Counter Offer Letter Template

International markets are capital to medical accessory manufacturers’ banking bloom and are continuing to abound in importance. Adaptation is an capital footfall in auspiciously bringing a medical artefact to a adopted market. An English-speaking doctor would not appetite to use a accessory or appoint medication if the accompanying advice were alone accessible in German. Imagine the adversity of appliance an over-the-counter artefact that alone comes with instructions in Japanese. Similarly, a artefact that is alone accessible in English will not adeptness its abeyant sales in adopted markets. Lionbridge (BGS) and CG-EY conducted a analysis analysis of medical accessory companies. The analysis states that1

• 90% say their charge for adaptation casework will access during the abutting bristles years.

• 80% announce that all-embracing markets comprise at atomic 25% of their absolute aggregation revenue, some as abundant as 50%.

• 65% say adaptation is analytical for authoritative approval.

• Added than 50% of all-around revenues for some arch medical artefact manufacturers appear from all-embracing markets.

• 35% say adaptation is capital for business and training.

As added companies become acquainted of the aftereffect of translation, they are alpha to ask how to construe rather than why to translate. There is a complicated and time-consuming web of regulations and business issues that charge be addressed aback it comes to all-around artefact development; about it is additionally one of the best disregarded necessities. Aback bringing a new accessory to market, accessory manufacturers should not delay until the final stages of development to activate acclamation the adaptation process. It is important to get it adapted the aboriginal time because a ailing translated artefact could accident the company’s acceptability or annual a accessible relations fiasco. Added importantly, it could actualize artefact accountability issues if the artefact is acclimated afield because of an inaccurate or cryptic translation.

Planning advanced for adaptation is the best way to save money and abstain cher downfalls such as artefact delays or a abridgement of the apparent aegis window, which can endanger abiding profits. Fixing a awry adaptation can bulk about as abundant as advice it accurately the aboriginal time, not to acknowledgment the abeyant for absent revenues while the adaptation is actuality reworked.

When gluttonous sources for translation, alertness is key. In agreement of all-around business of medical accessories and the adaptation process, requirements go above a simple artefact approval marking. Audits are advancing and companies charge to plan advanced for adaptation costs both in the antecedent development stages and throughout the activity of the product. There should be both centralized and alien audits of the adaptation action to ensure that the action has been followed and that every footfall is documented, bottomward to blockage the accreditation of the translators, reviewers, and added key players.

Preparation and Planning

The aboriginal accomplish in any activity should abide of beforehand planning and preparation. The afterward questions can advice OEMs ahead their adaptation needs:

What Needs To Be Translated? This should accommodate all documentation, packaging, software, hardware, and firmware. It is capital to accommodate all of the apparatus because authoritative additions after will adequate annual bulk overruns and activity delays. At minimum, all safety-related advice should be translated.

What Are the Authoritative Requirements? Does annihilation charge to be afflicted for the specific market? Are there specific regulations that will crave that the product, documentation, or added apparatus be adapted for one or added countries or regions? What are the acknowledged requirements for translation, testing, or annual testing in anniversary country or market? In accession to a bounded appointment or distributor, attorneys and consultants about specialize in allowance companies through this authoritative maze.

Does the Adaptation Affairs Assignment with All-embracing (Accented) Characters or Does It Charge To Be Adapted for the Bounded Market? Ensuring that the artefact accommodates different accent characteristics and standards is done through a action alleged internationalization. Adaptations may accommodate characteristic marks, such as tildes and umlauts, or characters acclimated in Asian languages.

It is abnormally important that any software acclimated in the adaptation action supports internationalization functions. Addresses and blast numbers are about bidding abnormally for assertive countries. In abounding countries, the postal cipher includes a aggregate of both numbers and letters. For example, in The Netherlands, a accurate postal cipher includes four numbers followed by a amplitude and two belletrist (e.g., “2714 GE”). Abounding software applications would adios such an access as invalid, and appropriately accomplish the abode acreage abstract in that country. In-country offices or distributors action particulars about bounded bazaar issues and what accessory changes may affect how able-bodied the artefact sells in the market.

What Action for Adaptation is Best? There are abounding adaptation models that can work, but it is important to appraise the options. Will the aggregation use a able adaptation company, freelance translators, or appoint centralized translators? There are advantages and disadvantages to anniversary model. Companies charge to adjudge which adjustment works best for their needs. A adaptation action with a accommodation timberline helps to ensure that all departments chase the aforementioned process.

Who Will Set the Absolute Analogue for the Accessory in Anniversary Country and Analysis (Validate) the Adaptation To Ensure That It Is Technically Accurate? Should a aggregation await on its benefactor or agents from the in-country appointment or should it allocution anon to physicians or medical specialists in anniversary country to do this? Medical translations crave specific adeptness of the acreage and how a medical accessory works. The purpose of the adaptation validation is not to absolute grammar, spelling, or added linguistic errors—this should already accept been done by a translator. Rather, validation is meant to ensure that the analogue and argument are actuality acclimated accurately in the ambience of the medical field. Alike translators with years of acquaintance advice in a specific acreage about do not accept the circadian adeptness of how a medical accessory is actuality acclimated in hospitals or medical clinics. Adaptation validation has been one of the best difficult issues to resolve, and alike today it causes delays for the adaptation managers at abounding medical accessory firms.

Why Actualize a Glossary? A adequate comment contains all the analogue that is analytical to the product. Not alone will the comment accomplish the adaptation added consistent, but it will additionally acceleration up the adaptation process, because translators will not acquaintance delays cat-and-mouse for description of agreement that could accept been authentic in advance. The comment should be accurate by a medical specialist from anniversary country with alive adeptness of the acreage in question.

All of these questions should be answered afore the aboriginal chat is translated or it could beggarly adjustment the adaptation later. Underprepared translations annual delays in absolution the product, which can advance to absent revenues, as able-bodied as added adaptation costs. The beforehand the adaptation action is authentic in the artefact development cycle, the better.

Regulations

Just as FDA regulates the manufacturing, marketing, and use of medical accessories in the United States, added countries accept regulations specific to medical devices. It is above the ambit of this commodity to awning all the regions of the world. However, because Europe accounts for about 30% of apple revenues for medical equipment, the regulations for adaptation of medical accessories in the the European Union (EU) affect a ample allocation of all-around accessory distribution. The EU is additionally different because bartering accessories to these countries bureau advice into several languages. Table I lists the official languages of associates and applicants in the EU. A few of the added above markets (Japan, Korea, and China) additionally crave some authoritative consideration.

The European Union. To bazaar articles aural the EU, manufacturers charge accede with the Medical Accessory Charge (MDD 93/42/EEC), the Active Implantable Medical Accessories Charge (AIMDD 90/385/EEC), or the In Vitro Analytic Charge (IVDD 98/79/EC).2–4 The MDD covers a array of medical devices. The AIMDD accurately covers implantable medical devices, and the IVDD covers accessories acclimated to analysis tissue, blood, and added fluids for diseases (such as HIV or hepatitis, claret levels of cholesterol or glucose) or abundance tests. The directives are absolutely agnate in how they administer to translation, so an all-embracing attending at the accent requirements of the IVDD can acknowledgment the aggregate of questions.

Medical accessories and accessories are authentic in the EU directives as Class I through Class III, with requirements adequate added circuitous depending on the classification. Higher-risk accessories in Class II and Class III, as able-bodied as best Class I devices, charge third-party acceptance and a registered EU representative. Companies that bazaar these accessories in the EU may additionally be adapted to accumulate abreast copies of assertive affidavit at their European offices or at the offices of an EU representative.

Some low-risk Class I accessories do not crave as abundant affidavit or, in some cases, may not alike charge to be certified by an absolute notified body. A notified anatomy is an alignment (such as Underwriters Laboratories in the United States, TÜV in Germany, or TNO in The Netherlands) that has been appointed by an EU country to accomplish acquiescence appraisal of medical devices.

Conformité Europeéne (CE) mark

CE Mark. With the accomplishing of the IVDD, which took aftereffect in December 2003 with broadcast requirements in December 2005, all new in vitro medical accessories marketed and put into annual charge accept the Conformité Europeéne (CE) mark. As declared in Commodity 4 branch 1, “Member States shall not actualize any obstacle to the agreement on the bazaar or the putting into annual aural their breadth of accessories abode the CE appearance provided for in Commodity 16 if these accessories accept undergone acquiescence appraisal in accordance with Commodity 9.” This allows in vitro accessories that accede with the charge and that accept the CE mark to be marketed and awash in the EU after added testing or approvals from anniversary affiliate country. CE appearance saves cogent time and money because companies do not accept to assignment through abstracted regulations for anniversary alone EU country.

IVDD Annex 1, Section B, branch 8.1 states, “Each accessory charge be accompanied by the advice bare to use it cautiously and properly, demography annual of the training and adeptness of the abeyant users, and to analyze the manufacturer.”

Regulations apropos adaptation of medical accessories adapt from country to country, and the capital differences can be activate in the breadth of accessible exceptions apropos articles for able use. In some EU countries, English affidavit may be adequate for articles that would be acclimated alone by professionals. However, all safety-related documents, such as instructions for use, user manuals, artefact or carton labels, and charwoman instructions charge be in the official accent of the country in which the accessory is sold. In addition, analytic analysis abstracts protocols, analytic studies results, abreast accord forms and accompanying documents, and case abode forms may charge to be translated. Therefore, depending on the allocation of the medical device, the IVDD, MDD, and AIMDD all crave adaptation of all safety-related affidavit or business collateral.

Japan. The Japanese bazaar for medical articles is estimated to be account added than $20 billion annually.5 Medical accessories are adapted beneath Japan’s Pharmaceutical Affairs Law administered by the Ministry of Health, Labor, and Welfare (MHLW). To bazaar a medical artefact in Japan, a architect charge access shonin (manufacturing artefact approval) for high-risk accessories ensuring the assurance and capability of the product. In addition, a architect needs a kyoka (license). The allotment provides allotment for an OEM to bazaar articles in Japan.

Medical accessories avalanche into one of three categories depending on the bulk of abeyant risk—highly controlled (high-risk), controlled (low-risk), and accepted (very low risk). Typically, all abstracts submitted for a shonin application, as able-bodied as all assurance documents, charge be in Japanese. This is a ample undertaking, abnormally for companies after a adaptation affairs in place.6

Korea. The Korea Food and Drug Administration (KFDA) allowable its Medical Accessories Act in May 2003. It is agnate to the arrangement acclimated by FDA. However, manufacturers should not await alone on FDA adeptness to cross characterization and added adaptation requirements in Korea. Medical accessories charge be registered with KFDA afore commercialization.

China—CCC Mark. The State Food and Drug Administration (SFDA) in China regulates alien medical devices. The State Administration for Entry-Exit Inspection and Quarantine issues assurance licenses for x-ray equipment, dialysis equipment, claret ablution equipment, electrocardiographs, implantable pacemakers, and ultrasound equipment. For assertive high-risk devices, the China Compulsory Acceptance (CCC) mark is required. Accessories abide a allotment action based on classification. Class III devices, for example, crave testing by a Chinese laboratory. All assurance advice charge be in Chinese for high-risk devices.

Medical accessories charge accommodate instructions for use in Mandarin Chinese adaptation aback importing into China. The adaptation charge be done afore the artefact is accustomed to access the country.

Because of these beefy requirements, best medical accessory manufacturers either accept their own administering authoritative anatomy or argue with authoritative specialists or consultants.

Translation Strategies

Some companies use centralized assets such as multilingual employees, while others attending to their distributors and added artefact assembly for translation. Others may appetite to appoint a able adaptation agency.

Whatever adaptation action is chosen, manufacturers charge use a constant and academic action with accepted operating procedures. Adaptation requires accurateness beyond the lath in all industries; however, medical adaptation is a acute process. Animal activity is at pale and, therefore, medical adaptation requires tighter processes and accurateness in translations that are edited and validated, bifold and amateur checked.

For these reasons, manufacturers may feel it is best to appoint that blazon of expertise. Vendors charge be inspected, accept references, and should accept a academic action in place. Ideally, a adaptation bell-ringer complies with ISO 9001. But aloof because the adaptation close has experience, doesn’t beggarly the accessory architect can decrease itself from the process. There are analytical questions manufacturers charge to ask.

Translators

Find out what types of translators the adaptation aggregation is using. What is their accomplishments and adeptness akin of the industry? It is not abundant to accept a translator that artlessly speaks the language.

Manufacturers should feel adequate allurement to analysis the résumé and accreditation of every translator. Highlighting industry-related needs (such as ISO 9001 certification) can advice attenuated the acreage of abeyant adaptation providers. Companies can depend on able translators to accomplish antecedent translations and edits. But they may appetite to go a footfall added to validate the assignment appliance their own resources.

For example, Philips Medical Systems uses a adaptation annual provider for its imaging and analytic products. The radiology and oncology capacity in accurate accept absolute specific analogue needs. Already the adaptation aggregation has done the antecedent analysis as able-bodied as an edit, Philips uses its own validators for anniversary accent and division. Not alone do they seek translators with medical backgrounds, they seek translators who accept radiology and oncology. Accessory companies charge accept translators that are accustomed with the analogue and accept the processes surrounding the equipment.

That archetype represents a absolute specific adaptation need, but it shows about how companies are acclamation adaptation accurateness internally.

It is additionally important to get a sample adaptation from the aggregation to see how able-bodied they will assignment with centralized agents and to barometer how the activity will be managed. Typically, 2000–3000 words is a reasonable bulk of argument for a adequate appraisal of the agency’s appearance and adeptness of a specific field. If you accept a comment and added advertence material, you should accommodate it with the sample adaptation task.

Realize that adaptation is not a one-way process. There should be approved advice amid the architect and the adaptation supplier. A adequate translator will ask questions to analyze the acceptation of the antecedent argument and to bigger accept the product. The manufacturer’s captivation should not end aback the absolute is angry over to the adaptation company.

There are bags of adaptation and localization agencies worldwide, so it may be advantageous to alpha the chase with a accordant barter affiliation such as the Globalization and Localization Affiliation (GALA). The Web site, www.gala-global.org, appearance a basal chase agent that can advice analyze assorted types of adaptation companies.

Terminology Lists and Software

Most companies advance analogue lists or glossaries for new products. This can be a time-consuming process, yet it is the foundation for the absolute adaptation and bounded accent product. It should be as absolute as accessible by including all key software, documentation, and added artefact agreement and phrases. A analogue account should be advised by the adapted bodies in-house, including in-country staff, distributors, or validators. It is analytical to absorb close acknowledgment and anatomy abutment for the adaptation activity from the onset.

Once analogue development has taken place, some blazon of adaptation anamnesis (TM) software can be acclimated to accomplish the adaptation activity added efficient. TM software is acclimated to advantage repetitive phrases and terms. This bureau that a translator can construe a book once, and every added time the book or a agnate book appears, the apparatus will accompany it to the absorption of the translator. Reducing the cardinal of words that charge to be translated after-effects in bulk reduction, alike the aboriginal time a artefact is translated. And because of the foundation congenital with TM tools, approaching updates could see alike greater bulk efficiency.

A architect may accept to advance in such software for centralized use. At the absolute least, companies should crave that the adaptation aggregation they arrangement with use TM software. The TM apparatus is advantageous and can advice save time and money.

Relying alone on adaptation tools, such as TM software, for a adaptation activity is not a adequate idea, although it may be tempting. Computer-assisted adaptation consistently requires animal alternation for checks and balances, because all languages advance and change. Subtle byword changes can badly adapt meaning, sometimes far added bound than software can be updated. Aback it comes to acute adaptation in the case of medical applications, it is capital to accept a animal duke in the process.

Accuracy Testing

As mentioned earlier, abounding companies booty on accurateness blockage by appliance their own adaptation validators. Some may accredit to this as an in-country analysis in which the documentation, or added translated material, is advised by an absolute built-in apostle from the bazaar country. Ideally, this is a physician, medical specialist, or addition with acquaintance in the specific field. This blazon of testing about comes in the anatomy of readability testing; however, there are instances in which companies and adaptation annual providers are assuming absolute user interface testing.

It is important to agenda that at this date of the development, adaptation validation is carefully a textual one. Already the antecedent translations accept been made, the validation appearance is not the time to accomplish changes to the messaging. It is not the job of the validators to accomplish any changes, alone to ensure the abstruse accurateness of the adaptation and the able use of terminology. Changes to the artefact messaging should be fabricated afore the adaptation action anytime begins. Beneath the EU directives, all accent versions should accommodate the aforementioned information, so if a validator in one country insists on authoritative additions to the instructions for use, these should be congenital into all added languages as well. In acute cases, this may additionally beggarly that the notified anatomy will accept to accept the revised antecedent text.

Many medical adaptation companies assignment with medical specialists for this blazon of validation as an added service. But because validation has consistently been a difficult affair for OEMs and adaptation companies, an OEM may appetite to attending into third-party companies to abode medical adaptation validation. For example, some companies action accuracy-testing measures. One aggregation distributes accommodating questionnaires to focus groups of all-embracing populations to appraise the dash of cultural sensitivity. Added casework may accommodate aback translation. The argument is translated into the bazaar accent and again aback to English. The two versions of English argument are again compared to verify that the adaptation match.

Postmarket Translations

Translation doesn’t end already the artefact is on the market. As articles are updated, the charge for adaptation is ongoing. However, already the antecedent advance has been made, adaptation becomes easier and beneath costly. Updates of articles with astronomic amounts of documentation, as best medical accessories assume to have, become abundant easier as a company’s TM database grows. For example, one Philips’ radiology arrangement contains over 2000 pages of documentation. Appliance its TM database, the aggregation may alone accept to construe 100-200 pages for a archetypal update. That bureau the aggregation does not accept to absorb abundant time or bulk to construe the abstracts and can accordingly get the artefact to bazaar quickly.

Companies with the staff, resources, and adeptness about accept the adeptness to auspiciously action through the intricacies of medical accessory translation, but alike the better companies may charge to about-face to adaptation agencies that specialize in the adaptation of medical and bloom science products. Whatever the process, however, companies charge accept accepted operating procedures in place, be accustomed with the ambition markets’ regulations apropos translation, and activate the action of adaptation early. The goals are to get articles to market, accommodate to bounded regulations, and back the bulletin of the artefact accurately and professionally.

Jackie Walsh is the PR Specialist for the Globalization and Localization Affiliation (GALA). She can be accomplished at [email protected]. Daniel Carter is a founding affiliate of GALA.

Reference

1. “Surveys: An Analysis of Bazaar and Customer Needs” (Waltham, MA: Lionbridge, 2004.).

2. European Union Charge 93/42/EEC, Medical Accessories General.

3. European Union Charge 90/385/EEC, Medical Accessories Active Implantable.

4. European Union Charge 98/79/EC, Medical Accessories In Vitro Diagnostic.

5. U.S. Department of Commerce, “Healthcare and Medical Articles [online] (Tokyo: U.S. Commercial Annual Japan, 2006); accessible from Internet: www.buyusa.gov/japan/en/medical.html.

6. Martin A. Yahiro and Kiyohito Nakai “Japan’s New Authoritative System,” Medical Accessory & Analytic Industry 24, no. 10 (2004) 64–69.

Bibliography

Lang, Yves. “Regulatory Accent Requirements and the IVDD.” ENLASO Corp., 2005.

“Labeling and Accent Requirements beneath the IVD Directive,” Andres Heuberger, ForeignExchange Adaptation Inc., 2003.

Copyright ©2006 Medical Accessory & Analytic Industry

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