Creating a Periodic Safety Update Report (PSUR) that Complies with MDR & IVDR

February 1, 2023

The Periodic Safety Update Report (PSUR) is one of the new postmarket surveillance (PMS) activities required by EU MDR and EU IVDR.

These new regulations represent a complete overhaul of the past EU regulations for medical devices and in-vitro diagnostic devices—notably in the addition of more rigorous PMS and vigilance requirements. So in this article, I want to focus specifically on the PSUR and help you understand what it is, what it includes, and whether your device needs one.

BONUS RESOURCE: Click here to download your free PDF copy of our Periodic Safety Update Report template.

What is a Periodic Safety Update Report (PSUR)?

The Periodic Safety Update Report is one of two new reports on postmarket surveillance that medical device manufacturers are required to maintain and submit to their Notified Body (NB) on a recurring basis.

The PSUR is a summary of the results of postmarket surveillance activities as well as the conclusions that manufacturers have drawn from those results. If the manufacturer has taken any corrective or preventive actions (CAPAs), a description and rationale for the actions must also be included in this report.

The Periodic Safety Update Report is part of a device’s technical documentation, and it has to be updated throughout the device’s lifecycle. The PSUR is initially submitted to a Notified Body during the device’s conformity assessment audit, but from then on it must be updated either annually or biennially.

The full requirements for your PSUR can be found in Article 86 of MDR or Article 81 of IVDR.

What’s the difference between a PSUR and a PMSR?

I mentioned that there are two reports required by MDR and IVDR. We’ve covered the PSUR, but there is another, similar report known as the Post Market Surveillance Report (PMSR).

Depending on the type of device and its classification, you will need to compile either a PMSR or a PSUR. Here’s when to use them:

Type	Classification under MDR or IVDR	PMSR or PSUR	Submission Protocol	Update Frequency
MEDICAL DEVICE	Class I	PMSR	Upon request	As necessary
	Class IIa	PSUR	During Conformity Assessment for Notified Body review	Every 2 years, at minimum
	Class IIb (non-implantable)	PSUR	During Conformity Assessment for Notified Body review	Every year, at minimum
	Class IIb (implantable)	PSUR	Via EUDAMED for Notified Body review	Every year, at minimum
	Class III (all)	PSUR	Via EUDAMED for Notified Body review	Every year, at minimum
IVD	Class A, B	PMSR	Upon request	As necessary
	Class C	PSUR	During Conformity Assessment for Notified Body review	Every year, at minimum
	Class D	PSUR	During Conformity Assessment for Notified Body review	Every year, at minimum

Periodic Safety Update Report (PSUR)

To summarize,

The PSUR is required for moderate and high risk devices. This includes medical devices that are classified as IIa, IIb, and III under MDR as well as implantable devices. It also applies to IVDs that are Class C or D under IVDR.
For Class IIa medical devices the PSUR is a biennial requirement.
For Class IIb and III medical devices and Class C and D in-vitro diagnostics, the PSUR must be submitted annually.
The PSUR for Class III and implantable medical devices and Class D in-vitro diagnostics must be submitted via EUDAMED. This requirement can be found in Article 86(2) of MDR and Article 81(2) of IVDR. Both articles reference “an electronic system” that readers should take to mean EUDAMED.

Post Market Surveillance Report (PMSR)

The PMSR is very similar to the PSUR—it is also meant to summarize results and conclusions from your postmarket surveillance, and it also includes the rationale for, and description of, any CAPAs. However, there are some key differences:

The PMSR is required for Class I medical devices and IVDs in Class A and B. Essentially, the PSMR is for low-risk devices and the PSUR is for those with a moderate or high risk.
Your PMSR must be maintained and available to EU Competent Authorities upon request, but it does not need to be submitted on a regular basis. The MDR recommends updating your PMSR at least once every three years.

What do I need to include in my PSUR?

At minimum, your PSUR should include the following:

Your postmarket surveillance data

The conclusions of your benefit-risk analysis

A description of any CAPAs and the rationale behind them

The findings of your Post Market Clinical Follow-up

The device’s sales volume and an estimate of the user population

The frequency of the device’s usage (if practical)

An analysis and summary of all the information listed above

This last point is important, because the PSUR is not about checking boxes. The Periodic Safety Update Report is intended to be an analysis of the postmarket data your company has actively collected. It’s a meaningful, regularly updated report that should help both regulators and internal stakeholders understand the safety and efficacy of your device during its time on the market.

BONUS RESOURCE: Click here to download your free PDF copy of our Periodic Safety Update Report template.

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Sara Adams

Sara Adams is a Medical Device Guru at Greenlight Guru and a Certified ISO 13485 Lead Auditor who began her career in the medical device industry in the post-manufacturing world. As an experienced Quality Engineer, she has been responsible for leading Corrective and Preventive Action (CAPA) investigations and...