This document provides information about drug master files (DMFs), including their definition, regulatory requirements, types, specifications, content, and submission process. A DMF is a confidential document containing details about the manufacturing and controls of an active pharmaceutical ingredient. There are five types of DMFs which provide information about drug substances, packaging materials, excipients, and other reference information. A Type II DMF for a drug substance must be organized according to ICH guidelines and contain manufacturing details, characterization, specifications, and stability data. Amendments and annual reports are used to update the information in a DMF.
Documentation in Pharmaceutical Industry.pptxAartiVats5
This document discusses various types of documentation required in the pharmaceutical industry, including exploratory product development briefs (EPDBs), product development plans (PDPs), and product development reports (PDRs). It also discusses drug master files (DMFs). The EPDB describes the drug substance and product. The PDP provides guidance for product development stages. The PDR provides a comprehensive understanding of the product and manufacturing process. Finally, the DMF contains confidential information used to support regulatory requirements for quality, safety and efficacy.
CLINICAL INVESTIGATION AND EVALUATION OF MEDICAL DEVICES AND.pptxFaizanShaikh204666
the presentation give idea about what is medical devices?
definition's given by cdsco and usfda
what is clinical investigation in evaluation in medical devices?
plasma master file is a EU requirement for the apploval of the biologics or the biosimilars to the EU in a eCTD format or Nees as per the requirement type and should contain the above given details
The document provides guidance for regulatory audits of medical device manufacturers' quality management systems. It discusses the Global Harmonization Task Force (GHTF), which aimed to harmonize medical device regulations internationally. GHTF established 5 study groups, including Study Group 4 which focused on auditing strategies and developed guidance documents. The guidance covers establishing auditing procedures, auditor competencies, and conducting and documenting audits in a harmonized manner. It provides a framework for consistent regulatory audits of medical device quality systems across countries.
The document provides an overview of medical device regulations in ASEAN countries. It discusses the ASEAN Medical Device Directive (AMDD), which provides harmonized regulations across ASEAN nations. It outlines the medical device classification system and regulatory registration procedure, including requirements for quality systems and clinical evaluation/investigation. Key aspects covered are the ASEAN Common Submission Dossier Template for product registration and ISO 13485 standards for quality management systems.
This document provides information about drug master files (DMFs), including their definition, regulatory requirements, types, specifications, content, and submission process. A DMF is a confidential document containing details about the manufacturing and controls of an active pharmaceutical ingredient. There are five types of DMFs which provide information about drug substances, packaging materials, excipients, and other reference information. A Type II DMF for a drug substance must be organized according to ICH guidelines and contain manufacturing details, characterization, specifications, and stability data. Amendments and annual reports are used to update the information in a DMF.
Documentation in Pharmaceutical Industry.pptxAartiVats5
This document discusses various types of documentation required in the pharmaceutical industry, including exploratory product development briefs (EPDBs), product development plans (PDPs), and product development reports (PDRs). It also discusses drug master files (DMFs). The EPDB describes the drug substance and product. The PDP provides guidance for product development stages. The PDR provides a comprehensive understanding of the product and manufacturing process. Finally, the DMF contains confidential information used to support regulatory requirements for quality, safety and efficacy.
CLINICAL INVESTIGATION AND EVALUATION OF MEDICAL DEVICES AND.pptxFaizanShaikh204666
the presentation give idea about what is medical devices?
definition's given by cdsco and usfda
what is clinical investigation in evaluation in medical devices?
plasma master file is a EU requirement for the apploval of the biologics or the biosimilars to the EU in a eCTD format or Nees as per the requirement type and should contain the above given details
The document provides guidance for regulatory audits of medical device manufacturers' quality management systems. It discusses the Global Harmonization Task Force (GHTF), which aimed to harmonize medical device regulations internationally. GHTF established 5 study groups, including Study Group 4 which focused on auditing strategies and developed guidance documents. The guidance covers establishing auditing procedures, auditor competencies, and conducting and documenting audits in a harmonized manner. It provides a framework for consistent regulatory audits of medical device quality systems across countries.
The document provides an overview of medical device regulations in ASEAN countries. It discusses the ASEAN Medical Device Directive (AMDD), which provides harmonized regulations across ASEAN nations. It outlines the medical device classification system and regulatory registration procedure, including requirements for quality systems and clinical evaluation/investigation. Key aspects covered are the ASEAN Common Submission Dossier Template for product registration and ISO 13485 standards for quality management systems.
The document discusses GMP compliance audits. It defines GMP audits as a process to verify that manufacturers follow good manufacturing practices regulations. There are two types of audits - onsite audits, which involve visiting the production site, and desktop audits, which review documentation without a site visit. Audits check various aspects of production including personnel, facilities, equipment, processes, warehousing and more. They help identify issues, ensure proper controls, and improve compliance.
The document provides information on documentation practices in the pharmaceutical industry. It discusses why documentation is important, defining documentation as written evidence of activities. It states that regulatory bodies prioritize reviewing documents to verify activities. Good documentation practices, including systematic preparation and review of documents, are required to prevent errors and ensure compliance. Documentation provides records, traceability, and audit trails for investigation and review.
The document discusses different procedures for obtaining marketing authorization for medicinal products in the European Union. It describes the national authorization procedure which allows approval in a single member state, as well as the centralized procedure which provides an authorization that applies across all EU states. It also outlines the mutual recognition and decentralized procedures, which allow authorization in multiple states via coordination between countries. Key steps, timelines and responsibilities of each process are defined in detail.
This document summarizes registration requirements for medicines in three CIS countries - Uzbekistan, Georgia, and Kyrgyzstan. Uzbekistan requires chemical, pharmaceutical, biological, pharmacological, toxicological and clinical documentation be submitted. Georgia requires administrative documents, labeling information approved in the exporting country, and samples. Kyrgyzstan requires an application, power of attorney, GMP certificate, product description and stability data. All three countries require documentation be submitted in their local languages and require stability testing in Zone I conditions.
This document summarizes a presentation on future compliance requirements related to medical devices. It discusses changes coming in how medical devices are named (GMDN), tracked (UDI), and have data captured (AIDC/GS1 coding). The Global Medical Device Nomenclature (GMDN) will standardize device names. Unique Device Identification (UDI) will assign each device a unique identifier tracked in a public database. Automatic identification like GS1 coding will help interface equipment and data. Hospitals should prepare by understanding these changes to integrate new identification standards.
GLOBAL MEDICAL DEVICES NOMENCLATURE.pptxSanthiNori1
1) The Global Medical Device Nomenclature (GMDN) is an internationally agreed system that provides a single common language of generic terms to uniquely identify medical devices. It aims to be adopted by medical device regulators, manufacturers and healthcare systems worldwide.
2) GMDN terms consist of a name, definition and code. Terms are searched on the GMDN agency website and used for data exchange between organizations. A unique device identifier (UDI) also uses GMDN codes.
3) GMDN was established in 1991 to allow efficient information exchange between stakeholders. It is important for regulatory approval and identification of product failures or inventory management.
This document summarizes a presentation given by Michael Swit on the 510(k) process for medical device clearance. The presentation covers the legal framework for 510(k) submissions, considerations for choosing device claims and introducing new features, evaluating device modifications that require new 510(k) filings, and the 510(k) review process. It provides guidance on strategies for obtaining 510(k) clearance, including starting with a narrow intended use and adding features incrementally, and the types of device changes that typically trigger a new 510(k).
The document discusses the regulation of medical devices in the United States. It begins by defining what constitutes a medical device according to the Code of Federal Regulations. It then outlines the key regulatory bodies that oversee medical devices, including the Center for Devices and Radiological Health and the Office of Combination Products. The document provides an overview of the classification system for medical devices and the different regulatory pathways for approval, including 510(k) premarket notification, investigational device exemptions, premarket approval, and humanitarian device exemption. It also summarizes the key requirements and processes for each approval pathway.
The STED (Summary of Technical Documentation) is a document that manufacturers of IVD medical devices must compile to demonstrate conformity with regulations. It provides:
1) A detailed description of the device's intended purpose and performance.
2) Information on design, manufacturing, safety and performance testing to show compliance with standards.
3) A checklist mapping requirements to how the device meets each essential principle.
The STED is required for premarket review of Class C and D devices and may be requested post-market. It provides regulators a summary of a device's technical file for audit purposes. Higher risk devices require more detailed information in the STED. The level of information helps determine conformity.
The slides explain 21 CFR Part 812. It includes all the guidelines to be followed by any manufacturer and investigator while manufacturing and investigating the safety, efficacy of the medical device.
This presentation is aimed at providing information on automation in the GLP practices in the pharmaceutical industry.
-Standard Operating Procedures.
-Documentation in GALP.
-Logs and Related Forms.
The document summarizes regulatory considerations for pharmaceuticals in Japan, including manufacturing, packaging, labeling, and post-marketing surveillance. For manufacturing, drugs must be approved by the Ministry of Health, Labor and Welfare and manufacturers must be licensed and follow good manufacturing practices. Packaging and labeling must contain specified information and any changes require relabeling. Post-marketing surveillance involves adverse event reporting, drug reexaminations every few years to reconfirm safety and efficacy, and reevaluations based on current medical knowledge.
Fda regulations for pharmaceutical packagingPrem Patil
The document discusses guidelines for packaging and labeling of active pharmaceutical ingredients (APIs). It outlines requirements for packaging materials, labeling, storage conditions, and expiration dating to ensure quality. Proper documentation of material specifications, examination and testing is required. Labels must include accurate information and be stored securely to prevent mix-ups. APIs should be packaged and labeled in a way that protects against deterioration and contamination during transport and storage.
This document summarizes the objectives and classification system of the Global Harmonization Task Force (GHTF) for in vitro diagnostic (IVD) medical devices. The GHTF was founded in 1993 to harmonize medical device regulations globally. It aims to facilitate trade while preserving public health. IVD medical devices are classified into 4 risk-based classes (A to D) based on 16 general rules related to device invasiveness, energy use, and disease detection. Class A devices pose the lowest risk while Class D the highest. The classification system aims to ensure regulatory oversight is proportionate to device risk.
introduction, classification, regulatory approval process for medical devices (510k) premarket notification, pre market approval (PMA), investigational device exemption (IDE) and invitro diagnostics, quality system requirements 21 CFR PART 820, labeling requirements 21 CFR part 801, UDI
Medical device as per india and usa special reference with 510(k)vikash vyas
1. medical device as per usa:
a) classification
b) 510(k)
c) 510(k) submission process
d) pre market approval(PMA)
2. medical device as per india
a) definition
b) organization of medical device reviewer
c) registration process
d) document required for the registration of medical device as per cdsco
The document discusses GMP compliance audits. It defines GMP audits as a process to verify that manufacturers follow good manufacturing practices regulations. There are two types of audits - onsite audits, which involve visiting the production site, and desktop audits, which review documentation without a site visit. Audits check various aspects of production including personnel, facilities, equipment, processes, warehousing and more. They help identify issues, ensure proper controls, and improve compliance.
The document provides information on documentation practices in the pharmaceutical industry. It discusses why documentation is important, defining documentation as written evidence of activities. It states that regulatory bodies prioritize reviewing documents to verify activities. Good documentation practices, including systematic preparation and review of documents, are required to prevent errors and ensure compliance. Documentation provides records, traceability, and audit trails for investigation and review.
The document discusses different procedures for obtaining marketing authorization for medicinal products in the European Union. It describes the national authorization procedure which allows approval in a single member state, as well as the centralized procedure which provides an authorization that applies across all EU states. It also outlines the mutual recognition and decentralized procedures, which allow authorization in multiple states via coordination between countries. Key steps, timelines and responsibilities of each process are defined in detail.
This document summarizes registration requirements for medicines in three CIS countries - Uzbekistan, Georgia, and Kyrgyzstan. Uzbekistan requires chemical, pharmaceutical, biological, pharmacological, toxicological and clinical documentation be submitted. Georgia requires administrative documents, labeling information approved in the exporting country, and samples. Kyrgyzstan requires an application, power of attorney, GMP certificate, product description and stability data. All three countries require documentation be submitted in their local languages and require stability testing in Zone I conditions.
This document summarizes a presentation on future compliance requirements related to medical devices. It discusses changes coming in how medical devices are named (GMDN), tracked (UDI), and have data captured (AIDC/GS1 coding). The Global Medical Device Nomenclature (GMDN) will standardize device names. Unique Device Identification (UDI) will assign each device a unique identifier tracked in a public database. Automatic identification like GS1 coding will help interface equipment and data. Hospitals should prepare by understanding these changes to integrate new identification standards.
GLOBAL MEDICAL DEVICES NOMENCLATURE.pptxSanthiNori1
1) The Global Medical Device Nomenclature (GMDN) is an internationally agreed system that provides a single common language of generic terms to uniquely identify medical devices. It aims to be adopted by medical device regulators, manufacturers and healthcare systems worldwide.
2) GMDN terms consist of a name, definition and code. Terms are searched on the GMDN agency website and used for data exchange between organizations. A unique device identifier (UDI) also uses GMDN codes.
3) GMDN was established in 1991 to allow efficient information exchange between stakeholders. It is important for regulatory approval and identification of product failures or inventory management.
This document summarizes a presentation given by Michael Swit on the 510(k) process for medical device clearance. The presentation covers the legal framework for 510(k) submissions, considerations for choosing device claims and introducing new features, evaluating device modifications that require new 510(k) filings, and the 510(k) review process. It provides guidance on strategies for obtaining 510(k) clearance, including starting with a narrow intended use and adding features incrementally, and the types of device changes that typically trigger a new 510(k).
The document discusses the regulation of medical devices in the United States. It begins by defining what constitutes a medical device according to the Code of Federal Regulations. It then outlines the key regulatory bodies that oversee medical devices, including the Center for Devices and Radiological Health and the Office of Combination Products. The document provides an overview of the classification system for medical devices and the different regulatory pathways for approval, including 510(k) premarket notification, investigational device exemptions, premarket approval, and humanitarian device exemption. It also summarizes the key requirements and processes for each approval pathway.
The STED (Summary of Technical Documentation) is a document that manufacturers of IVD medical devices must compile to demonstrate conformity with regulations. It provides:
1) A detailed description of the device's intended purpose and performance.
2) Information on design, manufacturing, safety and performance testing to show compliance with standards.
3) A checklist mapping requirements to how the device meets each essential principle.
The STED is required for premarket review of Class C and D devices and may be requested post-market. It provides regulators a summary of a device's technical file for audit purposes. Higher risk devices require more detailed information in the STED. The level of information helps determine conformity.
The slides explain 21 CFR Part 812. It includes all the guidelines to be followed by any manufacturer and investigator while manufacturing and investigating the safety, efficacy of the medical device.
This presentation is aimed at providing information on automation in the GLP practices in the pharmaceutical industry.
-Standard Operating Procedures.
-Documentation in GALP.
-Logs and Related Forms.
The document summarizes regulatory considerations for pharmaceuticals in Japan, including manufacturing, packaging, labeling, and post-marketing surveillance. For manufacturing, drugs must be approved by the Ministry of Health, Labor and Welfare and manufacturers must be licensed and follow good manufacturing practices. Packaging and labeling must contain specified information and any changes require relabeling. Post-marketing surveillance involves adverse event reporting, drug reexaminations every few years to reconfirm safety and efficacy, and reevaluations based on current medical knowledge.
Fda regulations for pharmaceutical packagingPrem Patil
The document discusses guidelines for packaging and labeling of active pharmaceutical ingredients (APIs). It outlines requirements for packaging materials, labeling, storage conditions, and expiration dating to ensure quality. Proper documentation of material specifications, examination and testing is required. Labels must include accurate information and be stored securely to prevent mix-ups. APIs should be packaged and labeled in a way that protects against deterioration and contamination during transport and storage.
This document summarizes the objectives and classification system of the Global Harmonization Task Force (GHTF) for in vitro diagnostic (IVD) medical devices. The GHTF was founded in 1993 to harmonize medical device regulations globally. It aims to facilitate trade while preserving public health. IVD medical devices are classified into 4 risk-based classes (A to D) based on 16 general rules related to device invasiveness, energy use, and disease detection. Class A devices pose the lowest risk while Class D the highest. The classification system aims to ensure regulatory oversight is proportionate to device risk.
introduction, classification, regulatory approval process for medical devices (510k) premarket notification, pre market approval (PMA), investigational device exemption (IDE) and invitro diagnostics, quality system requirements 21 CFR PART 820, labeling requirements 21 CFR part 801, UDI
Medical device as per india and usa special reference with 510(k)vikash vyas
1. medical device as per usa:
a) classification
b) 510(k)
c) 510(k) submission process
d) pre market approval(PMA)
2. medical device as per india
a) definition
b) organization of medical device reviewer
c) registration process
d) document required for the registration of medical device as per cdsco
Poster Presentation - FDA Compliance Landscape & What it Means to Your AI Asp...CitiusTech
CitiusTech delivered a poster presentation on the FDA compliance landscape (PMA, De Novo, 510k and Pre Cert) and its implication on AI in Healthcare, at the Mayo Clinic AI Symposium earlier this year.
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service
Center for Devices and Radiological Heath
Office of Communication, Education and Radiation Programs
Document Mail Center – WO66-G609
10903 New Hampshire Avenue
Silver Spring, MD 20993-0002
Watson Megatech, Inc.
% Chad Watson
Dec 1, 2011
President and CEO
5800 Industrial Blvd
Suite 11
Omaha, NE 68135
Re: P091462
BioBanking
Filed: Jan 9, 2010
Amended: August 5, September 8 and 13, 2010; February 22, 2011; September 22, 2011; October 6, 2011 and November 1, 2011.
Procode: RLD
Dear Mr. Watson:
The Center for Devices and Radiological Health (CDRH) of the Food and Drug Administration
(FDA) has completed its review of your premarket approval application (PMA) for the BioBanking Device.
BioBanking is intended to be for sub-dermal use as a radio frequency (RF) emitter in the prevention of identity theft and financial fraud. The device will interact with external scanners through radio frequency to identify the individual as well as financial account information. The device will also interact with external encoders for the purposes of addition or removal of financial account information. The device is solar powered and does not need internal batteries that would provide potential medical issues in the PMA review process.
The BioBanking insertion process can be administered by non-medical personnel trained in the implementation of the product. Financial institution personnel responsible for this administration will be trained and certified in application of the BioBanking device.
The sub-dermal BioBanking device is one element of the total transaction system. There is also a reader for the RF signals. Since the reader is a passive device it does not fall under provisions of the CDRH purview.
We are pleased to inform you that the PMA is approved. You may begin commercial distribution
of the device in accordance with the conditions of approval described below. You may continue
commercial distribution of the device upon receipt of this letter.
Page 2 – Mr. Watson
The sale and distribution of this device are governed by The Radiation Control provisions (originally enacted as the Radiation Control for Health and Safety Act of 1968) located in Sections 531 through 542 of the Act. They apply to any "electronic product" which is defined as: any manufactured or assembled product (or component, part, or accessory of such product) which, when in operation,
i. contains or acts as part of an electronic circuit and
ii. emits (or in the absence of effective shielding or other controls would emit) electronic product radiation.
"Electronic product radiation" is defined as:
i. any ionizing or non-ionizing electromagnetic or particulate radiation, or
ii. any sonic, infrasonic, or ultrasonic wave, which is emitted from an electronic product as the result of the operation of an electronic circuit in such product.
The device is restricted under section 515(d)(l)(B)(ii) o.
Premarket Notification The 510(k) ProcessMichael Swit
June 5, 2012 presentation to the Food & Drug Law Institute Introduction to Medical Device Law Conference, Palo Alto, CA, focusing on:
I.The Legal Framework For 510(k) Determinations
II.510(k) Preparation – From Planning to Content
A. Predicates: researching predicates, combination predicates, and pre-amendment predicates
B. Strategy: choosing the right claim and introducing new features
C. Assessing data requirements/pre-IDE meetings
III. Device Modifications - Choosing The Right Regulatory Mechanism
IV.The FDA Review
V.What To Do When Your Substantial Equivalence Argument Is Rejected
V. Special Topics: User Fees, Combination Products
VI. Lessons Learned: Seeing The 510(k) From The Reviewer’s Perspective
VII. Recent Trends, 510(k) Reform
VIII. Case Study
Drug Delivery -- Perspectives on the FDA Regulatory EnvironmentMichael Swit
Presentation to the Arrowhead Drug Delivery Summit, May 2009, in San Francisco, focusing on:
The FDA World –how is it changing?
Combination Product Regulation –where drug delivery intersects with agency purview
How FDA approaches combination products
Real time examples
Getting prepared --How to focus on FDA regulatory issues in drug delivery
Do you have a medical device that treats or diagnoses a life-threatening disease? If yes, your device may be eligible for an expedited review pathway called the Breakthrough Devices Program. The FDA defines a breakthrough device as any device (or device-led combination product) that will “provide for more effective treatment or diagnosis of life-threatening or irreversibility debilitating diseases or conditions”...
medical device regulatory approval in USASuraj Pamadi
The document discusses the approval process for medical devices in the United States, including an overview of the classification system for medical devices (Class I, II, III), the requirements for each class (e.g. 510(k) notification or premarket approval), and the components required for a 510(k) premarket notification application to the FDA.
Update on software as a medical device (SaMD)TGA Australia
This presentation explores the definition of a medical device and how this applies to software. In addition, the nuances of the kinds of software are discussed in relation to their likely classification as a medical device.
AdvaMed 510(k) Submissions Workshop: How to Assemble A Bullet Proof 510(k) Su...Jon Lendrum
The document provides an overview of a workshop on assembling 510(k) submissions for the FDA. It discusses selecting a predicate device, organizing data, and preparing the actual 510(k) submission. Key points include understanding FDA Form 3654 (Standards Data Report), tips and best practices for 510(k) submissions, potential pitfalls, and common mistakes. The workshop objectives are to help attendees understand how to select a predicate device, collect and organize required data, and understand the overall 510(k) process.
DESIGN OF IMPLANTABLE DEVICE – UNDERSTANDING THE PREMARKET REVIEW PROCESS AN...UBMCanon
1) The document provides an overview of the FDA premarket review process for medical devices, with an emphasis on biocompatibility evaluation and regulations regarding device materials.
2) Key aspects of the premarket review process are outlined, including device classification and types of premarket submissions. Biocompatibility testing requirements are discussed, with tests selected based on the intended use and patient exposure to the device.
3) Recognized standards for materials and biocompatibility testing are reviewed, with the importance of evaluating the final device rather than raw materials emphasized. Useful online FDA resources are also presented.
The document provides guidance for implantable radiofrequency transponder systems used for patient identification and health information. It outlines risks like adverse tissue reactions, information security issues, device failures, and electromagnetic interference. It recommends measures to address these risks, including biocompatibility testing, information security validation, software validation, performance testing, and electromagnetic compatibility testing. The guidance also covers sterility, MRI compatibility, and labeling. Compliance with the recommendations provides reasonable assurance of safety and effectiveness, allowing exemption from premarket notification requirements.
The document defines medical devices and their classification according to various regulatory bodies. It begins by defining a medical device as any instrument intended for internal or external use in the diagnosis, treatment, or prevention of disease. It then discusses the classification of devices by the US FDA, CDSCO, and the European Union as Class I, II, or III based on increasing risk levels. The document provides examples of devices that fall into each class and outlines the regulatory processes, including premarket approval or clearance, that manufacturers must go through for devices in each class to be legally marketed.
Device registration and listing of medical devices on the US marketttopstart B.V.
We provide an overview of the regulations and legislations with regard to commercialisation of medical devices in the US. The product category of medical devices ranges from class I devices up to class III devices. In the US, market approval is granted by the FDA (Food and Drug Administration) upon assessment of quality, safety and effectiveness.
The information provided here informs start-ups, spin-offs and biotech companies about the differences in regulatory procedures for specific classes of medical devices. By summarising the procedures for each class of medical device, we, ttopstart, aim to offer a guide through this dense regulative and legislative landscape. These insights can be used to design the optimal market introduction strategy for your medical device.
This document provides guidance for industry and FDA staff on the content of premarket submissions for software contained in medical devices. It recommends that manufacturers determine the "Level of Concern" for their software device based on the potential severity of injury from device failures or flaws. The Level of Concern helps determine the extent of software-related documentation that should be included in premarket submissions. The guidance outlines recommended documentation for software devices with Major, Moderate, or Minor Levels of Concern, with more documentation recommended for higher Levels of Concern.
FDA Regulations and Medical Device Pathways to MarketMethodSense, Inc.
Bringing your medical device to market requires in-depth attention to its safety, reliability and compliance. In addition to designing a quality medical device, it’s critical that you anticipate and address the requirements that allow you to introduce it to the market successfully.
Life Science consulting firm, MethodSense, discusses important FDA regulations as they relate to bringing a medical device to market, including 21 CFR Part 821, 510(k) approval and 21 CFR Part 11.
FDA Regulations and Medical Device Pathways to MarketMethodSense, Inc.
Bringing your medical device to market requires in-depth attention to its safety, reliability and compliance. In addition to designing a quality medical device, it’s critical that you anticipate and address the requirements that allow you to introduce it to the market successfully.
Life Science consulting firm, MethodSense, discusses important FDA regulations as they relate to bringing a medical device to market, including 21 CFR Part 821, 510(k) approval and 21 CFR Part 11.
The 21st Century Cures Act a focus on Title III Subtitle F – Medical Device I...David Loeser
The 21st Century Cures Act aims to improve and expedite medical device development and regulation. Specifically, Title III Subtitle F focuses on medical device innovations through 10 sections that rewrite rules around devices. This document analyzes 5 key sections: breakthrough devices designation and expedited review (§3051), recognition of standards training for FDA reviewers (§3053), reclassifying some devices (§3054), requiring validated cleaning instructions (§3059), and clarifying software regulation (§3060). The analysis argues these sections will reduce device approval times, improve FDA efficiency, and help safe, effective devices reach patients faster.
Similar to Medical device accessories – describing accessories and classification (20)
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These lecture slides, by Dr Sidra Arshad, offer a simplified look into the mechanisms involved in the regulation of respiration:
Learning objectives:
1. Describe the organisation of respiratory center
2. Describe the nervous control of inspiration and respiratory rhythm
3. Describe the functions of the dorsal and respiratory groups of neurons
4. Describe the influences of the Pneumotaxic and Apneustic centers
5. Explain the role of Hering-Breur inflation reflex in regulation of inspiration
6. Explain the role of central chemoreceptors in regulation of respiration
7. Explain the role of peripheral chemoreceptors in regulation of respiration
8. Explain the regulation of respiration during exercise
9. Integrate the respiratory regulatory mechanisms
10. Describe the Cheyne-Stokes breathing
Study Resources:
1. Chapter 42, Guyton and Hall Textbook of Medical Physiology, 14th edition
2. Chapter 36, Ganong’s Review of Medical Physiology, 26th edition
3. Chapter 13, Human Physiology by Lauralee Sherwood, 9th edition
8 Surprising Reasons To Meditate 40 Minutes A Day That Can Change Your Life.pptxHolistified Wellness
We’re talking about Vedic Meditation, a form of meditation that has been around for at least 5,000 years. Back then, the people who lived in the Indus Valley, now known as India and Pakistan, practised meditation as a fundamental part of daily life. This knowledge that has given us yoga and Ayurveda, was known as Veda, hence the name Vedic. And though there are some written records, the practice has been passed down verbally from generation to generation.
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Mercurius is named after the roman god mercurius, the god of trade and science. The planet mercurius is named after the same god. Mercurius is sometimes called hydrargyrum, means ‘watery silver’. Its shine and colour are very similar to silver, but mercury is a fluid at room temperatures. The name quick silver is a translation of hydrargyrum, where the word quick describes its tendency to scatter away in all directions.
The droplets have a tendency to conglomerate to one big mass, but on being shaken they fall apart into countless little droplets again. It is used to ignite explosives, like mercury fulminate, the explosive character is one of its general themes.
5-hydroxytryptamine or 5-HT or Serotonin is a neurotransmitter that serves a range of roles in the human body. It is sometimes referred to as the happy chemical since it promotes overall well-being and happiness.
It is mostly found in the brain, intestines, and blood platelets.
5-HT is utilised to transport messages between nerve cells, is known to be involved in smooth muscle contraction, and adds to overall well-being and pleasure, among other benefits. 5-HT regulates the body's sleep-wake cycles and internal clock by acting as a precursor to melatonin.
It is hypothesised to regulate hunger, emotions, motor, cognitive, and autonomic processes.
Histololgy of Female Reproductive System.pptxAyeshaZaid1
Dive into an in-depth exploration of the histological structure of female reproductive system with this comprehensive lecture. Presented by Dr. Ayesha Irfan, Assistant Professor of Anatomy, this presentation covers the Gross anatomy and functional histology of the female reproductive organs. Ideal for students, educators, and anyone interested in medical science, this lecture provides clear explanations, detailed diagrams, and valuable insights into female reproductive system. Enhance your knowledge and understanding of this essential aspect of human biology.
2. Introduction
• Document issued on December 20, 2017 by US FDA
Center for Devices and Radiological Health.
• This guidance represents the current thinking of the
FDA ( the Agency) on this topic.
– It does not establish any rights for any person and is not
binding on FDA or the public.
– Companies can use an alternative approach if it satisfies
the requirements of the applicable statutes and
regulations.
– To discuss an alternative approach, contact the FDA staff or
Office responsible for this guidance
3. Background
• FDA has jurisdiction over accessories because the definition of the
term “device” provided in Section 201(h) of the FD&C Act defines
“device” to include, among other products, an “accessory”:
– (1) recognized in the official National Formulary (NF), or the United States
Pharmacopeia (USP), or any supplement to them;
– (2) intended for use in the diagnosis of disease or other conditions, or in
the cure, mitigation, treatment, or prevention of disease, in man or other
animals, or
– (3) intended to affect the structure or any function of the body of man or
other animals, and which does not achieve its primary intended purposes
through chemical action within or on the body of man or other animals,
and
– (4) which is not dependent upon being metabolized for the achievement
of its primary intended purposes.
4. Traditional Classification of Device
Accessories
• FDA has traditionally used one of two approaches to
classifying medical device accessories. Under the first
approach, FDA classifies accessories through:
– (1) 510(k) Premarket Notification clearance.
– (2) Premarket Application (PMA) approval.
– (3) By express inclusion in the classification regulation or
reclassification order for the parent device.
5. Traditional Classification of Device
Accessories
• Under the second approach, FDA classifies accessories
by issuance of a unique, separate classification
regulation for the accessory.
– FDA has determined that a classification regulation for an
accessory should be separate from that of the parent device.
– This has traditionally been considered for accessory types that
may be used with multiple parent devices or that have unique
stand alone functions.
– FDA may issue a separate classification regulation for a
specific category of accessories that has been identified as
having a different risk profile from that of the parent device
and thus requires a different level of regulatory controls.
7. So what has changed?
On August 18, 2017, section 513(f) of the FD&C Act was
amended by the FDA Reauthorization Act of 2017 (Public
Law 115-52) to state that
• “the Secretary shall … classify an accessory under
[section 513] based on the risks of the accessory when
used as intended and the level of regulatory controls
necessary to provide a reasonable assurance of safety
and effectiveness of the accessory, notwithstanding the
classification of any other device with which such
accessory is intended to be used.”
8. In other words . . .
• Classifying an accessory in the same class as its parent
device is appropriate when the accessory, when used
as intended with the parent device.
• However, some accessories can have a lower risk
profile than their parent device and, therefore, may
warrant being regulated in a lower class.
– For example, an accessory to a class III parent device may
pose lower risk that could be mitigated through general
controls or general and special controls and thus could be
regulated as class I or class II.
9. Scope of the Guidance
• Applicable to articles that meet the definition of a device
under §201(h) of the FD&C Act.
• Accessory Classification processes under §513(f)(6) of the
FD&C Act, which provides mechanisms for requesting the
appropriate classification (or reclassification) of –
– an accessory that is included in an application for PMA under
§515, or
– an accessory that has been granted marketing authorization
as part of a submission for another device with which the
accessory is intended to be used, through an application for
such other device under §515(c), a report under §510(k), or a
request for classification under §513(f)(2).
10. In other words, you need to understand the intended
use(s) of the accessory AND the potential regulatory
approval paths for the device!
11. Important!
• FDA intends for the risk-based & regulatory control-based
classification paradigm discussed in this guidance to apply to
all software products that meet the definition of an accessory,
including those that may also meet the definition of
“Software as a Medical Device (SaMD).”
• SaMD that meets the definition of a device under the FD&C
Act is regulated by FDA. However, SaMD that meets this
definition and uses data from a medical device does not
automatically become an accessory.
– For example, a stand-alone software program that is intended to
analyze radiological images or analyzes specific data parameters
generated by a device is considered a SaMD but would not be
considered to support, supplement, and/or augment the performance
of the device that generated the data, and therefore, would not be an
accessory.
12.
13. Definitions
• Accessory: A finished device that is intended to support,
supplement, and/or augment the performance of one or
more parent devices.
• Component (21 CFR 820.3(c)): “Any raw material, substance,
piece, part, software, firmware, labeling, or assembly which
is intended to be included as part of the finished, packaged,
and labeled device.”
• Finished Device (21 CFR 820.3(l)): “Any device or accessory
to any device that is suitable for use or capable of
functioning, whether or not it is packaged, labeled, or
sterilized.”
• Parent Device: A finished device whose performance is
supported, supplemented, and/or augmented by one or
more accessories.
14. How does FDA classify Accessories?
• In order to classify an accessory, FDA addresses the
following two questions:
– 1. Is the article an accessory?
– 2. What is the risk of the accessory when used as
intended with the parent device(s) and what regulatory
controls are necessary to provide a reasonable assurance
of its safety and effectiveness?
• The answers to these two questions inform the risk-
and regulatory control-based classification of a
potential accessory pursuant to the criteria at section
513(a)(1) of the FD&C Act.
15. Is the article an accessory?
1. Is intended for use with one or more parent devices.
– FDA expects that whether an article is intended for use with a
parent device will generally be determined by the labeling and
promotional materials for the accessory device (rather than by
the labeling and promotional materials for the parent device).
– If labeling, promotional materials, or other evidence of intended
use demonstrates that an article is intended for use with a
parent device (either a particular brand or a device type), and it
supports, supplements, and/or augments that device, FDA
generally considers the article to be an accessory and, thus, a
“device” as defined in section 201(h) of the FD&C Act.
– This includes those articles labeled as being “optional”.
16. Is the article an accessory?
2. Is intended to support, supplement, and/or augment the
performance of one or more parent devices.
– Example: a tunneling tool for a neuro-stimulation device that is intended
to create a conduit for the leads between the target location to the
neuro-stimulator supports the neuro-stimulator by facilitating it to
provide stimulation to the target neural tissue. In this case, the accessory
is necessary to support the parent device to meet its intended use.
– Example: a pulse oximeter allows a multi-parameter monitor to display
oxygen saturation but does not change its intended use, which is to
record and display multiple physiological parameters, i.e. it supplements
the device.
– Augments includes improving the performance of a parent device by
enabling it to perform more quickly or improving usability or convenience
for the device user. For example, a guidewire augments the performance
of a bone-cutting instrument by increasing precision of the parent device
and reducing the risk to the patient.
17. “In practice, the distinctions among devices that support, supplement, or
augment parent devices are subtle and many devices that meet the definition
of an accessory may do more than one of these things. Thus, if the device is
intended to support, supplement, and/or augment the performance of one or
more parent devices, [FDA] intend to consider the device to be an accessory
whether it is required or optional.”
18. What are the Risks?
What are the risks of the accessory when used as intended
with the parent device(s) and what regulatory controls are
necessary to provide a reasonable assurance of its safety
and effectiveness? FDA:
– Intends to determine the risk of accessories (and necessary
controls for safety and effectiveness) according to their intended
use, in the same manner that is used to determine such for
devices that are not accessories.
– intends to determine the risks of accessories when used, as
intended, with the parent device.
– Determining the risks of accessories according to their use with
parent devices does not mean that all risks of a parent device
are imputed to the accessory; the risk profile of an accessory can
differ significantly from that of the parent device, warranting
differences in regulatory classification.
19. Accessory Classification Process
• The appropriate classification or reclassification of a legally-
marketed accessory or a new accessory type can be requested
under section 513(f)(6) of the FD&C Act through the
Accessory Request types described below. The FDA intends to
track Accessory Requests as Q-Submissions.
• Accessory Requests should be submitted to:
U.S. Food and Drug Administration
Center for Devices and Radiological Health Document Control Center –
WO66-G609
10903 New Hampshire Avenue
Silver Spring, Maryland 20993-0002
20. New Accessory Type
• In accordance with section 513(f)(6)(C) of the FD&C Act, you
may submit an Accessory Request for appropriate
classification of an accessory that is included in a PMA, PMA
supplement, or 510(k), if the accessory has not been classified
distinctly from another device.
• This New Accessory Request is appropriate for an accessory of
a type that has not been previously classified under the FD&C
Act, cleared for marketing under a 510(k) submission, or
approved in a PMA.
• This request should be submitted together with the parent
device submission and include a cover letter that clearly
identifies that the submission includes a “New Accessory
Request.”
21. New Accessory Type
• The proposed classification of the accessory (i.e., class I or
class II) should also be clearly identified in the cover letter
and/or the request.
• In addition, the request should provide the necessary
information, based on Least Burdensome principles, to
establish the risk profile of the accessory when used as
intended with the parent device.
• Since a Pre-Submission is appropriate when FDA’s feedback on
specific questions is necessary to guide product development
and/or application preparation, it is recommended that
companies submit a Pre-Submission to request feedback on a
proposed Accessory Request.
22. New Accessory Type
• https://www.fda.gov/downloads/MedicalDevices/DeviceRegul
ationandGuidance/GuidanceDocuments/UCM311176.pdf
23. Existing Accessory Type
• In accordance with section 513(f)(6)(D) of the FD&C Act, a
company may submit an Accessory Request for classification of
an accessory that has been granted marketing authorization as
part of a submission for another device that the accessory
involved is intended to be used, through a premarket submission
or a De Novo request.
• The Accessory Request should include:
– A cover letter identifying the submission as an “Existing Accessory
Request.”
– The proposed classification of the accessory (i.e., class I or class II), as well
as the current classification, should also be clearly identified.
– The necessary information, based on Least Burdensome principles, to
establish the risk profile of the accessory when used as intended with the
identified parent device.
– Must include an initial draft proposal for special controls, if special controls
would be required.
24. Classification of New Accessory Types
through the De Novo Process
• In addition to the Accessory Requests under Section 513(f)(6), a
company can utilize the De Novo classification process in Section
513(f)(2) of the FD&C Act to request risk-based and regulatory
control-based classifications of new accessory types.
• In order to be considered a new accessory type, the accessory
under consideration should not be classified by an existing
classification regulation and should not be the subject of any
approved PMAs or cleared 510(k)s for that accessory type.
– This De Novo classification process provides a pathway to class I or class II
classification for accessories with low to moderate risk for which general
controls or general and special controls provide a reasonable assurance of
safety and effectiveness, but for which there are no legally marketed
predicate devices.
25. Summary
• Classification of the accessory is no longer inherited from
the parent device.
• Classification of an accessory is based on the risks
associated with use of the accessory.
– An accessory can potentially be lower risk than the parent
device.
• Includes SaMD, however SaMD is not automatically
considered an accessory.
• FDA determines whether an item is an accessory based
on:
– Labeling and promotional materials, and
– Whether it supports, supplements, and/or augments the parent
device.