal Institute for Drugs and Medical Devices – Germany) playing parallel roles in incident tracking and FSCA reporting4–6.
International standards such as ISO (International Organization for Standardization) 13485 and IEC (International Electrotechnical Commission) 60601 ensure manufacturers consistently meet regulatory expectations during pre-market development, focusing on safety, biocompatibility, electromagnetic compatibility, and environmental resilience7,8. However, numerous studies have highlighted that post-market phases often lack standardisation in surveillance practices1,3, which can hinder timely detection and management of adverse events. Furthermore, challenges specific to software-driven medical devices including calibration issues, signal loss, and algorithmic bias present gaps that conventional regulatory tools may not fully address9.
Studies emphasize the urgent need for harmonised surveillance approaches, especially given the global distribution of medical devices. For instance, discrepancies in adverse event reporting between EUDAMED and MAUDE databases point to variations in regulatory expectations, affecting how manufacturers implement FSCA protocols10,11. Similarly, real-world post-market studies involving cardiac implantable devices and software-based tools have reported increasing device-related infections and systemic malfunctions, despite evolving PMS strategies3.
This study aims to bridge these gaps by analysing post-market incident trends for high-risk devices across multiple databases, including EUDAMED (EU), MAUDE (USA), BfArM (Germany), and ANSM (France). By focusing on reported incidents and FSCA effectiveness in 2024, it seeks to evaluate the regulatory performance of PMS systems, identify areas of improvement, and propose recommendations for strengthening global post-market vigilance12.
Materials & Methods
This study was undertaken by the department of Neuroscience, National University of Ireland Galway, in collaboration with the department of Chemistry, SNS College of Technology, Coimbatore, India with additional contributions from industry research in biomedical engineering. The study period was from March 2024 to February 2025. The analysis was based entirely on secondary data from publicly accessible regulatory databases (EUDAMED, MAUDE, BfArM, and ANSM).
Data sources
Maintained by the Federal Institute for Drugs and Medical Devices, BfArM provides a publicly accessible database of post-market incidents, recalls, and Field Safety Corrective Actions (FSCAs) for medical devices marketed in Germany. The data used in this study were directly obtained from the BfArM website5.The French National Agency for the Safety of Medicines and Health Products (ANSM) maintains a publicly accessible database for medical device safety. Data on incident reports and safety alerts related to devices marketed in France were collected from the ANSM portal4. The Manufacturer and User Facility Device Experience (MAUDE) database is maintained by the U.S. Food and Drug Administration (FDA). It is publicly accessible and offers post-market surveillance data on medical devices used in the U.S. This database was used to identify global trends for comparative purposes6. The European Database on Medical Devices is maintained by the European Commission. Although not fully functional at the time of the study, it is designed to be a centralised platform for publicly accessible information on serious incidents, FSCAs, and compliance data for devices within the EU. Available data from EUDAMED were reviewed where applicable13.
Research design
This observational and descriptive study utilised secondary data from the regulatory databases. The primary objective was to analyse trends in post-market incidents and the effectiveness of FSCAs for Class IIb and Class III medical devices in different geographic regions, with a specific focus on the comparative effectiveness of corrective actions across regions.
Data collection
Data were extracted on serious incidents for Class IIb and Class III medical devices from BfArM, ANSM, FDA MAUDE, and EUDAMED (once operational). Key variables will included device type, manufacturer, incident date, type of incident (e.g., malfunction, injury, death), and geographic location. Data on Field Safety Corrective Actions (FSCAs) were collected from all databases (Supplementary Table I)4–6,13. The key data points included the type of corrective action (e.g., recall, field modification, safety notice), the timeline for action, and the effectiveness of these actions as reflected in follow-up reports. Incidents reported in 2024 were included. The compiled dataset detailing user actions and corresponding regulatory notifications is summarised in supplementary table II4–6,13.
Results
The distribution of risks associated with medical devices across product categories and manufacturers is shown in figure 1. Manufacturer 4 had the most significant frequency of risks involved, especially in surgical/medical equipment and implanted devices, while Manufacturers 1 through 5 exhibited differing degrees of impact. There were fewer issues reported in general-use gadgets, and other manufacturers were spread more evenly throughout categories.

- This figure visualizes the affected product categories within medical device classes (Class IIa, IIb, III) and their respective risk counts, illustrating the variability of risk distribution across device types.
The impaired product categories for Class IIa, IIb, and III medical device classes are also depicted in Fig.1. With six occurrences, Class III cardiac monitoring and implanted devices had the most significant risk percentages. Class IIb has greater vulnerability due to the prevalence of infusion pumps/system issues and various implanted and specialised devices. Class IIa exhibits significant risks in surgical/medical devices as well as diagnostic and monitoring devices. A unbalanced breakdown of risks is shown in the graph, with Class III devices being more commonly implied because of their more advanced complication and vital role.
The five clusters of medical device hazards hardware/mechanical failures, calibration/accuracy concerns, software problems, contamination risks, and patient safety risks are shown in figure 2. With 25 incidents, hardware/mechanical issues were the most common among them.

- Distribution of identified risk types across five major device failure categories.
A summary of hardware failures as the main risk across different medical device categories is shown in Table. The most common problems, such as implant corrosion as well as premature wear on equipment like hip implants, are reported by orthopaedic and implantable devices, underscoring serious material fragility issues. The significance of dependable energy sources is highlighted by problems like declining battery life and broken blood pumps that follow cardiac monitoring and implanted devices. Risks during procedural usage are indicated by the major hardware issues with invasive and diagnostic devices, such as stapler misfiring and catheter breakage. While many implantable devices indicate issues including electrode deterioration and device migration, diagnostic and monitoring tools reveal moisture-related device malfunctions, highlighting the need for meticulous quality assurance among all categories.
| Device category | Number of issues | Examples of issues |
|---|---|---|
| Orthopaedic & implantable devices | 4 | Implant corrosion, premature blade dulling, premature wear on hip implants, material fragility in nerve guide |
| Cardiac monitoring & implantable devices | 3 | Battery life reduction, blood pump malfunction, battery connection issues |
| Invasive and diagnostic devices | 4 | Catheter breakage, misfiring staplers, lens fogging, fragility during sampling |
| Diagnostic and monitoring instruments | 1 | Device malfunction due to moisture |
| Miscellaneous implantable and specialised devices | 2 | Electrode degradation in neuromodulation systems, device migration |
Field modifications accounted for the largest proportion (46%), followed by software updates (26%) and recalls (22%) (Supplementary Fig. 1). As shown in supplementary table II and supplementary figure 2, the most common user actions included device replacement, performance monitoring, and software updates. Regulatory notifications were primarily directed to the FDA and relevant national health authorities.
Discussion
This study analysed incident reporting and Field Safety Corrective Actions (FSCAs) for Class IIb and III medical devices across four major regulatory databases: EUDAMED, MAUDE, BfArM, and ANSM. The findings revealed that hardware failures remain the most frequent category of post-market incidents, particularly in orthopaedic implants and cardiac devices, while software-driven devices such as insulin pumps demonstrated high recurrence rates despite FSCA interventions. Field modifications were the most frequently implemented corrective action, and although generally effective in reducing recurrence, variability in FSCA outcomes highlighted gaps in current regulatory strategies. Regional discrepancies between databases also underscored the lack of harmonisation in incident reporting and transparency across jurisdictions1,10,14
These observations are consistent with prior literature documenting challenges in high-risk medical device safety and the growing complexity of managing failures in both hardware- and software-based systems1,14–16. Studies on orthopaedic implants and cardiac monitoring devices have similarly reported durability concerns, infections, and device-related mortality risks15,16. The persistence of complications in software-based tools aligns with reports on Software as a Medical Device (SaMD), where calibration issues and algorithmic limitations reduce FSCA effectiveness11,17. The findings also reflect broader regulatory discussions emphasising proactive surveillance, as outlined in EU MDR Articles 83 and 88 and related MDCG guidance, which stress trend reporting and continuous monitoring as essential to patient safety9,18. This analysis highlights the significance of customised regulatory actions for high-risk manufacturers and illustrates how specific manufacturing practices can directly influence device dependability19,20. These findings are consistent with prior reports emphasising the role of manufacturing quality and process control in minimising post-market device failures.
A key strength of this study lies in its comparative use of multiple international databases, offering a cross-regional perspective on incident trends and regulatory responses. However, limitations must be acknowledged. First, reporting practices varied significantly across EUDAMED, MAUDE, BfArM, and ANSM, which may affect data consistency and comparability. Second, EUDAMED was not fully operational during the study period, restricting comprehensive EU-wide analyses. Third, anonymisation and inconsistent terminology in some databases may have impacted device classification. Finally, as this study relied on publicly available secondary data, it is observational in nature and does not permit causal inference regarding the effectiveness of specific FSCAs21.
These findings hold practical implications for both clinical practice and regulatory policy. For clinicians, awareness of recurring risks such as battery depletion in pacemakers or failures in orthopedic implants can guide monitoring and patient follow-up strategies to mitigate adverse outcomes. For regulators, the study highlights the need for harmonised reporting frameworks and differentiated approaches to hardware- and software-based device regulation22. The Indian context is particularly relevant: while the Materiovigilance Programme of India (MvPI) provides a foundation, it lacks the comprehensiveness of platforms like EUDAMED13,23. Establishing a centralised national registry, supported by digital health initiatives and regulatory reforms, could enhance early detection, FSCA coordination, and international alignment24. Overall, this study demonstrates that strengthening post-market surveillance, standardising data transparency, and addressing the unique challenges of software-driven devices are critical steps toward reducing patient harm and improving medical device governance worldwide9,17,25.
Acknowledgment
Authors acknowledge all regulatory agencies and databases, including EUDAMED, MAUDE, BfArM, and ANSM, for providing valuable insights and data for this research
Declaration
Authors declare that AI-assisted technology (ChatGPT, OpenAI) was used for improving grammar, readability, and structuring reviewer responses. Further authors confirm that no AI was used for scientific content, data analysis, and no images were manipulated using AI.
Financial support & sponsorship
None.
Conflicts of Interest
None.
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