Regulation

 

Recycling of orthodontics devices
(brackets, bands, Archwires, Quad Hélix, Facebows)


I. Recycling and regulation


II. Obligations as regard EC marking


III. Offence of fraud

A-Material element of the infringement
B-Intentional element of the infrigement

 

 




I. Recycling and regulation

If you are not amenable to the European Community, there does not exist actually specific regulation. Recycling is free.

If you are amenable to the European Community, recycling is governed by Directive 93/42/CEE. In this case it is advisable to distinguish the medical devices which are "single use" of those which are reusable.

All the manufacturers claim single use for the brackets. This claim is founded. The removal of the composite is delicate and cannot be implemented by the orthodontist without damage. Only the manufacturer or a competent organism could carry out such a work. For technical and commercial reasons, the manufacturers do not wish to recycle the brackets. The only possibility consists in using the old bracket like raw material to manufacture a new bracket, as a paper maker uses the old paper to manufacture a new one.

The recycling of the brackets demand a manufacturing process which takes again some procedures of manufacturing new bracket and adds other procedures such removal of the adhesive. Final control cannot be statistical but must relate to each part as in aviation. The recycling process is less expensive in machining is more expensive in term of quality control. The control of each part gives a considerable asset to recycling. The number of new brackets not conform is not negligible (torque, angulation, welding of the studs on the basis reversed...). The recycled bracket does not have anything to envy the new bracket if work was carried out correctly.

As Re-manufactured, the recycled bracket must imperatively carry a new EC marking. Juridically, it is a new product put on the market by the recycling firm which is the "manufacturer" according to directive 93/43/CEE. Another approach which consists in telling that the bracket "is overhauled" comes amounts to the same thing, the directive indicating that the company which overhaul a medical device assumes the responsibilities of the manufacturer.

The localisation of the recycling company in France, Europe or outside Europe does not mind. To offer its services to orthodontists of the European Community, it must affix EC marking on the recycled brackets. The orthodontist who uses not EC marked products does not respect the reference can be attacked for fraud by his patients and encounter serious problems in the event of control by the authorities. The laboratories which claim to conform to Directive 93/42/CEE but which was not certified work illegally and cannot be considered as serious. The self certification has no legal value for medical devices placed in IIa class. The directive requires before EC marking the control of a notified body. We give the position of Master Lucas Baloup, lawyer quoted by the SFODF (article of May 2002 of the Review of Orthopedy Dento Faciale) which we consulted to know his position on the activity of our competitors which work without being certified and on risks for the orthodontists.



II. Obligations as regard EC marking

1. According to the devices of the L.5211-3 article:

"The medical devices cannot be imported, placed on the market, brought into service or be used, if they did not receive, as a preliminary, a certificate attesting their performances like their conformity with essential requirements relating to the safety and the health of the patients, the users and the third parties."

2. The article R.665-5 2° defines the placing on the market as:

"a)The setting on sale, the sale, the placing at disposal with payment or free, the transfer of all type, of a medical device other that a device having to be the subject of clinical investigations, that it new or overhauled;[... ]"

Besides, the second subparagraph of the 3° recalls:

"The obligations which are essential to the manufacturer under the terms of the present book are also indispensable to the person or entity which assembles, conditions, milked, overhauls or labels medical devices, or assigns to prefabricated products the destination of medical devices with a view to put them on the market on its own name.[... ]"

3. Articles R. 665-7 and R. 665-8 impose that any medical device "placed on the market or brought into service" in France is in conformity with those of the requirements mentioned in R.665-12 which are applicable for him, taking into account its destination, and is covered EC marking attesting that it meets the conditions stated by the R.665-7 article.

4. The recycled brackets are the subject of a new placing on the market and, consequently, must receive as a preliminary EC marking.

5. The violation of this rule is sanctioned by the R.665-43 article which institutes, without prejudice of the application of the penal sanctions and the administrative measures envisaged in book II of the code of consumption, punishment of penalty, planned for the infringments of 5th class (1500 euros, amount which can be carried to 3000 euros in the event of cases of relapse), inflicted to the persons or entities which, in particular:

" 1°[... ] will have placed on the market a medical device not covered of a EC marking whenever the affixing of this marking is necessary; [... ]

3°[... ] will have placed on the market a medical
device obviously nonin conformity with the essential requirements of safety mentioned with the R.665-12 article which are applicable for them;"

Consequently, those of your competitors which do not observe these procedures expose to these punishments.


III. Offence of fraud

 - A-Material element of the infringement:

1. Penally, to market brackets not fulfilling the requirements of the regulation on the medical devices, is likely to raise the offence of fraud envisaged, with the L.213-1 article of the code of consumption:

" will be punished of a two years imprisonment to more and of a penalty of 37 500 euros to more or one of these two punishments only, whoever, that is or not bounded by the agreement, has misled or tried to mislead the contractor, by some means or process that it is, even by the intermediary of a third:

1° either on the substantial nature, species, origin, qualities, the composition or the content of useful principles of all goods;

2° either on the quantity of the thing delivered or their identity by the delivery of other goods than previously defined in the contract;

3° either on the operating requirement, the risks inherent in the use of the product, controls carried out, the instructions or the precautions to take;

1 [ L.213-2 article of the code of consumption envisages the doubling of the punishments, in particular if the offences resulted of the use of dangerous goods for the health of the man or the animal, or if the offence or the attempt at offence envisaged with the L.213-1 article were made using fraudulent indications trying to make believe to a former and exact operation.]

This infringement, can be charged to whoever, without distinction between the defrauders, merchants or consumers, nor between the commercial or civil contracts.

2. The fraud would relate here to the purpose (brackets) of a contract between the laboratories which do not have a certificate of EC marking and their customers.

In the business known as of "contaminated blood", accused were declared guilty of fraud because of no respect of the provisions of the articles L.661 and following (new L.1221-1 and following) of the code of the public health service (Cass. crim. June 22, 1994, JCP 1994 II 22310, score Mr.-L.Rassat).

In a very extensive idea, case-law retains that the concept of fraud "consists of a lie made during the formation or execution of the contract, and in that only, since it is not necessary that it is resulted from it a damage. The lie can be purposely or not, but in practice, it generally results from reserves ".

3. The contractual lies are not all punishable. The L.213-1 article referred to above gives a long enumeration of it.

So, your competitors which are freed from the obligations which fall to them, could be possibly be blamed for having made this infringement in connection with:

(a) Substantial quality:

The Supreme court of appeal admitted that substantial qualities of a foodstuff can result from data registered in the national and Community regulations or the uses (Cass. crim., March 30, 1994, JCP 1994 IV 1672).

In the situation which occupies us, substantial qualities of the brackets emanate from directive 93/42 the EEC and its transposition in the law. Considering the orthodontists who "make them recycle", or more generally the companies which do not apply knowingly or not this standard, the offence of fraud could be made up.

(b) Of the risks inherent in the use of the product:

This type of lie was evoked, with that of the operating requirement, at the time of the lawsuit known as of contaminated blood, against an importer of toys "provided with a label mentioning their conformity to the obligatory standards wrongfully" (CA Paris, March 18, 1992, Juris-Dated 1992-020822) thus also, at the sides of the fraud on substantial qualities, in connection with an electric material not answering the safety requirements (Cass. crim. April 10, 1997, JCP 1997 IV 1780).

"The importation, the placing on the market, the putting into service or the use "of brackets nonin conformity with the above mentioned texts "obligatory or safety standards", would thus constitute also a fraud, on the risks inherent in the use of the product.

(c) Of controls carried out:

The case-law knew the case of an importer of toys, author of the first placing on the market, which "claimed wrongfully that their conformity to the obligatory standards had been checked", which was prosecuted and condemned on the base of this infringement (CA Paris, March 18,
1992, cf supra).

For the brackets, the fact of conferring to a batch, which has escaped the control required with appendix IV of the decree of 1995 relating to the medical devices, the number of another having undergone successfully this control, would amount "claiming wrongfully that conformity to the obligatory standards of the first batch was checked", which constitutes there still the offence of fraud on controls carried out.

4. It is useful here to lay stress on all the interest of the judgement of March 18, 2000 of the Court of Appeal of Montpellier, on the involuntary discharge from hospital of the Supreme court of appeal (June 19, 1999), directly aiming the re-use of medical devices at single use.

If the doctors having re-used medical devices (probes of electrophysiology) were released of the count of fraud, it is only because the reproached acts were held at one period during which the circulars (nonlawful) prohibited the resterilisation of medical devices of single use, according to the labelling of the manufacturer. At the time of the infringement, there was not standard, and thus, no failure to this one. Nevertheless, the litigious facts were described as fraud on substantial qualities, like on the ability employment and the risks inherent in the use of these medical devices.

You will note that the mistakes of your competitors could reasonably be appreciated by the courts as being constitutive of the offence of fraud.

- B Intentional element of the infringement:

1. It is in addition, necessary to identify the will of the author of the offence. The L.212-1 article of the code of consumption, resulting from the law of July 21, 1983, lays out with its 2nd
subparagraph that:

" the person in charge for the first placing on the market of a product is held to check that this one is in conformity with the regulations in force."

2. Thus, the courts will condemn the prosecuted person who not checked the conformity of her goods with the rules, written or usual, which govern its manufacture or its importation, this one having taken the risk to mislead her contractors in violation of the article L.212-1. It does not matter it calls upon her good faith (Cass. crim. April 7, 1999, Juris-Data 1999-001673).

For example, was condemned the importer of this material of tools not meeting the applicable standards, which it had not checked (Cass. crim. 10 April 1997, above mentioned), or the person in charge for the setting on sale of toys nonin conformity with the safety requirements (Cass. crim. 7 April 1999, above mentioned).