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  • 1.  510 (k) new article number

    Posted 23-Sep-2022 08:52
    Dear Community,

    i have maybe a stupid question - but iam not sure.
    What is your experience/knowledge about the follwing:

    If you create a variant of an existing device, wich can be evaluated similar per FDA procedure ("Desciding When to submit a 510 (k) for a change to an existing device") but has another article number and is existing in paralell with the other article.

    What is your opinion? I s a "device" nessecarily = article number?

    thanks for your support
    Lutz

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    Lutz Babilon
    Director QM/RA Black Forest Medical Group
    Freiburg im Breisgau
    Germany
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  • 2.  RE: 510 (k) new article number

    Posted 23-Sep-2022 16:59
    Lutz:

    Perhaps you can expand on what you mean with 'article' number - is article number meant to convey part number or SKU? Perhaps you are referring to what some might call a line extension?  

    With some additional clarity, you might receive some valuable feedback.

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    Scott Bishop
    McKinney TX
    United States
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  • 3.  RE: 510 (k) new article number

    Posted 24-Sep-2022 04:30
    Hi,

    Yea agree, needs a bit more clarity on the question because not understanding what you mean by a new article number - maybe a model number?

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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: 510 (k) new article number

    Posted 24-Sep-2022 14:34
    Dear Scott and Richard,

    thanks for your reply. In fact i am talking about different model numbers (e.g. a new instrument (forceps), similar, but a bit longer)
    Tests may be needed, but no new risks are expected.

    iam curious about your opinion.
    br
    Lutz

    ------------------------------
    Lutz Babilon
    Director QM/RA Black Forest Medical Group
    Freiburg im Breisgau
    Germany
    ------------------------------



  • 5.  RE: 510 (k) new article number

    Posted 25-Sep-2022 12:44
    Dear Lutz

    It sounds like the thing has clearance as a device, but now you are thinking of making a family group of devices.

    So one question would be why do they need this new device. Is it for a different patient population? Is it for a different procedure, or a different illness? That could lead you through the part of the flowchart about changed indications for use.

    You'll probably need to check the part of the flowchart about changes in the labeling.

    It may be true there are no new risks. You might review Appendix A examples 14-17 that talk about potential impact or non-impact of dimension changes, in case any considerations like those might be applicable.

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    Anne LeBlanc
    United States
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  • 6.  RE: 510 (k) new article number

    Posted 26-Sep-2022 02:12
    Hello Lutz,

    You might want to get some other expert advice specific to your situation because there are many different ways medical devices can be identified or provide traceability through article numbers, model numbers, part numbers, SKUs, etc.  You can have different part numbers or model numbers existing within a Product Family which are all covered under the same 510(k).  If you introduce a new part number or article number for a device outside the current range cleared under the 510(k), then need to review how this may impact the safety and/or efficacy (performance) of the device.  When making line extensions, these are often accepted to complete a change order and no new 510(K) is required, but just keep in mind the aspect of safety and efficacy.  If the line extension, new article number, is significantly different, then this may require something else like a new 510(k) submission.

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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 7.  RE: 510 (k) new article number

    This message was posted by a user wishing to remain anonymous
    Posted 26-Sep-2022 08:58
    This message was posted by a user wishing to remain anonymous

    Dear Anne, 
    Can you please point to which link or document you are referring to, 'Appendix A, examples 14-17'. Also, where is the flowchart for labeling? 
    Thanks.


  • 8.  RE: 510 (k) new article number

    Posted 27-Sep-2022 02:54
    Thank you Anne for clarification,

    this helps, in fact, it is going to be a nicer product, some kind of a line extension. I dont come to the decision of a new 510(k), however, i did thought alone the fact having an additional product with a new model number on the shelf would mean a new 510(k). but this seems not so.

    Have a great week!


    @ anonymus, here is the link: https://www.fda.gov/media/99812/download




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    Lutz Babilon
    Director QM/RA Black Forest Medical Group
    Freiburg im Breisgau
    Germany
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