Adverse Event Reporting — What Must Be Reported
Legal basis
The obligation to report adverse events is set out in the HP(MD) Regulations 2010 and applies to all companies dealing in medical devices in Singapore — importers, manufacturers, wholesalers, and registrants.
What is a reportable adverse event?
A reportable adverse event (AE) is any malfunction or deterioration in the characteristics or performance of a medical device, or any inadequacy in labelling or instructions for use, that has led to, or could lead to, the death or serious deterioration in the state of health of a patient, user, or other person.
This includes:
- Serious injury or death caused by or suspected to be caused by the device;
- Near-miss events where a malfunction occurred but serious harm was avoided by chance or timely intervention;
- Device malfunctions that, if they recurred in a similar situation, could lead to serious harm;
- Incorrect results from an IVD that led to, or could have led to, incorrect treatment causing serious harm.
Who must report
All of the following must report AEs involving devices they deal in:
- Importers of the device
- Manufacturers (local manufacturers)
- Wholesalers
- Registrants (product registration holders)
Healthcare professionals and hospitals are encouraged to report AEs but are not subject to the same mandatory reporting obligations as dealers. HSA operates a separate voluntary reporting system for healthcare institutions.
What does not need to be reported
Not every device-related complaint or incident is a reportable AE. Events that do not need to be reported include:
- Deficiencies in device performance that are expected based on the device's known characteristics and do not cause patient harm;
- Complaints resolved by device replacement where no patient harm occurred and no safety trend is indicated;
- Events caused entirely by patient condition unrelated to device performance.