Author: Julio Martinez-Clark

  • Latam Research Associates (Panama) vs a First-in-Human Device CRO (bioaccess®)

    If you typed Latam Research Associates (LR Associates, LRA, lrassociates.health) into a search box, you are probably vetting a site partner for a clinical study in Panama. This article uses only what is public about Latam Research Associates (lrassociates.health) and compares it with bioaccess®, the First-in-Human CRO for medical devices in Latin America since 2010. It is a practitioner comparison, not a teardown.

    What Latam Research Associates publishes

    Latam Research Associates Corp. is a Panama corporation (sociedad anónima) registered in Panama City on May 5, 2025, listed as active in the public company registry (registry listing). Its website, lrassociates.health, titled “LR Associates”, showed an email sign-up form when reviewed in November 2026; we found no published services, team, study list or address there. Outreach from the company describes access to affiliated doctors and medical groups in Panama.

    A search of ClinicalTrials.gov in November 2026 returned no study records mentioning “Latam Research Associates” (query). Based on its own description, it presents as a physician and site network intermediary rather than a full-service CRO.

    Latam Research Associates vs bioaccess®

    Dimension Latam Research Associates bioaccess®
    Core focus Network of affiliated doctors and medical groups in Panama First-in-human and early feasibility studies for medical devices
    Founded Registered in Panama, May 2025 Latin America, since 2010
    Public study record No ClinicalTrials.gov records found mentioning the company (Nov 2026) Published case studies on bioaccessla.com
    Device FIH track record No named device first-in-human study found on the public pages reviewed Published case studies on bioaccessla.com
    After the trial See provider site Live multi-country sanitary registration and in-country holder service

    Where each one fits

    If you only need introductions to physicians in Panama, a referral network like Latam Research Associates may be one option; ask it for its investigator list, prior sponsors and executed studies before you commit.

    If the job is a first-in-human or early feasibility study for a medical device, bioaccess® is a specialist built for exactly that, running device studies in Latin America since 2010. When the study ends, the same company can register and hold the device across the region through its market access service. Ask any CRO or site network on your list, including Latam Research Associates, for a named or de-identified device first-in-human study: device class, implant or not, number of patients, ISO 14155 monitoring plan and how the data was used in an FDA file.

    For the local regulatory path, see CRO in Panama. Other Latin American CROs are compared in the guide to first-in-human device CROs in Latin America and on the bioaccess® compare hub.

    Ready to compare a proposal? Request a first-in-human study proposal.

    Facts from the Latam Research Associates website, the Panama company registry and ClinicalTrials.gov linked above, reviewed for bioaccess® competitive research (Nov 2026). No invented sponsors, prices or contacts.

  • Changing your distributor or importer on a COFEPRIS device registration: Modality A vs. B after the 2025 simplification, and what to do if the application is still pending

    The question comes up more often than you’d think. A device company has a COFEPRIS registration filed or already granted in Mexico, and then the commercial picture changes: a new distributor, an added importer, a distributor that has to come off the file. The next email to the regulatory team is always some version of “Does this delay us, and what do we have to file?”

    I’m Julio Martinez-Clark, CEO of bioaccess®. We help medical device companies through first-in-human studies and market access across the Americas, and Mexico is one of our core countries. This article explains how COFEPRIS handles distributor and importer changes on a device registration (registro sanitario) after the 2025 and 2026 simplification agreements, and how I’d handle a change that comes up while an application is still under review.

    The short answer

    Once a registration is granted, a change to the authorized distributor in Mexico is filed as an administrative modification under homoclave COFEPRIS-2022-022-003. Since the simplification agreement published in the Diario Oficial de la Federación (DOF) on 11 July 2025, “change or inclusion of the authorized distributor in national territory” is on the closed list of resolución inmediata cases (Modality A). COFEPRIS checks the fee payment and issues a constancia without a technical review, as long as the file meets the requirements. Changes outside that list, such as a change in the company name of the holder, distributor, importer or manufacturer, go through Modality B (dictaminación), which involves an evaluation. A transfer of the registration itself (cesión de derechos) is now handled inside Modality B, not as a separate procedure.

    The modification procedures change the conditions of an existing registration. If your application hasn’t been granted yet, there’s nothing to modify. That’s where most of the timing questions come from.

    What changed in 2025 and 2026

    Before 2022, device modifications were filed under COFEPRIS-04-002, Modalities A to H. In 2022 they were regrouped into separate homoclaves for administrative changes (COFEPRIS-2022-022-003-A), technical changes (COFEPRIS-2022-022-004-A) and transfers (COFEPRIS-2022-022-005-A).

    The DOF agreement of 11 July 2025 merged the administrative and transfer procedures into one: “Modificación administrativa del registro sanitario de dispositivos médicos,” homoclave COFEPRIS-2022-022-003, with two modalities:

    • Modality A, immediate resolution. The agreement says COFEPRIS “will only validate the payment of the respective fee and issue the document,” provided the requirements are met.
    • Modality B, dictaminación. COFEPRIS may run an evaluation before issuing a resolution.

    Article three of that agreement lists the Modality A cases. The ones relevant to distribution are:

    • Change of address of the holder and/or the national distributor
    • Change or inclusion of the authorized distributor in national territory
    • Change of company name of the foreign distributor
    • Change of address of the foreign distributor
    • Inclusion of new foreign distributors
    • Removal of manufacturers (as long as at least one remains), presentations, distributors and similar items
    • All administrative and technical modifications of low-risk device registrations, except a transfer of rights

    The list is closed. Anything not expressly listed goes to Modality B.

    What goes into a distributor change file

    For Modality A, the 2025 agreement requires:

    • The modification form FF-COFEPRIS-15, fully completed
    • Proof of payment of the fee under the Ley Federal de Derechos
    • Technical, scientific and legal information that justifies the modification, following COFEPRIS’s criteria for supporting documentation on device modifications
    • If the change affects the label, a label project in Spanish that meets the applicable NOM (labeling of medical devices is governed by NOM-137-SSA1)

    In practice, the document that justifies a new importer or distributor is a letter of representation from the manufacturer that names the new party. COFEPRIS’s modification guidance asks for a letter authenticated by the legal procedure of the country of origin, with a Spanish translation by a perito traductor if it’s in a language other than Spanish or English. COFEPRIS has accepted English documents for some years, but your Mexican partner should confirm the current requirement for each document before you send anything abroad for authentication. Our guide to COFEPRIS language requirements covers this in detail.

    Also remember the label. Mexican labeling names the importer or distributor, so a distributor change usually means a new label project too. That’s the part teams forget, and it’s the part that causes the most rework.

    Timing: what you can plan on

    • Modality A is immediate resolution in principle. While COFEPRIS’s digital platforms were being adapted, the 2025 agreement’s first transitional article allowed in-person filing with a maximum of 10 business days. Treat the 10 days as the planning number until your partner confirms the digital route is working for your filing.
    • Modality B was 22 business days. The 2025 agreement cut transfers to 15 business days. A DOF agreement of 4 May 2026 cut Modality B generally to 15 business days, but its fifth transitional article says the reduction takes effect only once the supporting platforms are running. Don’t build a launch date on 15 days without checking.
    • Technical modifications (COFEPRIS-2022-022-004-A) remain at 22 business days per the official procedure listing.

    One rule matters more than the timelines. If COFEPRIS issues a prevención (a request for missing information) and you don’t answer within the deadline it sets, which can’t be shorter than five business days, the filing is discarded. You start over with a new fee and a new clock.

    When the change comes up during review

    This is the scenario sponsors ask me about most. You filed the registration naming one distributor or importer, and before the grant you need a different one.

    The modification procedures apply to an existing registration, so you can’t file a distributor modification against an application. The realistic options are:

    1. Let the application run and modify after the grant. If the new distributor can be covered by Modality A, this is usually the fastest route overall. You keep your place in the review queue, and the change is a short filing afterward. The cost is a period where the registration names a party you’re moving away from, so your commercial agreements need to allow for that.
    2. Withdraw and refile. This resets the review clock. I’d only consider it when the party named in the application can’t stay on the file, for example because the relationship has ended badly and that party won’t cooperate.
    3. Ask your Mexican partner to raise it with COFEPRIS directly. Whether a change can be absorbed into an open file, for example in the response to a prevención, depends on the file. That’s a question for COFEPRIS through your holder, not something to assume.

    Whichever route you choose, settle the question of who holds the registration before you file. In Mexico the holder needs a Mexican domicile, and many companies name their distributor as holder. That’s the arrangement that creates distributor lock-in. If the holder is independent of the distributor, changing distributors later is a Modality A filing. If the distributor is the holder, you’re looking at a transfer of rights in Modality B, which needs the holder’s cooperation and a notarized transfer agreement, and must be notified to COFEPRIS within 30 business days under article 202 of the Ley General de Salud. See our pieces on registration holder vs. distributor and transferring a registration to a new holder.

    Mistakes I see

    • Filing by dictaminación something that qualifies for immediate resolution, especially for low-risk devices, where even technical changes go through Modality A.
    • Forgetting that the label names the distributor, and filing without an updated Spanish label project.
    • Starting the manufacturer’s letter authentication late. Authentication and translation often take longer than the COFEPRIS step.
    • Planning on the conditional 15-day Modality B timeline.
    • Missing the deadline to answer a prevención, which discards the filing.
    • Naming a distributor as holder without thinking about the exit.

    Frequently asked questions

    Does adding a second distributor in Mexico need a COFEPRIS filing? Yes. Inclusion of an authorized distributor in national territory is an administrative modification. Since July 2025 it has been on the immediate-resolution list (Modality A).

    Is a change of importer the same as a transfer of the registration? No. Changing or adding a distributor or importer leaves the holder in place. A transfer (cesión de derechos) changes the holder, is handled in Modality B and needs a notarized agreement.

    Does a distributor change reopen the technical review? Not in Modality A, where COFEPRIS validates the fee and issues a constancia. COFEPRIS can still verify the constancia later and can revoke it if any information is false.

    Can I change the distributor named in a pending application? There’s no modification procedure for an application that hasn’t been granted. Most companies wait for the grant and then file the change. Ask your holder to confirm with COFEPRIS if the change can’t wait.

    If you’re planning Mexico market access, or want a holder structure that doesn’t tie you to one distributor, bioaccess® can help. See our Mexico COFEPRIS page and the Latin America market access overview.

    Sources: DOF, Acuerdo de simplificación de trámites COFEPRIS, 11 July 2025 (arts. 1–3, 7, 12; first transitional article); DOF, Acuerdo de simplificación, 4 May 2026 (fifth transitional article); DOF, Acuerdo de simplificación, 22 August 2025; COFEPRIS guide to modifications of device registration conditions; Ley General de Salud art. 202; Reglamento de Insumos para la Salud arts. 153 and 190 Bis 5; NOM-137-SSA1.

  • Importing investigational devices into Colombia for a first-in-human study: INVIMA approval, VUCE and the mistakes that delay start-up

    A sponsor gets the INVIMA approval letter for a first-in-human device study in Colombia, the team celebrates, and then someone asks the question nobody planned for: how do the devices actually get into the country? In Colombia, the approval and the import are two different steps, handled by two different parts of INVIMA, and the second one has its own paperwork. I’ve seen study start dates slip because the investigational devices sat in a warehouse while the import request was corrected.

    I’m Julio Martinez-Clark, CEO of bioaccess®. We run first-in-human and early feasibility device studies across Latin America, and Colombia is one of our core countries. This article explains how investigational device imports work in Colombia, what INVIMA’s own instructions require, and the mistakes I see most often.

    The short answer

    An investigational medical device without a Colombian sanitary registration can be imported for a clinical study only after INVIMA’s Specialized Chamber (Sala Especializada de Dispositivos Médicos y Reactivos de Diagnóstico In Vitro) has issued its concept approving the protocol. The importer then files an import request (registro, licencia o modificación de importación) through Colombia’s single foreign-trade window, VUCE 2.0, and INVIMA gives its visto bueno. The request must quote the approval document and match it exactly: product name, manufacturer, country of origin, presentation and the quantities INVIMA authorized. If the importer isn’t named in the approval, a letter proving its relationship with the sponsor must be attached.

    Step 1: the approval comes first, and it sets the quantities

    Device studies in Colombia are reviewed by INVIMA’s Clinical Research and Specialized Chamber Support Group (GICASE), created by Resolution 2022035262 of 20 September 2022. For prototype devices, the submission follows INVIMA’s checklist form ASS-RSA-FM085 and the concept request form ASS-RSA-FM172, both listed as current on INVIMA’s device clinical research page. Our INVIMA clinical trial submission checklist covers that file in detail.

    What matters for the import is what the approval says. The import request can only cover what INVIMA approved, in the quantities it approved. That means the supply plan has to be in the submission, not worked out after approval. If your protocol says 15 subjects but you need spare units, sizes, accessories or replacements for devices that fail inspection, account for them in the file. Asking for more later is possible, but it adds a step you didn’t need.

    Step 2: the VUCE import request

    INVIMA’s instruction for import requests through VUCE 2.0, IVC-INS-IN70 (version 2, implemented 1 August 2025), has a specific section for devices used in clinical studies. When the products are imported with the prior concept and approval of the review commission or the specialized chamber, box 34 of the request (“Descripción de la mercancía”) must list:

    • The number of the INVIMA act, letter (oficio) or resolution
    • The date of that INVIMA document
    • The specialized chamber or group that issued it
    • The protocol code INVIMA assigned
    • The filing number (radicado) under which the concept was requested
    • The product name exactly as approved in the act, letter or resolution
    • The manufacturer’s name
    • The country of origin
    • The commercial presentation
    • The quantities, as authorized by the commission or the relevant group
    • The condition of the goods, stated word for word (for example, “Mercancía Nueva”)

    The same instruction adds three notes. If the importer isn’t named in the approval, a letter showing the importer’s relationship with the sponsor (the party named in the approval) must be attached electronically. Clinical research protocols, including the import request, are subject to later follow-up and control by INVIMA. And if a previous import request was denied, that has to be disclosed in the “Solicitudes especiales” box.

    Where sponsors get caught

    The product name doesn’t match. The import request has to use the product name as it appears in the approval. Engineering teams rename prototypes. Commercial invoices carry internal part numbers. Packing lists use a third name. If the name on the shipping documents doesn’t line up with the approval, expect questions. Pick one name in the submission and use it on the labels, invoice and packing list.

    The importer isn’t who INVIMA expects. A US start-up can’t import into Colombia itself. Someone in Colombia has to be the importer of record, and that party is often not the sponsor named in the approval. That’s allowed, but only with the relationship letter. Decide who the importer is before you file the study, and if possible name it in the submission.

    The quantities run out. The import can’t exceed what was authorized. Sponsors who planned only for the patients in the protocol find themselves short when a device is damaged in transit, a size is wrong or the study adds a site. Build a reasonable margin into the quantities you request at the start, and justify it.

    The manufacturer or origin changes. Early-stage companies move production between a contract manufacturer and their own line, or ship from a different facility. The import request lists the manufacturer and country of origin from the approval. A change there is not a logistics detail. Talk to your regulatory team before you ship.

    Shipping before the visto bueno. Devices that arrive before the import authorization is in place sit in customs. For sterile, single-use or temperature-sensitive products with shelf-life limits, that’s not only a delay but a possible loss of the batch.

    Packaging and labeling for investigational devices

    Investigational devices go to Colombian sites in their study packaging, not commercial packaging. The import request asks for the commercial presentation and the condition of the goods, so the packaging you describe in the submission should be what actually ships. Make sure every unit can be traced to the approval and the protocol, the labels clearly identify the product as investigational, and the shelf life is visible. If your sterile barrier or packaging validation is still being finished, plan the shipment around it. Re-labeling in Colombia is not where you want to solve that.

    Biological samples going the other way

    INVIMA treats the export of biological samples for clinical studies as a separate request. Its guidance on importing supplies and exporting biological samples for clinical studies (INVIMA guide) describes, for medicine studies, declaring the exports in the initial submission and filing later requests with a dedicated form. For device studies, if your protocol sends samples to a US core lab, ask the question during the submission, not when the first sample is ready to ship.

    Clinical import vs commercial registration

    Importing for a study does not create a sanitary registration. The VUCE instruction has a separate section for registered products, which requires the registro sanitario number, expiry and shelf life, and for products without registration but authorized by INVIMA. Investigational units can’t be sold or used outside the protocol. When you’re ready to commercialize, the device goes through a registration under Decreto 4725 of 2005, which is a different file. Our Colombia INVIMA market access page explains that route and who can hold the registration, and the market access overview compares Colombia with the rest of the region.

    My checklist before you file

    1. Write the supply plan into the submission: every unit, size, accessory and spare, with a margin you can justify.
    2. Choose the Colombian importer before filing and, if possible, name it in the submission. If not, have the sponsor relationship letter ready.
    3. Fix one product name and use it in the protocol, labels, invoice and packing list.
    4. Confirm the manufacturer and country of origin won’t change before the first shipment.
    5. File the VUCE request as soon as the approval document is issued, and copy the approval data into box 34 exactly.
    6. Don’t ship until the import authorization is granted.
    7. Check that study packaging, investigational labels and shelf life are final and match what you described.
    8. If samples will leave Colombia, settle the export route during the submission.

    Frequently asked questions

    Do I need a Colombian sanitary registration to import an investigational device? No. Investigational devices are imported under the INVIMA clinical study approval, not under a registro sanitario. The import request must reference that approval.

    Can the sponsor be the importer? The importer has to be a party in Colombia that can file through VUCE. If it isn’t the party named in the INVIMA approval, a letter showing its relationship with the sponsor must be attached.

    Can I import more units than INVIMA approved? No. The import request has to match the quantities authorized. Plan for spares in the original submission.

    Is the import request reviewed after the study starts? INVIMA says clinical research protocols, including the import requests, are subject to later follow-up and control.

    If you’re planning a first-in-human or early feasibility device study in Colombia and want the import planned with the submission, not after it, bioaccess® can help. Start with our INVIMA approval timeline guide and the Colombia INVIMA page.

  • Visionware Clinical Sydney vs a Latin America First-in-Human Device CRO (bioaccess®)

    If you typed Visionware Clinical into a search box, you are probably building a CRO shortlist. This article uses only what Visionware Clinical publishes (visionwareclinical.com · visionwareclinical.com/services · visionwareclinical.com/about-us) and compares it with bioaccess®, the First-in-Human CRO for medical devices in Latin America since 2010. It is a practitioner comparison, not a teardown.

    What Visionware Clinical publishes

    Visionware Clinical is a Sydney-area (Mosman, NSW) contract research organisation that calls itself an emerging CRO in Australia and New Zealand specialising in medical devices. Its services page covers consulting, data gathering, medical writing, clinical trials and regulatory work. It says it will help design and conduct first-in-human, feasibility and pivotal trials, set up paper or electronic data capture, and support ARTG registration with the TGA. It also advises on Australia's R&D tax incentive and on setting up a local entity. Dina Peleg Kowarski is CEO and Director of Clinical Operations, with more than 15 years in clinical trials. We found no named sponsor or study on its site.

    Visionware Clinical vs bioaccess®

    Dimension Visionware Clinical bioaccess®
    Core focus Boutique Australian medical-device CRO First-in-human and early feasibility studies for medical devices
    Geography Australia and New Zealand Latin America, since 2010
    Device FIH track record No named device first-in-human study found on the public pages reviewed Published case studies on bioaccessla.com
    After the trial ARTG registration support with the TGA and post-market clinical trials, per its services page Live multi-country sanitary registration and in-country holder service

    Where each one fits

    If you want a small device-only team for a first Australian feasibility study, with ARTG support afterwards, Visionware publishes that offer.

    If the job is a first-in-human or early feasibility study for a medical device, bioaccess® is a specialist built for exactly that, running device studies in Latin America since 2010. When the study ends, the same company can register and hold the device across the region through its market access service. Ask any CRO on your list, including Visionware Clinical, for a named or de-identified device first-in-human study: device class, implant or not, number of patients, ISO 14155 monitoring plan and how the data was used in an FDA file.

    Australia sells real country features: the CTN scheme, English-language ethics and, for eligible companies, the R&D tax incentive. Those are country features, not Visionware Clinical features. The country math is on bioaccess® vs Australia, and the established Australian device EFS boutique is covered in Mobius Medical vs bioaccess®.

    Ready to compare a proposal? Request a first-in-human study proposal.

    Competitor facts from the Visionware Clinical public pages linked above and public announcements, reviewed for bioaccess® competitive research (Aug 2026–Nov 2026). Claims are theirs. No invented sponsors, prices or contacts.

  • Scientia Clinical Research Sydney vs a Latin America First-in-Human Device CRO (bioaccess®)

    If you typed Scientia Clinical Research into a search box, you are probably building a CRO shortlist. This article uses only what Scientia Clinical Research publishes (www.scientiaclinicalresearch.com.au · www.scientiaclinicalresearch.com.au/about-scientia · www.scientiaclinicalresearch.com.au/our-experience · www.scientiaclinicalresearch.com.au/sponsors) and compares it with bioaccess®, the First-in-Human CRO for medical devices in Latin America since 2010. It is a practitioner comparison, not a teardown.

    What Scientia Clinical Research publishes

    Scientia Clinical Research is a not-for-profit Phase 1 unit in Randwick, Sydney, incorporated in 2015 and based in the Bright Building on the Randwick health precinct. It has a long-term lease with South Eastern Sydney Local Health District and a service agreement with Prince of Wales Hospital for emergency support, and calls itself the only purpose-built first-in-human Phase 1 unit in central Sydney run as a not-for-profit. It claims 300+ studies completed, 24/7 participant monitoring, in-house ethics and start-up specialists, and experience in SAD/MAD, food-effect, drug-interaction, PK, biosimilar, vaccine and Phase 1 oncology studies. Its experience page lists "First In Human Medical device studies" among its capabilities, but we found no named device sponsor on the pages reviewed.

    Scientia Clinical Research vs bioaccess®

    Dimension Scientia Clinical Research bioaccess®
    Core focus Not-for-profit drug Phase 1 unit; device FIH listed as a capability First-in-human and early feasibility studies for medical devices
    Geography Australia Latin America, since 2010
    Device FIH track record No named device first-in-human study found on the public pages reviewed Published case studies on bioaccessla.com
    After the trial See provider site Live multi-country sanitary registration and in-country holder service

    Where each one fits

    If you need a Sydney Phase 1 unit for a drug, a biologic, or a device study that can run under Phase 1 confinement, Scientia is a credible choice.

    If the job is a first-in-human or early feasibility study for a medical device, bioaccess® is a specialist built for exactly that, running device studies in Latin America since 2010. When the study ends, the same company can register and hold the device across the region through its market access service. Ask any CRO on your list, including Scientia Clinical Research, for a named or de-identified device first-in-human study: device class, implant or not, number of patients, ISO 14155 monitoring plan and how the data was used in an FDA file.

    Australia sells real country features: the CTN scheme, English-language ethics and, for eligible companies, the R&D tax incentive. Those are country features, not Scientia Clinical Research features. The country math is on bioaccess® vs Australia, and the established Australian device EFS boutique is covered in Mobius Medical vs bioaccess®.

    Ready to compare a proposal? Request a first-in-human study proposal.

    Competitor facts from the Scientia Clinical Research public pages linked above and public announcements, reviewed for bioaccess® competitive research (Aug 2026–Nov 2026). Claims are theirs. No invented sponsors, prices or contacts.

  • COFEPRIS language requirements: what must be in Spanish in a Mexico medical device submission, and what NOM-137-SSA1-2025 changes

    A manufacturer sends me a clean, well-organized registration file for Mexico. The technical documentation is complete, the FDA clearance is in place and the test reports are signed. Almost all of it is in English. The first question I ask isn’t about the device. It’s this: which of these documents has to be in Spanish, who signs the translations, and which ones need a certified translator and an apostille? In Mexico, language isn’t a formatting detail you sort out at the end. It’s written into the regulation, and it’s one of the most common reasons a COFEPRIS file comes back with a request for information.

    I am Julio Martinez-Clark, CEO of bioaccess®. We act as registration holder and in-country partner for medical device manufacturers in Latin America, and we run first-in-human and early feasibility studies across the Americas. This page covers what the Mexican rules actually say about language, what changes when the new device labeling standard, NOM-137-SSA1-2025, comes into force, where sponsors get caught, and the checklist I use before a Mexican dossier goes in.

    One-sentence answer

    For a medical device registration (registro sanitario) in Mexico, every document attached to the application must be in Spanish or come with a Spanish translation signed by the Mexican responsible health officer (responsable sanitario); documents issued by foreign authorities, such as a certificate of free sale, must also be apostilled or legalized and translated by a certified translator (perito traductor); and the label project and the instructions for use or operating manual must be submitted in Spanish, with the brand name being the only label element allowed in another language.

    What the rules actually say

    Article 153: every attachment in Spanish, or translated

    The general rule sits in Article 153 of the Reglamento de Insumos para la Salud (RIS), the regulation that governs the registration of medicines and medical devices in Mexico. COFEPRIS repeats it word for word in its registration trámite guide published in the Diario Oficial de la Federación and again in the January 2020 equivalence agreement. It has three parts:

    • Documents that accompany an application must be written in Spanish.
    • If they aren’t, the applicant attaches a Spanish translation, endorsed with the signature of the responsable sanitario, the licensed professional who answers to COFEPRIS for the establishment.
    • Documents issued by authorities of other countries must be apostilled or legalized and translated by a perito traductor, a court-certified translator.

    That last line is the one that trips people up. A test report or a design description can be translated in-house and endorsed by the responsable sanitario. A certificate of free sale, a government-issued GMP certificate or an FDA Certificate to Foreign Government can’t. Those need the apostille or legalization and a certified translation.

    Article 179: label and IFU in Spanish

    Article 179 of the RIS lists what a device registration application must include. Two of the items specify the language directly: the label project in Spanish, under the applicable Mexican standard (fraction II), and the instructions for use, where they apply, or the operating manual in Spanish (fraction III). COFEPRIS’s trámite guide carries the same two items into each registration modality, including the equivalence routes for devices already approved by the FDA, and into technical modifications of an existing registration.

    Article 180: the foreign documents

    For devices made outside Mexico, Article 180 adds the documents that most often need the apostille and certified translation: the certificate of free sale or equivalent from the country of origin, the manufacturer’s letter of representation when the product isn’t made by the company applying, the GMP certificate from the health authority of the country of origin, and the manufacturer’s certificate of analysis. The trámite guide says the letter of representation must be authenticated under the procedure of the country of origin and, if it isn’t in Spanish, translated by a perito traductor.

    NOM-137: what the label must say, and in which language

    The current device labeling standard is NOM-137-SSA1-2008. Its section 4.1 requires label and counter-label information to be in Spanish, in clear and legible terms, without preventing other languages from appearing too. Text in another language can be the same size as the Spanish but can’t contradict it. If the original label doesn’t comply, a Spanish counter-label (contraetiqueta) can carry the missing health information, as long as it doesn’t cover information that affects the product’s quality or use. Section 4.1.1.2 says the distinctive name (the brand) is the only required element that can appear in a language other than Spanish.

    What changes with NOM-137-SSA1-2025

    COFEPRIS published the replacement standard, NOM-137-SSA1-2025, Etiquetado de dispositivos médicos, in the Diario Oficial on 19 May 2026. Under its chapter 11, it enters into force 360 calendar days after publication, which Mexico’s standards registry lists as 14 May 2027. At that point it replaces the 2008 standard. Its second transitional article gives devices whose labeling can’t be changed another 180 calendar days to use up existing packaging and finished product.

    On language, the core rule doesn’t move. Section 5.1 still requires label information to be in Spanish, in understandable terms with legible type and size, and still allows other languages. Section 5.7 keeps the rule that a second language can’t contradict the Spanish. Section 5.10.2 keeps the brand name as the only element allowed in another language. What’s new matters for international manufacturers:

    • Electronic complements. Sections 5.2 and 5.10.11.1 allow label information and instructions for use to be complemented electronically, through RFID, barcodes, QR codes or a website, provided the electronic content doesn’t replace or contradict what COFEPRIS authorized. In other words, a QR code can point to more information. It doesn’t remove the need for Spanish on the physical labeling.
    • Counter-labels after customs. Section 5.7.1.1 says that for imported devices, the counter-label can be applied in Mexico after customs clearance, before the product is sold or supplied. That’s a practical gain for manufacturers who don’t want a Mexico-specific label on the production line.
    • Shared responsibility for the IFU. Section 5.6 makes the health information in manuals and instructions for use the responsibility of both the manufacturer and the registration holder (titular del registro sanitario). If you use a third-party holder, they are now explicitly on the hook for your Spanish IFU.
    • Labeling under document control. Section 5.8.2 requires the holder or manufacturer to keep labeling under document control, with version control. A translated IFU that drifts from the English master is now a compliance gap, not just a quality problem.
    • Software. Section 6.3.2 allows software without a physical form or packaging to carry its labeling electronically, accessible through the software itself or a website.
    • Symbols. Section 5.9 and Appendix A set the symbols that can be used. Symbols outside the appendix or international references need a description in the labeling, and that description has to be in Spanish too.

    If you register in Mexico in 2027 or later, I’d write the Spanish label and IFU to the 2025 standard now. The label you submit with the registration has to match the authorization (section 5.5), and changing it later means a modification request.

    What about clinical trials?

    For a first-in-human or early feasibility study in Mexico, the language question shows up in the informed consent first. Mexico’s Reglamento de la Ley General de Salud en Materia de Investigación para la Salud requires, in Article 21, that the participant receive a clear and complete explanation in a way they can understand, and in Article 22, that the consent be in writing, reviewed by the institution’s ethics committee and signed by the participant and two witnesses. For Mexican participants, that means a Spanish consent form written in plain language, not a literal translation of a sponsor template. Our knowledge base guide to informed consent for first-in-human studies in Mexico goes through it in detail.

    I also plan Spanish for anything site staff will use at the bedside: the investigational device’s instructions, the training material and patient-facing documents. The COFEPRIS submission package guide for first-in-human device trials covers the rest of the study file, and the COFEPRIS pathway for first-in-human trials covers the approval sequence.

    A note for drug and biologic sponsors: the rule isn’t identical across product types. COFEPRIS’s January 2020 equivalence agreement for medicines already approved by reference regulators, including the FDA and Health Canada, keeps the Article 153 rule but lists technical and scientific documents it accepts in English. For example, it accepts full CTD reports in Modules 3 to 5 in English with Spanish summaries. Read the instrument that applies to your product. Don’t assume the device rule carries over, or the other way round.

    Where sponsors get caught

    1. Translating the certificate but not apostilling it. A certified translation of a document that was never apostilled or legalized doesn’t meet Article 153. Order the apostille in the country of origin first, then translate the apostilled document, so the translation covers the apostille too.
    2. Machine-translated IFUs with no owner. Article 153 requires the responsable sanitario to sign the translation, and NOM-137-SSA1-2025 makes the holder co-responsible for the IFU. Someone in Mexico has to read the translation and stand behind it.
    3. Labels that don’t match the authorization. The Spanish label project in the file becomes the label COFEPRIS authorizes. Marketing changes after approval, such as a new claim or a new model list, mean a modification request.
    4. Relying on a QR code. Under the new standard, an electronic link can complement the label and IFU. It can’t replace the Spanish health information on the labeling.
    5. Assuming an FDA route removes the language work. The equivalence modalities for FDA-approved devices shorten the technical review. They don’t remove the Spanish label project, the Spanish IFU or the apostille on the FDA documents. Our post on regulatory reliance in Latin America and the knowledge base page on the COFEPRIS equivalence agreement explain what reliance does and doesn’t buy you.
    6. Version drift. The English IFU gets a new revision for the US and nobody updates the Spanish one. NOM-137-SSA1-2025 now expects the holder or manufacturer to control labeling versions.

    My checklist before a Mexican device dossier goes in

    • A document list split into three columns: already in Spanish; translate and have the responsable sanitario sign; apostille or legalize, then certified translation.
    • Apostilles ordered early for the certificate of free sale, the GMP certificate and any FDA-issued document, plus authentication of the letter of representation.
    • A Spanish label project written to the current NOM-137 and checked against NOM-137-SSA1-2025 if launch will fall after 14 May 2027.
    • A Spanish IFU or operating manual, reviewed by a clinician who uses the device type, with a version number tied to the English master.
    • A decision on counter-labels: printed in Mexico after customs, or applied at the factory.
    • For any electronic IFU or QR link, confirmation that the content matches what COFEPRIS authorizes and that the Spanish health information stays on the physical labeling.
    • A named registration holder in Mexico who understands they share responsibility for the IFU. Our posts on holder vs distributor and transferring a registration to a new holder cover that choice.

    Frequently asked questions

    Can I submit my technical file to COFEPRIS in English?

    Not as-is. Under Article 153 of the RIS, any attachment that isn’t in Spanish needs a Spanish translation signed by the responsable sanitario, and documents issued by foreign authorities need an apostille or legalization and a certified translation.

    Does the device label have to be fully in Spanish?

    The required health information does. Other languages can appear alongside it, at up to the same size, as long as they don’t contradict the Spanish. The brand name is the only required element that can be in another language.

    Can a QR code or website replace the printed Spanish IFU?

    Under NOM-137-SSA1-2025, electronic means can complement the instructions for use but can’t replace or contradict what COFEPRIS authorized. For software without a physical form, labeling can be provided electronically.

    When does NOM-137-SSA1-2025 apply?

    It was published on 19 May 2026 and enters into force 360 calendar days later (14 May 2027, per Mexico’s standards registry), replacing NOM-137-SSA1-2008. Devices whose labeling can’t be changed get another 180 calendar days to use up existing stock.

    How bioaccess® helps

    We build the Mexican dossier with the language plan in it from day one: which documents get translated and signed, which get apostilled and certified, and a Spanish label and IFU written to the standard that will apply on your launch date. As registration holder, we sign for what we file. See our medical device registration in Mexico (COFEPRIS) service or the full Latin America market access overview, and our post on ordinary vs equivalence registration routes in Mexico.

  • Dominican Republic Device Registration: Titular, Representative and Co-Distributors

    Short answer: In the Dominican Republic, a medical device needs a DIGEMAPS sanitary registration (registro sanitario) before it can be imported, distributed or used. A Dominican establishment licensed by DIGEMAPS must file the application under a power of attorney from the product owner, and that local establishment is the importer of record. DIGEMAPS’s device procedures distinguish the titular (the product owner) from the local representative, and they include published routes to add a co-distributor, change the representative, or change the titular. Your control over the registration depends on how those roles are set up at filing and on what your distribution agreement says.

    This guide is for medical device manufacturers in the United States, Latin America and elsewhere who plan to sell in the Dominican Republic. It adds to our DIGEMAPS registration overview, which covers the dossier itself.

    Key takeaways

    • Registration is mandatory for medical devices. Being non-implantable does not exempt a device.
    • The application is filed and endorsed by a DIGEMAPS-licensed Dominican establishment and its technical director, under a power of attorney from the product owner.
    • Imports come in through the licensed local establishment named on the registration. In practice, the local registered party is the importer of record. A foreign manufacturer cannot import directly under the registration.
    • DIGEMAPS publishes separate procedures for adding a co-distributor, changing the representative and changing the titular. Each one runs on a power of attorney from the titular.
    • The device-specific regulation published as a draft in January 2025 is not in force. Today’s rules are Ley 42-01, Decreto 246-06 and DIGEMAPS’s published procedures.
    • The distribution agreement is where you protect the registration. Dominican distributor-protection law limits how you can end the relationship, so have Dominican counsel draft those terms.

    What rules apply today

    Three layers are in force:

    1. Ley General de Salud No. 42-01. The framework law for health products, including registration and imports.
    2. Decreto 246-06, Reglamento de Medicamentos. It is written for medicines. It has no device chapter, but DIGEMAPS lists it as the legal basis for registering productos sanitarios. The articles that matter most here are Art. 23 and 25 (who may file), Art. 31 (power of attorney from a foreign owner), Art. 77 to 79 (changes to a registration) and Art. 104 (imports).
    3. DIGEMAPS’s published service procedures for productos sanitarios. These list the documents for a new registration, a change of titular, a change of representative and the inclusion of a co-distributor.

    Proposed, not in force: the Ministry of Public Health has published a draft Reglamento de Productos Sanitarios y/o Dispositivos Médicos, dated January 2025. It would add device classes (I, IIa, IIb and III, following the EU approach), family rules and holder rules. As of October 2026 we have not seen it enacted. Treat it as a signal of direction, not as a rule you can file against.

    Who files the application

    Decreto 246-06 limits who may file and hold registrations to licensed Dominican establishments, such as manufacturing laboratories and distributors (Art. 23). The application must be endorsed jointly by the titular of a licensed pharmaceutical establishment and that establishment’s technical director (Art. 25).

    DIGEMAPS’s device registration page asks for:

    • a current copy of the sanitary registration certificate of the applicant or representative establishment, laboratory or distributor
    • a power of attorney from the product owner (empresa titular) in favor of the representative establishment in the Dominican Republic, notarized and apostilled or legalized for imported products
    • a Certificate of Free Sale from the country of origin, and a manufacturing or quality-system certificate, both apostilled or legalized
    • a ONAPI trademark certificate, where applicable

    So a foreign manufacturer cannot file on its own. It needs a licensed local establishment.

    Titular and representative: two roles

    This is the point sponsors most often get wrong.

    The medicines text in Decreto 246-06, Art. 31(c), says the power of attorney goes to the Dominican establishment that files the application, “que será el titular”, meaning that establishment becomes the holder.

    DIGEMAPS’s device procedures use different language. They refer to the “empresa titular” (the product owner) granting a power of attorney to the “establecimiento farmacéutico representante” (the local representative). They also offer separate procedures to change the titular and to change the representative.

    For devices, this means the foreign manufacturer may be able to appear on the registration as titular, with the licensed local company as representative and importer. How a given certificate names each party is something to confirm with DIGEMAPS before filing. Where the manufacturer can be named as titular, it is the stronger position, because later changes of representative run mainly on the titular’s own power of attorney.

    Who imports

    Imports go through a licensed Dominican establishment named on the registration:

    • Decreto 246-06, Art. 104, allows imports only when both the product and the establishments involved hold a valid registration at the time of import. Only persons authorized by the health ministry may import (Art. 104, Párrafo II). The article is written for pharmaceutical products and is applied to devices through DIGEMAPS practice.
    • Import permits are requested through the VUCE single window and are consigned to the product’s registered representative.

    In practice, the local registered party is the importer of record. A foreign manufacturer cannot ship directly to hospitals or buyers under the registration, and neither can a foreign consultant.

    Can more than one company import or distribute

    Yes, with the titular’s authorization. DIGEMAPS publishes a procedure called Modificación / Inclusión de Co-distribuidor for productos sanitarios. It requires:

    • the modification request form (DGDF-RP-FO-004)
    • the current registration certificate of the requesting establishment
    • a power of attorney from the product titular to the co-distributor
    • the co-distributor’s own DIGEMAPS establishment registration
    • the co-distributor’s drug and import permits, where they apply

    So a registration is not locked to one commercial partner. More than one licensed Dominican company can be authorized under it, but only if the titular grants each one a power of attorney. Before relying on this, confirm with DIGEMAPS whether each co-distributor can clear imports of your device on its own permit.

    Changing the representative or the titular later

    DIGEMAPS publishes a separate procedure for each change.

    Change of representative (Modificación de Representante):

    • the modification request form (DGDF-RP-FO-004)
    • the current registration certificate of the representative or distributor establishment
    • a copy of the product registration certificate being modified
    • a power of attorney from the registration titular to the new representative

    Change of titular (Modificación de Titular):

    • the modification request form (DGDF-RP-FO-004)
    • the original current registration certificate
    • drug and import permits, where they apply
    • a power of attorney from the registration titular to the new representative
    • documents authorizing the transfer
    • a new manufacturing contract, if the titular is not the manufacturer
    • for imported products, a power of attorney from the foreign titular to the establishment that will distribute in the Dominican Republic
    • updated label art, insert and packaging, plus an updated technical sheet and professional information sheet

    DIGEMAPS lists a response time of 90 working days for each procedure. That is a service target, not a guaranteed approval date.

    Notice what the change of titular asks for: the original certificate and documents authorizing the transfer. If a distributor is the titular and will not cooperate, it can stall the change by holding back the original certificate or files. That is why the distribution agreement matters.

    Structure options

    Setup Who is titular Who represents and imports Main risk
    Manufacturer as titular, distributor as representative Manufacturer (if DIGEMAPS names it that way) Distributor Distributor delays handing back the certificate or files
    Distributor as titular Distributor Distributor Changing partner needs the distributor’s cooperation on a change of titular
    Independent licensed company as representative Manufacturer, where allowed A licensed company that is not one of your sales distributors, supplying them Adds a logistics layer and its own fee
    Manufacturer as titular plus co-distributors Manufacturer Representative plus authorized co-distributors Each co-distributor needs its own power of attorney and establishment registration

    What to put in the distribution agreement

    These are the terms we suggest sponsors raise with their Dominican counsel. They reduce the risk that a distributor holds the registration hostage.

    • Name the manufacturer as titular where DIGEMAPS allows it, with the distributor as representative only.
    • State ownership. The distributor acts on the registration solely on the manufacturer’s behalf. The manufacturer owns the technical dossier, the data and the trademarks.
    • Register trademarks with ONAPI first. Do this before appointing the distributor, and prohibit the distributor from filing any trademark of its own for your products.
    • Limit the power of attorney to regulatory acts, for a fixed term that ends with the agreement, revocable by the manufacturer.
    • Require cooperation on demand. Within a fixed number of days after the manufacturer asks, for any reason, the distributor signs every document DIGEMAPS needs for a change of representative or a transfer. It also returns the original certificate, DIGEMAPS correspondence, import records and dossier copies.
    • Back it with a notarized special power of attorney. At signing, the distributor grants one to the manufacturer or to a Dominican law firm acting as escrow agent, so the documents can be signed if the distributor does not cooperate. Renew it periodically. This is generally more reliable than an undated letter signed in advance.
    • Prohibit retention, liens or set-off over the registration. Also prohibit cancelling it or letting it lapse, and set deadlines for renewals and for reporting DIGEMAPS requests.
    • Keep cooperation separate from money disputes, so a disagreement over compensation cannot hold up the transfer.
    • Set out who pays transfer costs, with daily penalties for delay and a dispute resolution clause.

    A note on Dominican distributor-protection law

    The Dominican Republic has a law that protects local distributors and agents of foreign companies, Ley 173-66. In general terms, ending or not renewing a distribution relationship without just cause can lead to compensation claims, and those protections may not be waivable by contract. How it applies depends on your contract, your country of origin and the facts. Consult Dominican counsel before you sign, and have them draft the term, termination and just-cause provisions.

    How the draft regulation could change this

    If the January 2025 draft is enacted as published, it would:

    • set device classes I, IIa, IIb and III. Under its Rule 6(e), short-term surgically invasive devices intended to diagnose, monitor or correct a defect of the heart or central circulatory system through direct contact would be Class III.
    • limit who may file to local laboratories and distributors, as titulares or representatives (Art. 20)
    • require a power of attorney from the foreign titular to the local applicant (Art. 28(f))
    • add a procedure for assignment of rights (cesión de derechos, Art. 90)

    None of this is in force yet. Today, DIGEMAPS asks the applicant to declare the device’s risk level in the dossier.

    Where bioaccess® fits

    bioaccess® prepares the DIGEMAPS dossier and files it together with your licensed local representative, answers DIGEMAPS questions through approval, and advises on the regulatory terms for your distribution agreement. bioaccess® does not act as registration holder, representative or importer of record in the Dominican Republic. That role belongs to a DIGEMAPS-licensed Dominican establishment.

    To start, send us your IFUs, your SKU list (code, description, device type, sizes, sterilization method, manufacturing site) and your current certificates through our contact page.

    Frequently asked questions

    Does a non-implantable device need DIGEMAPS registration?

    Yes. DIGEMAPS registration is required for the import, distribution and use of productos sanitarios in the Dominican Republic. Being non-implantable does not exempt a device.

    Can a foreign manufacturer hold the registration itself?

    It cannot file or import on its own. A licensed Dominican establishment must file and import. DIGEMAPS’s device procedures do distinguish the titular (product owner) from the local representative, so the manufacturer may be able to appear as titular. Confirm with DIGEMAPS how the certificate will name each party.

    Who is the importer of record?

    The licensed Dominican establishment named on the registration. Import permits are requested through VUCE and consigned to the product’s registered representative.

    Can I have more than one distributor?

    Yes. DIGEMAPS publishes a procedure to add a co-distributor to an existing registration. It needs a power of attorney from the titular to the co-distributor and the co-distributor’s own DIGEMAPS establishment registration.

    How do I change distributors after registration?

    File a change of representative, or a change of titular if the distributor is the titular. Both need a power of attorney from the titular. DIGEMAPS lists 90 working days for each. If the distributor is the titular, you will need its cooperation, which is why the distribution agreement should require it.

    Is the January 2025 device regulation in force?

    No. It is a draft published by the Ministry of Public Health. As of October 2026 we have not seen it enacted. Current rules are Ley 42-01, Decreto 246-06 and DIGEMAPS’s published procedures.

    Can my distributor refuse to hand over the registration?

    It can try to delay by holding back the original certificate or files. Name yourself as titular where DIGEMAPS allows it, and put cooperation-on-demand duties and an escrowed notarized power of attorney in the agreement. Dominican distributor-protection law can still affect termination, so consult Dominican counsel.

    Does bioaccess® act as holder or importer in the Dominican Republic?

    No. bioaccess® prepares and files the dossier with your licensed local representative and advises on the distribution agreement. A DIGEMAPS-licensed Dominican establishment acts as representative and importer.

    Sources

    • DIGEMAPS, Registro Sanitario de Productos Sanitarios (service page)
    • DIGEMAPS, Modificación de Titular – Productos Sanitarios
    • DIGEMAPS, Modificación de Representante – Productos Sanitarios
    • DIGEMAPS, Modificación / Inclusión de Co-distribuidor – Productos Sanitarios
    • Ley General de Salud No. 42-01
    • Decreto 246-06, Reglamento de Medicamentos (Art. 23, 25, 31, 77–79, 104)
    • Ministerio de Salud Pública, draft Reglamento de Productos Sanitarios y/o Dispositivos Médicos (January 2025, not in force)

    General information, not legal advice. DIGEMAPS requirements change; confirm the current procedure and have Dominican counsel review your distribution agreement.

  • Tecnovigilancia in Colombia: what an INVIMA registration holder must report, and how fast

    The registration is published, the first units ship to Colombia, and a few weeks later the manufacturer gets a question it didn’t plan for: who is your tecnovigilancia responsible, and where is your institutional program? In Colombia, post-market surveillance for medical devices isn’t a paragraph in the registration dossier. It’s a standing program that the manufacturer or importer has to run in the country, with a named person, written procedures and fixed reporting clocks.

    I am Julio Martinez-Clark, CEO of bioaccess®. We act as the in-country registration holder and importer for medical device manufacturers in Latin America, and this is one of the questions sponsors ask me most often after an INVIMA approval. This page covers what the rule says, the deadlines that matter, what the holder actually has to set up, and the checklist I use before the first commercial unit is implanted or used.

    One-sentence answer

    Under Ministry of Health Resolution 4816 of 2008, every manufacturer and importer of medical devices in Colombia must run an institutional tecnovigilancia program with a designated responsible person registered with INVIMA, report serious adverse events and incidents to INVIMA within 72 hours, send consolidated quarterly reports of non-serious events, notify INVIMA within 72 hours of international safety alerts on devices it sells in Colombia, and notify product withdrawals that put patients at risk.

    What the rule actually says

    The legal basis

    Colombia’s National Tecnovigilancia Program is set out in Resolution 4816 of 2008 of the then Ministry of Social Protection, issued under Article 61 of Decree 4725 of 2005, the decree that also governs device registration (registro sanitario). INVIMA’s legal compilation publishes the full text. The resolution applies to INVIMA, the departmental and district health secretariats, manufacturers and importers, health service providers, independent professionals and device users.

    The definitions that drive the clock

    Article 2 separates events from incidents, and serious from non-serious:

    • Serious adverse event: an unintended event that could have led to death or serious deterioration of the health of the patient, operator or anyone involved, as a consequence of using a medical device.
    • Serious adverse incident: a potential risk of unintended harm that could have led to death or serious deterioration of health, but did not, because of chance, the intervention of a health professional or another person, or a safety barrier.
    • Immediate reports are the reports that relate a serious event or a serious incident to a particular device. Everything non-serious goes into periodic reporting.

    The incident definition is the one manufacturers coming from other systems tend to underestimate. A near miss that a nurse caught still counts if it could have caused serious harm.

    The obligations on manufacturers and importers

    Article 9, item 1 lists what manufacturers and importers must do:

    • Design and implement an institutional tecnovigilancia program that keeps continuous track of adverse events and incidents the devices it sells may cause, so it can identify, record, evaluate and manage the reports.
    • Designate at least one competent professional as responsible for the program.
    • Report adverse events and incidents to INVIMA on the terms of the resolution.
    • Take the preventive and corrective actions that apply, plus any that INVIMA requires, immediately.
    • Tell INVIMA about international alerts on devices it sells or has sold that may still be in use, and the actions taken.
    • Cooperate with and answer INVIMA’s safety requests quickly, within the time INVIMA sets.

    What the institutional program must contain

    Article 10 sets the minimum content of the program:

    1. A designated tecnovigilancia responsible.
    2. A report form for adverse events with medical devices, or INVIMA’s own form.
    3. A data management system that protects the integrity, accuracy, reliability, consistency and confidentiality of the information and lets you follow safety problems over time.
    4. A Tecnovigilancia Manual: the institutional document that defines the devices under surveillance, the concepts of events and incidents, the surveillance and report-collection strategy, the analysis of results, and reporting to the manufacturer and the authority. Procedures must be documented and approved by the tecnovigilancia responsible and by management.

    Article 11 requires every actor to tell INVIMA who its designated responsible is. That person becomes the program’s contact with INVIMA. Article 12 makes the responsible person accountable for recording, analyzing and managing every event, recommending immediate preventive measures, telling INVIMA immediately about serious cases, and sending the quarterly periodic reports.

    The deadlines

    What happened What the holder must do Deadline Source
    Serious adverse event or serious adverse incident Immediate report to INVIMA with the information listed in Article 14 Within 72 hours of the event or incident Art. 15
    Non-serious adverse events Consolidated periodic report with the preventive measures taken, to INVIMA or the health secretariat as applicable Quarterly Arts. 16 and 17
    International alert from the parent company or any health agency on a device sold in Colombia Notify INVIMA Within 72 hours of learning of the alert Art. 20
    Total or partial withdrawal of product from the market that poses a risk to patients Notify INVIMA No fixed hour count in the resolution; notify as the withdrawal happens Art. 19
    INVIMA asks for an investigation of an event Manufacturer carries out the investigation; INVIMA monitors and can request more information until satisfied As INVIMA sets Art. 26

    The quarterly report was voluntary for the first 48 months after the resolution was issued and has been mandatory since then (Art. 16, paragraph). It isn’t optional today.

    What a periodic report has to include

    Article 17 sets the minimum content: patient age and sex; date of the event, main diagnosis, outcome and a description; the device’s generic and trade name, manufacturer, lot or serial number, model, software version where relevant, registro sanitario number, distributor or importer, and where the device was being used; whether the provider told the manufacturer or importer; actions taken and corrective or preventive measures; an internal report code; and the reporting institution, the tecnovigilancia responsible’s name, date and contact details. Article 21 makes clinical-record information in these reports confidential and limits its use to health surveillance.

    Implantables

    Article 31 makes traceability mandatory for implantable devices under Decree 4725 of 2005: each implant’s record has to be completed and kept in the patient’s clinical record at each facility so the device can be followed if needed. If your product is an implant, your distribution records have to let you trace every lot or serial number to the facility that received it. Otherwise a field action becomes guesswork.

    What INVIMA can do

    If evaluation of the safety reports shows that a device puts patients, operators or third parties at risk, even when used as indicated and properly maintained, Article 32 lets INVIMA order seizure or freezing of the product, or prohibit or restrict its use, on top of the sanitary measures available under Law 9 of 1979 and Decree 4725 of 2005.

    Where sponsors get caught

    • Assuming the foreign manufacturer’s complaint system is enough. The resolution puts the program on the manufacturer or importer in Colombia. If you sell through a local holder or importer, that company needs its own program, manual and registered responsible, and it needs a contractual line to your complaint-handling and vigilance team that works inside 72 hours.
    • Missing the international-alert clock. A field safety notice issued in the US or anywhere else starts a 72-hour clock in Colombia from the moment the importer learns of it (Art. 20). Your global vigilance team has to copy the Colombian holder on the same day, not at the next monthly call.
    • Treating the distributor as the holder. A distributor that resells your device isn’t automatically the party INVIMA holds responsible for the registration. I wrote about that split in registration holder vs. distributor, and the Colombia specifics are in Colombia INVIMA registration holder and importer of record.
    • No traceability for implants. If you can’t map serial numbers to facilities, you can’t run a targeted recall and you can’t answer INVIMA’s questions quickly.
    • Changing holders without moving the program. When a registration moves to a new holder, the tecnovigilancia responsibilities and the open case history have to move with it. See transferring a device registration to a new holder.

    From first-in-human study to commercial product

    Most of our sponsors meet Colombia first through an early feasibility or first-in-human study. During a clinical investigation, adverse events are handled under the study’s own framework: the protocol, the ethics committee and INVIMA’s clinical research approval. That process is described in our guide to first-in-human approval in Colombia. Resolution 4816 is about devices placed on the market. The practical lesson is to plan the move: the safety data and the people who handled it during the study are the best starting point for the post-market program, but the program, the manual and the registered responsible have to exist before the first commercial unit is used.

    My checklist before the first commercial unit ships

    1. Name the tecnovigilancia responsible at the Colombian holder or importer, and tell INVIMA who it is (Art. 11).
    2. Approve the Tecnovigilancia Manual and procedures, signed by the responsible person and by management (Art. 10).
    3. Adopt INVIMA’s report form or an institutional form with the same fields (Art. 14).
    4. Set up a case log that can produce the Article 17 quarterly report without rework.
    5. Write the 72-hour paths into the quality agreement between manufacturer and holder: serious events (Art. 15) and international alerts (Art. 20), with named contacts and backups on both sides.
    6. Agree on how withdrawals and field actions are decided and notified to INVIMA (Art. 19).
    7. For implants, confirm lot and serial traceability down to the receiving facility (Art. 31).
    8. Diary the quarterly report dates for the first year, and check the first one goes out on time.

    FAQ

    Who has to report adverse events with medical devices in Colombia?

    Manufacturers and importers, health service providers, independent health professionals, device users and anyone who learns of an adverse event or incident (Art. 13). For a foreign manufacturer, the practical owner is the Colombian holder or importer running the institutional program.

    How fast must a serious adverse event be reported to INVIMA?

    Within 72 hours of the event or incident, using the report form and the information in Article 14 (Art. 15).

    Are non-serious events reported?

    Yes. They’re consolidated and sent quarterly with the preventive measures taken (Arts. 16 and 17). The quarterly report became mandatory 48 months after the resolution was issued.

    Does a recall abroad matter in Colombia?

    Yes. Importers must notify INVIMA within 72 hours of learning of an international alert from the parent company or any health agency that involves a device they sell in Colombia (Art. 20).

    How bioaccess® helps

    We act as registration holder and importer for device manufacturers entering Colombia and the rest of Latin America, and we set up and run the local post-market duties that come with that role. The Colombia registration pathway is on our Colombia INVIMA market access page, and the full program is at bioaccess® market access.

    Source: Ministry of Social Protection Resolution 4816 of 2008, Articles 2, 9 to 17, 19 to 21, 26, 31 and 32, as published in INVIMA’s legal compilation. This page is general regulatory information, not legal advice for a specific product.

  • Ethics Committee Submission Requirements in Latin America, the US and Canada: A Country-by-Country Guide (2026)

    By Julio G. Martinez-Clark

    CEO, bioaccess®

    General information, not legal or regulatory advice. Requirements are cited to the regulation, the committee’s own manual or the regulator’s page. Each ethics committee can ask for more than the national minimum, so confirm the list with the committee before you file.

    In this guide: The short answer · Clocks at a glance · The core packet · Country table · How many committees · Drugs vs devices · Checklist · What gets missed · Glossary · FAQ · Sources

    The short answer

    Every country in this guide requires ethics committee approval before an interventional clinical trial can enroll. The typical packet is industry standard: protocol, investigator’s brochure, informed consent form, recruitment materials and investigator CVs, plus good clinical practice (GCP) certificates and proof of insurance, which most Latin American countries require. The ethics principles are the same for drug and device trials; device trials add device-specific technical documents.

    What changes by country is the detail, and the detail is what causes questions and delays:

    • Who reviews. A committee at each institution (Mexico, Colombia, Peru), a single committee for a multicenter study (Brazil), an institutional committee plus a national body (Uruguay, the Dominican Republic, Costa Rica), or one national committee (El Salvador).
    • Language. Spanish (or Portuguese in Brazil) for the protocol, consent and participant materials. Ecuador asks for an official translation of documents in other languages.
    • Country documents. Examples: an insurance policy that applies in El Salvador, an insurer registered in Ecuador, apostilled foreign documents in El Salvador, a consent form stamped on every page in Guatemala, and the study budget in Colombia.
    • Fees. Mexico’s committees do not charge sponsors, and Brazil’s transitional CEP/CONEP rules do not allow committees to charge for review. Panama allows fees. Peru’s committees each set their own. El Salvador’s committee publishes a fee schedule.
    • Clocks. From 10 to 20 business days in Panama to 60 business days in Ecuador. Brazil’s committees have 10 business days to check completeness and 30 business days to give an opinion.

    Ethics approval is one step in site activation. For the regulator’s review clock, see our regulator approval times guide; for the full path to first patient, see our site activation timeline guide.

    Committee clocks at a glance

    Published ethics committee review clocksBar chart of published ethics committee clocks in approximate calendar days by country.0d15d30d45d60d75d90d105dPanama · committee10–20 business daysEl Salvador · CNEIS20 business daysBrazil · CEP10 + 30 business daysDominican Rep. · CONABIOS45 business daysChile · CEC45 days (+20)Ecuador · CEISH60 business days (+30)Uruguay · institutional + CNEI60 days eachApprox. calendar days (business days x 7/5). Mexico’s national guide recommends at most 30 calendar days.Colombia, Peru, Argentina, the US and Canada leave timing to each committee.
    Published ethics committee clocks (sources in the country table)

    Only some countries publish an ethics committee clock. Most clocks start when the file is complete, and the time you spend answering questions is usually not counted.

    The core packet every committee expects

    These documents follow the international good clinical practice standard (ICH E6) for drugs and ISO 14155 for devices. They appear in most countries’ lists in some form; each committee can set its own list, so treat this as a preparation checklist:

    Document What the committee checks Device trials
    Protocol, with version and date Design, risks and benefits, vulnerable populations, statistics Same
    Investigator’s brochure Safety, preclinical and prior clinical data Device investigator’s brochure or equivalent, with risk analysis and instructions for use
    Informed consent form, local language Clear language, voluntariness, injury coverage, confidentiality, right to withdraw Same; explains the procedure and device
    Recruitment ads and participant materials Accuracy, no undue influence Same
    Investigator CVs and GCP certificates Qualified team at the site Same, plus device training where relevant
    Insurance policy or certificate (required in most Latin American countries) Coverage for participants in that country Same
    Site or institution authorization The institution agrees to host the study Same
    Contract and budget (some countries) Payments to participants and sites, no cost to participants Same

    Ethics committee requirements by country

    Country Who reviews Country-specific documents and format Fees Committee clock Official source
    Argentina An accredited research ethics committee in the jurisdiction of each site. After ANMAT authorizes the study, each site is authorized by, or notified to, ANMAT with its accredited committee’s approval. Committee accreditation is handled by each jurisdiction; confirm the local document list. Confirm with the committee. Set by the committee and jurisdiction. ANMAT Disposition 7516/2025
    Brazil Research ethics committee (CEP). For a multicenter study, a single CEP, preferably the coordinating center’s, reviews and notifies the other sites’ CEPs (Law 14,874, Art. 14). Under the transitional CEP/CONEP rules, the national commission (CONEP) also reviews special areas such as human genetics, reproduction and indigenous populations. Brazil is moving to a new national system; its national authority (INAEP) was appointed in July 2026. Consent and participant materials in Portuguese. Drug trials need both ethics and ANVISA approval to start. A decree allows an integrated ethics and ANVISA review. Committees may not charge sponsors for review under the transitional CEP/CONEP rules. Completeness check within 10 business days; opinion within 30 business days of accepting the documents. Questions suspend the clock for up to 20 business days; the researcher has 10 business days (extendable by 10) to answer. Law 14,874/2024; ClinRegs Brazil
    Chile An accredited scientific ethics committee (CEC). In multicenter studies, one committee reviews and each site carries out a local evaluation. For drug trials, the ISP file includes the protocol and investigator’s brochure in English and Spanish, the consent approved by the committee, the committee’s favorable report and an insurance policy. Confirm with the committee. 45 days for the committee’s report, extendable once by 20 days (Supreme Decree 114, Art. 18). Supreme Decree 114/2010; InvestChile
    Colombia The research ethics committee (CEI) of the site. For drug trials, the institution needs a current good clinical practice certificate from INVIMA. For studies with medicines, INVIMA’s 2025 committee guide lists the investigator’s brochure; CVs (the principal investigator needs the specialty, 3 years’ experience and a GCP certificate no older than 3 years); protocol; consent form under Resolution 8430 of 1993; recruitment materials; the study budget; and the contract. Device studies go to an INVIMA-approved committee too; see our Colombia device walkthrough. Confirm with the committee. Set by the committee’s meeting calendar. INVIMA guide ASS-RSA-GU040; Resolution 8430/1993
    Costa Rica An ethics committee (CEC) accredited by the national council, CONIS. The CEC then files the approved protocol with CONIS. CONIS publishes the registration requirements the CEC files. At social security (CCSS) hospitals, research can start 8 days after the investigator is notified of the CONIS registration and receives the ethics approval documents (CCSS instruction). Confirm with the committee. Committee: confirm with the CEC. Next step, CONIS: acknowledgment within 5 business days; technical report within 10 business days of assignment. CONIS registration requirements
    Dominican Republic The ethics committee of the site (or a recognized independent committee), then the national bioethics council (CONABIOS). Filed in person: the protocol in its original language with a faithful Spanish translation, a bound original and a digital version. The CONABIOS file includes the site committee’s approval, a letter from the site director, a no-objection letter from the national health service (SNS) for public sites, CVs with current GCP certificates, the insurance policy and the detailed budget. Submit at least 60 days before the planned start (Provision 004-A-2004). Confirm with CONABIOS. CONABIOS: final result within 45 business days; 21 calendar days for urgent protocols. CONABIOS manual; submission requirements
    Ecuador A research ethics committee (CEISH) approved by the Ministry of Public Health. The list includes the protocol in its original language and in Spanish; consent in Spanish or the participants’ ancestral language; an insurance policy from an insurer registered in Ecuador; the principal investigator’s registration with the national science agency (SENESCYT); for multicenter trials, the ethics approval from the sponsor’s home country; and the sponsor–investigator contract. All documents in Spanish, with an official translation where needed. Confirm with the committee. Opinion within 60 business days for clinical trials, counted as a legal término; 45 for studies on expedited review; up to 30 more days when clarifications are requested. Ministerial Agreement 00005-2022
    El Salvador The national ethics committee (CNEIS), through a platform shared with the regulator, SRS. The SRS route lists CNEIS approval before the regulator’s authorization. Ethics step: submission letter, application form, proof of fee payment, investigators’ medical licenses, the institution’s operating license (private sites), delegation letter and conflict-of-interest declaration. Shared step: investigator’s brochure, consent with version and date, an insurance policy that applies in El Salvador, the site’s authorization letter, CVs and GCP certificates for all staff, the protocol and the sponsor–investigator contract. Foreign legal documents must be apostilled or legalized. CNEIS publishes review fees by applicant type; confirm the current amount. 20 business days for CNEIS approval (SRS route). SRS–CNEIS platform instructions; CNEIS
    Guatemala An ethics committee authorized and listed on the national registry of the regulator, DRCPFA. The consent form must be foliated and stamped, signed and dated on every page by the committee president, coordinator or a member the committee designates. The DRCPFA file includes the committee’s favorable report and a copy of the insurance policy. Confirm with the committee. Committee: confirm with the committee. Next step, DRCPFA: 30 business days after a complete file. Ministerial Agreement 206-2021
    Mexico The institution’s ethics and research committee (CEI), plus the biosafety committee where applicable. The committee approves before COFEPRIS reviews. All documents in Spanish. Since May 2026, the COFEPRIS application carries the committee’s approval and its registration, replacing the 2025 single committee form. Ethics committees do not charge sponsors; the institution funds them. The national committee guide recommends a decision within 5 working days of the meeting, and no more than 30 calendar days from the request. ClinRegs Mexico; DOF, 28 April 2025; DOF, 4 May 2026
    Panama A research ethics committee accredited by the national bioethics committee (CNBI). The CNBI reviews new high-risk technologies and hears appeals. Submissions are electronic; the printed consent and participant materials follow approval. Documents in Spanish. The study is registered in the national research registry, RESEGIS. Committees may charge fees. Up to 20 business days (10 expedited). If the study returns to the full committee after the first review, the total is 30. Time spent answering is not counted. Appeals to the CNBI are decided within 20 business days. Executive Decree 21/2026
    Peru An institutional research ethics committee (CIEI) registered with, and for drug trials accredited by, the national institute of health (INS). The committee approves the protocol and consent form before the INS application; the INS receives the committee-approved versions. Protocol and investigator’s brochure in Spanish, with the original. Each committee sets its own fees. Each committee sets its own timeline. ClinRegs Peru (Supreme Decree 021-2017-SA)
    Uruguay The institutional ethics committee, plus the national commission (CNEI) for multicenter single-opinion studies, vulnerable populations, biosafety, and trials of new drugs, indications, vaccines, diagnostics, devices or invasive procedures. Documents in Spanish, with the originals. The insurance must be identified. Confirm with the committee. 60 days for the institutional committee; 60 days, extendable, for the CNEI. Investigators have 60 days to answer questions. Decree 158/019
    United States An institutional review board (IRB). The IRB reviews the protocol, consent, recruitment materials and investigator information under FDA rules; each IRB sets its own submission list. Non-significant-risk device studies need no IDE application to FDA; IRB approval and the abbreviated IDE requirements apply. Confirm with the IRB. No federal clock. 21 CFR 56
    Canada Research ethics board (REB) approval covering each site; one REB may cover several sites. REB approval is required for each site of a drug trial, and for a device investigational testing authorization the REB approval must reference the protocol and consent versions. Confirm with the REB. No federal clock. CTA guidance; ITA guidance

    How many committees review your study?

    • One committee per institution. Mexico, Colombia and Peru: each site’s committee reviews. In Mexico the institution’s ethics and research committee can be joined by a biosafety committee.
    • One committee for multicenter studies. Brazil: a single CEP, preferably the coordinating center’s, reviews and notifies the other sites’ CEPs (CONEP also reviews special areas under the transitional rules). Chile: one accredited committee reviews and each site carries out a local evaluation.
    • Institutional plus national. Uruguay (institutional committee, plus CNEI for trials of new drugs and devices) and the Dominican Republic (site committee, then CONABIOS).
    • One national committee. El Salvador (CNEIS).
    • Committee, then national registration. Costa Rica (CEC, then CONIS) and Panama (accredited committee, plus RESEGIS registration).
    • United States and Canada. One IRB or REB can cover several sites; check the single-IRB rules that apply to your study.

    Where each site has its own committee, plan each committee’s calendar separately. Our parallel vs sequential submissions guide covers how committee cadence affects the timeline.

    Drugs vs devices

    The ethics review asks the same questions for drugs and devices: risks and benefits, consent, participant protection and the team’s qualifications. The technical documents differ. For device trials, the investigator’s brochure is replaced or supplemented by the device description, risk analysis and instructions for use (ISO 14155 sets the international standard for device investigations), and the consent form explains the procedure and the device. In the United States, non-significant-risk device studies need no IDE application to FDA. Some country documents are drug-specific, such as Chile’s ISP file and Colombia’s 2025 committee guide, which is written for studies with medicines. Ask the committee which list applies to a device study.

    Ethics submission checklist

    • ☐ Protocol, with version number and date, in the local language (and the original where required).
    • ☐ Investigator’s brochure (or device equivalent), current version.
    • ☐ Informed consent and assent forms in the local language, adapted for the site, with version and date.
    • ☐ Recruitment ads, diaries, questionnaires and any material given to participants.
    • ☐ CVs and current GCP certificates for the principal investigator and team; medical licenses where asked.
    • ☐ Insurance policy or certificate that covers participants in the country, from a local insurer where required. See our insurance requirements by country.
    • ☐ Site authorization letter from the institution’s director or legal representative.
    • ☐ Contract and budget, where the committee reviews them.
    • ☐ Committee forms, declarations of conflicts of interest and proof of fee payment.
    • ☐ Apostilled or legalized foreign documents, and official translations, where required.
    • ☐ Registration in the national registry (for example Panama’s RESEGIS) where required.

    Requirements sponsors often miss

    These come straight from the national rules above; each one can send a file back:

    • Insurance that names the country. El Salvador asks for a policy that applies in its territory; Ecuador asks for an insurer registered in Ecuador. Our guide on the insurance certificate that starts a device study covers the wording.
    • Translations. Ecuador requires an official translation; the Dominican Republic asks for a faithful Spanish translation with the original. See Spanish or Portuguese insurance certificates for ethics.
    • Every-page stamping. Guatemala’s consent form must be stamped, signed and dated on every page by the committee president, coordinator or a designated member.
    • Investigator credentials. Colombia’s 2025 guide asks for a GCP certificate no older than 3 years; El Salvador asks for GCP certificates for all staff, national and international.
    • The sponsor’s home approval. Ecuador asks for the ethics approval from the sponsor’s home country for multicenter trials.

    Glossary

    • CEI / CEP / CIEI / CEC / CEISH. Local names for a research ethics committee in Mexico and Colombia, Brazil, Peru, Chile and Costa Rica, and Ecuador.
    • CONEP / CNEI / CNBI / CNEIS / CONABIOS / CONIS. National ethics bodies in Brazil, Uruguay, Panama, El Salvador, the Dominican Republic and Costa Rica.
    • IRB / REB. Institutional review board (United States) and research ethics board (Canada).
    • GCP (BPC). Good clinical practice, the ICH E6 standard.
    • Apostille. A certificate that authenticates a foreign public document for use in another country.
    • Expedited review. A shorter review for minimal-risk studies or minor changes.

    Frequently asked questions

    What documents does an ethics committee in Latin America require?
    The typical packet is the protocol, investigator’s brochure, informed consent form in the local language, recruitment materials, investigator CVs and GCP certificates, an insurance policy (required in most Latin American countries) and the site’s authorization. Countries add their own items, such as the study budget in Colombia or an insurer registered in Ecuador.

    Do ethics committees in Latin America charge fees?
    It depends on the country. Mexico’s committees do not charge sponsors, and Brazil’s transitional CEP/CONEP rules do not allow committees to charge for review. Panama allows fees, Peru’s committees set their own, and El Salvador’s national committee publishes a fee schedule.

    How long does ethics committee approval take in Latin America?
    Published clocks run from 10 to 20 business days in Panama and 20 business days in El Salvador to 60 business days in Ecuador; Uruguay’s committees have 60 days. Brazil’s committees have 10 business days to check completeness and 30 business days to give an opinion. Mexico’s national guide recommends no more than 30 calendar days. Colombia and Peru leave the timeline to each committee.

    Do documents have to be in Spanish?
    Yes for the consent form and participant materials everywhere in Spanish-speaking Latin America, and Portuguese in Brazil. Several countries also want the protocol in Spanish: Mexico, Peru, Ecuador and the Dominican Republic, often with the original. Chile’s regulator file has the protocol in English and Spanish.

    Is ethics approval needed before the regulator reviews?
    In Mexico, Colombia, Peru, Chile, Costa Rica, Ecuador, Guatemala and El Salvador, yes. In Brazil, and in Panama for high-risk research, the two can run at the same time. In Argentina, ANMAT authorizes the study and each site is then presented with its committee’s approval. See our regulator approval times guide.

    Is there a single ethics committee for a multicenter study?
    In Brazil, a single CEP reviews a multicenter study and notifies the other sites’ committees. In El Salvador, one national committee reviews. Chile allows one accredited committee plus a local evaluation at each site. In Mexico, Colombia and Peru each site’s committee reviews. In Canada each site needs REB approval, and one REB can cover several sites.

    Do device trials need the same ethics documents as drug trials?
    The ethics questions are the same, but the technical documents differ: the device description, risk analysis and instructions for use take the place of, or supplement, the investigator’s brochure. In the United States, non-significant-risk device studies need no IDE application to FDA; IRB approval and the abbreviated IDE requirements apply.

    Prepare your ethics submissions

    bioaccess® prepares ethics packets country by country for drug and device sponsors, and runs the submissions alongside the regulatory file. bioaccess® runs first-in-human studies in Colombia now. Contact us to plan your submissions.

    Country walkthroughs: Colombia: IRB (CEI) approval for a device study · Panama CNBI procedure checklist · El Salvador ethics approval · Ecuador ethics approval

    Sources

    • Argentina: ANMAT Disposition 7516/2025 (InfoLEG).
    • Brazil: Law 14,874/2024 (Planalto), Arts. 14 and 58; ClinRegs Brazil (NIH), including the CEP/CONEP rules and the 2026 appointment of INAEP.
    • Chile: Supreme Decree 114/2010 (Ley Chile); InvestChile pharmaceutical industry e-book.
    • Colombia: INVIMA guide ASS-RSA-GU040 (version 1, December 2025); INVIMA guide ASS-RSA-GU039; Resolution 8430 of 1993.
    • Costa Rica: CONIS registration requirements and procedure (2025); CCSS memo CENDEISSS-AB-0115-2024.
    • Dominican Republic: CONABIOS operating manual, 2nd edition, submission requirements, and Provision 004-A-2004.
    • Ecuador: Ministerial Agreement 00005-2022 (CEISH regulation), Arts. 64, 67, 84, 86 and 87.
    • El Salvador: SRS–CNEIS platform user instructions (November 2025); SRS clinical trial evaluation route (2025); CNEIS manual.
    • Guatemala: MSPAS Ministerial Agreement 206-2021.
    • Mexico: ClinRegs Mexico (NIH), citing the CONBIOÉTICA committee guide (2018); DOF agreements of 28 April 2025 and 4 May 2026.
    • Panama: Executive Decree 21 of 2026 (Gaceta Oficial 30510-C).
    • Peru: ClinRegs Peru (NIH), citing Supreme Decrees 021-2017-SA and 010-2025-SA.
    • Uruguay: Decree 158/019 (IMPO).
    • United States: 21 CFR 56 and 812.2 (eCFR).
    • Canada: Health Canada CTA and ITA guidance documents.


  • Procedural readiness for first-in-human device trials: proctoring, simulation, dry runs and sign-off

    The contract is signed, the ethics committee has approved the protocol and the devices cleared customs last week. Then the first patient is on the table, the delivery system is in the physician’s hands for the first time under live fluoroscopy, and the scrub nurse is opening packaging she has only seen in a slide deck. That’s the morning when a first-in-human (FIH) device study is most fragile, and it’s where the early protocol deviations come from.

    I am Julio Martinez-Clark, CEO of bioaccess®. We run early feasibility and FIH device studies across Latin America for sponsors who plan to take the data to FDA. This page covers how I build procedural readiness before the first case: benchtop and simulation training, dry runs in the real room, device-placement training logs, proctor sign-off and a monitor check that ties it together. It also sets out what 21 CFR Part 812 actually asks for, and what it leaves to the sponsor. It sits next to our guide on foreign proctors and field engineers at FIH cases in Latin America, which covers the permits the visiting team needs to be in the room.

    This is operator guidance, not legal or medical advice. The device’s instructions, the investigational plan and the site’s own credentialing rules always come first.

    One-sentence answer

    Before the first subject is enrolled, every person who will touch the investigational device should have practiced the procedure on a bench or simulator against written pass criteria, rehearsed the case in the actual procedure room with the actual team, had each training session recorded in a log tied to the device version and protocol version, and been signed off by a qualified proctor, and the monitor should have checked those records against the protocol steps before the site is activated.

    What the evidence says about early cases

    There is no single number for how many deviations happen in the first cases of a device trial, and I’d be careful with anyone who quotes one without a source. Two published studies are worth knowing, as long as you read them for what they measured.

    • Deviations follow a learning curve. A retrospective analysis of the VALIANT trial (Taekman et al., Quality & Safety in Health Care, 2010) looked at 12,367 patients at 931 sites and found that protocol departures were more common for patients enrolled earlier at each site. In the authors’ words, compared with the 30th patient, the first had 47% more departures. Departures were also more common at sites that enrolled slowly. VALIANT was a drug trial in acute myocardial infarction, not a device study, but the pattern is the one every device sponsor sees: the first patients at a site carry the most risk of a departure from the plan.
    • Training to a benchmark beats training for time. A randomized study in JAMA Network Open (Mascheroni et al., 2023) compared two simulation curricula for 30 novice cardiac device implanters performing a virtual cardiac resynchronization therapy implant. The group that had to demonstrate a predefined proficiency level before advancing completed 27% more procedural steps and made 73% fewer errors and 84% fewer critical errors than the group that received the same simulation training without the proficiency requirement. That was measured on a simulator, not in patients and not as protocol deviations, so it shouldn’t be quoted as a clinical trial deviation rate. What it does show is that how you gate training matters as much as whether you do it.

    FDA’s draft guidance on protocol deviations (December 2024, non-binding and not yet final) draws the operational conclusion. It says sponsors should train investigators on the protocol to help them follow it, and should also train them to identify important protocol deviations. Its list of deviations FDA considers important includes implanting an incorrect device. It also notes that a high number of deviations at a site may suggest that more resources, such as staffing or training, are needed.

    What 21 CFR Part 812 requires, and what it doesn’t

    Part 812 doesn’t use the words “simulation” or “proctor,” and it doesn’t set a number of training cases. It does set the obligations that a training program has to satisfy, and an FDA reviewer or inspector will look for evidence of them.

    • Qualified investigators. Under § 812.43(a), the sponsor must select investigators qualified by training and experience to investigate the device. Under § 812.43(c), the signed investigator agreement includes the CV and, where applicable, a statement of relevant experience with dates, location, extent and type. Under § 812.43(d), monitors must also be qualified by training and experience.
    • Informed investigators. Under § 812.45, the sponsor must give every participating investigator the investigational plan and the report of prior investigations, which under § 812.27 covers the prior clinical, animal and laboratory testing of the device.
    • Written monitoring procedures. Under § 812.25(e), the investigational plan includes the sponsor’s written monitoring procedures. Under § 812.46(a), a sponsor who finds an investigator not complying with the agreement or the plan must promptly secure compliance or stop shipments and end that investigator’s participation.
    • Supervised device use. Under § 812.110(c), the investigator may let the device be used only with subjects under the investigator’s supervision, and may not supply it to anyone not authorized to receive it. That’s the basis for keeping the local investigator, not the visiting proctor, responsible for each case.
    • Deviation records and approvals. Under § 812.140(a)(4), the investigator keeps the protocol with documents showing the dates of and reasons for each deviation. Under § 812.150(a)(4), a deviation from the investigational plan to protect the life or physical well-being of a subject in an emergency must be reported to the sponsor and the reviewing IRB as soon as possible, and no later than 5 working days after the emergency. Outside an emergency, changes in or deviations from the plan need the sponsor’s prior approval, and, if they may affect the scientific soundness of the plan or the rights, safety or welfare of subjects, FDA and IRB approval as provided in § 812.35(a).
    • Data from outside the US. When data from a study run outside the US, such as an FIH study in Latin America, supports an IDE or a marketing submission, § 812.28(a)(1) asks for a statement that the study followed good clinical practice. Section 812.28(b) asks for a description of what the sponsor did to ensure it, including the investigators’ qualifications (b)(2), how the sponsor monitored the study and ensured it followed the protocol (b)(11), and how investigators were trained to comply with GCP and to conduct the investigation in accordance with the protocol (b)(12). That last item is the most direct regulatory hook for everything on this page: you will have to describe the training, so build it so it can be described.

    In other words, the regulation tells you to use qualified people, monitor them and document deviations. Benchtop work, dry runs, logs and proctor sign-off are how I make “qualified by training and experience” something I can show to a reviewer rather than something I assert.

    The readiness stack I use

    1. Benchtop and simulation training with pass criteria

    The physician’s general experience with similar procedures is the starting point, not the finish line. A novel delivery system, a new anchoring step or an unfamiliar sizing tool needs hands-on time before it goes near a patient.

    • Train on the bench model, anatomical phantom or simulator the engineering team used to verify the device, with the same device configuration and instructions for use that the site will receive.
    • Write the pass criteria before training starts: the steps that must be completed in order, the errors that fail a run, and the critical errors that fail it outright. Agree them with the lead investigator and the proctor.
    • Train the whole team, not just the implanter. The scrub nurse prepares and hands off the device, the technologist sets up imaging, the anesthesia team needs to know the expected procedure time and the points where the patient must not move.
    • Repeat until the criteria are met, and record each attempt. Hours spent at the bench prove attendance. A passed run against written criteria shows competence.

    2. A dry run in the real room

    The bench teaches the device. The dry run teaches the room. I schedule it at the site, in the procedure room where the first case will happen, with the people who’ll be on that case’s schedule.

    • Walk the case from patient arrival to recovery. Who checks eligibility on the day, who confirms consent, who opens which package and when, where the device and its backups sit.
    • Rehearse the handoffs on the sterile field and the imaging set-up for each step of the protocol.
    • Rehearse what happens when something goes wrong: the bailout plan in the protocol, who decides to stop, which backup devices are open, how the case is documented.
    • Check that the protocol-required measurements and images can actually be captured and saved the way the case report form expects.
    • Run it in the team’s working language. In most of our sites that’s Spanish or Portuguese, and the training materials and procedure checklist should be in that language too, approved under the site’s document control.

    Much of what a dry run catches isn’t clinical skill. It’s a missing extension cable, an imaging protocol that wasn’t loaded, a step in the case report form that nobody knew how to capture, or a device box stored where the sterile nurse can’t reach it.

    3. Device-placement training logs

    If it isn’t in the log, it didn’t happen. I set up the training log before training starts, so every session is recorded the same way. For each entry the log records:

    • The trainee’s name and study role, and the trainer’s name.
    • Date, location and training format (bench, simulator, dry run, proctored case).
    • Device model and version, and the revision of the instructions for use and of the protocol used for training.
    • The specific steps practiced, the pass criteria used and the result.
    • Signatures of trainee and trainer.

    The log goes into the investigator site file and the sponsor’s trial master file, alongside the delegation log. Two checks I run every time: nobody is delegated a device task on the delegation log without a matching training entry, and when the device or the instructions change, everyone affected is retrained and the log shows it. That record is also what lets the device receipt, use and disposition records under § 812.140(a)(2) match the people who actually handled the device. We cover the accountability side in our post on investigational device accountability in FIH studies.

    4. Proctor sign-off

    Proctoring is where the device’s most experienced operator watches, coaches and, when the plan allows it, steps in. Sign-off is the documented decision that a trainee can do the next case without that support, or with less of it.

    • Define in advance who can proctor, what qualifies them and how many proctored cases the plan calls for. Write it in the training plan, not in an email.
    • Use a sign-off form with the same criteria as the bench training: steps completed, errors, how the operator handled anything unexpected. The proctor signs, and the lead investigator acknowledges.
    • Keep the roles clear. The local investigator stays responsible for the subject under § 812.110(c). The proctor advises and, where the local authorization and the plan permit, assists.
    • Get the permits sorted before you book flights. In Colombia and Brazil, a foreign physician who takes part in a procedure needs an authorization requested by the host institution, and in Panama medicine is a profession reserved for nationals, with case-by-case routes. In Brazil the medical council asks for the request at least 30 days in advance. The details for Colombia, Brazil and Panama are in our foreign proctors guide.

    5. The monitor closes the loop

    Before site activation, the monitor checks the training log, the sign-offs and the delegation log against the protocol steps. After each of the early cases, I want a short debrief within days, not at the next routine visit: what deviated from the plan, why, and whether the cause was training, the device, the protocol or the room. My rule is that if the same deviation shows up twice, it gets a root-cause analysis and, if needed, retraining or a protocol clarification. FDA’s draft guidance, which is non-binding, recommends a root-cause analysis when similar deviations recur.

    A readiness gate before the first subject

    I don’t let a site enroll until these are true and filed:

    1. Every person on the delegation log for a device task has a passed bench or simulator run against written criteria.
    2. A full dry run has been done in the actual procedure room with the first-case team, and the issues it found are closed.
    3. The training log is complete, signed, and tied to the current device version, instructions for use and protocol.
    4. Proctor qualifications, the number of proctored cases and the sign-off criteria are written into the training plan.
    5. Any visiting proctor or field engineer has the local authorization the country requires, or a documented reason none is needed.
    6. The monitor has reviewed the training records against the protocol and signed off on activation.
    7. The deviation reporting route is clear to the site team: what goes to the sponsor, what goes to the ethics committee and in what time frame.

    This gate sits after the regulatory and ethics gate we describe in our cross-functional FIH readiness gate and the investigator selection steps in how we qualify FIH sites and investigators.

    Common mistakes

    • Treating a slide deck at the site initiation visit as device training.
    • Training only the implanting physician and not the nurses, technologists and anesthesia team.
    • Measuring training in hours instead of against pass criteria.
    • Skipping the dry run because the team “does this procedure every week” with a different device.
    • Training on one device version and shipping another, without retraining or a log entry.
    • A proctor who arrives without the local authorization, so the first case moves or the proctor watches from outside the room.
    • Waiting for the next scheduled monitoring visit to review the first case’s deviations.

    How bioaccess® runs this

    On our FIH and early feasibility studies, we build the training plan with the sponsor’s clinical and engineering team, translate and control the site materials, schedule the bench sessions and the dry run around the site’s procedure calendar, file the logs and sign-offs, and handle the visiting team’s local authorizations. Our monitors review the training records before activation and debrief the site after each of the early cases. If you are planning a first-in-human device study in Latin America, you can contact us.

    FAQ

    Does 21 CFR Part 812 require proctoring or simulation training?

    Not by name. Part 812 requires investigators and monitors qualified by training and experience (§ 812.43), written monitoring procedures (§ 812.25(e)) and records of deviations (§ 812.140(a)(4)). Proctoring, simulation and training logs are the usual way sponsors meet and document those requirements for a novel device.

    How many proctored cases should a site do?

    There’s no regulatory number. It depends on the device, the procedure and how close it is to what the team already does. Set it in the training plan before the first case, and base sign-off on criteria rather than a count alone.

    Can the visiting proctor be the operator?

    Only if the plan allows it and the country authorizes it. Under § 812.110(c) the device can only be used with subjects under the investigator’s supervision, and in Colombia and Brazil a foreign physician needs a local authorization, requested by the host institution, to take part in a procedure. See our foreign proctors guide.

    What happens if there’s a deviation in the first case?

    Record it with the date and reason, as § 812.140(a)(4) requires. If it was an emergency deviation to protect the subject, notify the sponsor and the IRB as soon as possible and within 5 working days under § 812.150(a)(4). Any other deviation should have had the sponsor’s prior approval, so treat it as a compliance finding and report it the way the protocol and the ethics committee require. Then debrief the team before the next case and decide whether the cause calls for retraining, a protocol clarification or a change to the room set-up.

    Sources: 21 CFR Part 812, §§ 812.25(e), 812.27, 812.28(a)(1) and (b)(2), (b)(11) and (b)(12), 812.35(a), 812.43(a), (c) and (d), 812.45, 812.46(a), 812.110(c), 812.140(a)(2) and (a)(4) and 812.150(a)(4) (eCFR, current as of October 2026); FDA, Protocol Deviations for Clinical Investigations of Drugs, Biological Products, and Devices, draft guidance for industry (December 2024); Taekman JM et al., “Departures from the protocol during conduct of a clinical trial: a pattern from the data record consistent with a learning curve,” Quality & Safety in Health Care, 2010 (doi:10.1136/qshc.2008.028605); Mascheroni J et al., “Effect of Metrics-Based Simulation Training to Proficiency on Procedure Quality and Errors Among Novice Cardiac Device Implanters,” JAMA Network Open, 2023;6(8):e2322750 (doi:10.1001/jamanetworkopen.2023.22750).