Regulatory Open Forum

 View Only
  • 1.  510(k) submission preparation timeline

    This message was posted by a user wishing to remain anonymous
    Posted 30-Jan-2023 08:15
    This message was posted by a user wishing to remain anonymous

    I am new to the industry and will be preparing my first Traditional 510(k).  Can anyone provide a generic timeline on preparing my submission kindly?  I will have about 3 months to prepare.  What I should do first and the next logical steps?  I will also use eStar.  Thank you in advance.


  • 2.  RE: 510(k) submission preparation timeline

    Posted 30-Jan-2023 13:50
    It generally takes a few weeks' time or less for my firm to prepare a Traditional 510(k).  But that is assuming all of the supporting data (e.g., verification studies, validation studies, labeling, etc.) are generated, vetted, and ready.  If the supporting data are still being developed and generated, then the timeline is contingent on the timelines of those developmental outputs plus the aforesaid few weeks.

    ------------------------------
    Kevin Randall, ASQ CQA, RAC (U.S., Europe, Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2023 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------



  • 3.  RE: 510(k) submission preparation timeline

    Posted 31-Jan-2023 04:56
    Hello Anon,

    In line with what Kevin said, it highly depends on the source material and supporting data in the quality of the information, completeness, and readily available the information.  It can take from a few weeks to a few months to prepare a submission.  If everything is good, complete, and easy to organise in the submission, it can be done in less than a month - just plug-n-play.  If this is your first 510(k) submission assembling, you might want to have an experienced person complete a review of the submission prior to be made with FDA.

    ------------------------------
    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
    ------------------------------



  • 4.  RE: 510(k) submission preparation timeline

    Posted 31-Jan-2023 12:08
    Hi Anon,

    Kevin and Richard always give good advice. I have three additional suggestions for you.

    a. Ask an experienced writer and native speaker of English to review the document before you submit it. You would be surprised at how ambiguous many sentences can become, especially longer, run-on sentences. Keep the writing clear and to the point. Avoid puffery and unsupported claims. Substantial Equivalence and Performance are usually the most important sections to review, but a pre-submission review of the entire document is ideal.

    b. Save a copy of the ESTAR PDF before you sign it. Once the file is signed, it becomes harder to edit. Use the "Save As..." option to create an unsigned copy for your records, then sign a separate submission copy. This helps if you find an error during final pre-submission review and need to re-sign the PDF, or if you need to update the 510(k) later due to FDA questions.

    c. Do not use a 510(k) Statement. Always create a 510(k) Summary.

    Below is a basic timeline. You can compress it or expand it depending on the status of the supporting materials.

    February: Review all sections of the 510(k) and determine which are applicable to your device, review your predicate (and your reference devices, if using) to see if there have been any recalls or other issues with them. I like to create a simple tracking spreadsheet for each section of the 510(k) that shows whether it has been started, completed, reviewed, etc. and what inputs it requires. For example, you can put your DV reports and other bench test reports down as your requirements for the Performance section. Ensure that Biocompatibility, EMC and animal and/or clinical reports are clear and ask authors for re-writes or clarifications if necessary. Animal study reports should follow GLP. Start on your opening sections of the 510(k) and work through them. The introduction should include photos and/or drawings of the device. When you write, remember that your task is to clearly explain the device's construction and intended use to the reviewer and explain why it is Substantially Equivalent (SE) to the predicate. Don't assume the reviewer will see things that you consider to be obvious. (You have become aware of the obvious aspects of your device but the reviewer is seeing your documentation without the benefit of prior knowledge.) The guidance documents The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)] | FDA and Benefit-Risk Factors to Consider When Determining Substantial Equivalence in Premarket Notifications (510(k)) with Different Technological Characteristics | FDA (if applicable to your device) are a helpful start for crafting your SE rationale. Define any acronyms or unfamiliar terms used at first instance in parentheses. If you are eligible for a small business discount, apply for it now and pay the submission fee. If you don't have CDRH portal access, apply for it now.

    March: Begin self-review of completed sections. If you are still waiting for any updates or additional information for test reports, ask your manager to escalate with the test report owner(s). Make corrections based on your review. Pay particular attention to the SE section. Does this section clearly explain why your device is equivalent? Does it address any differences between the predicate and your subject device? Discuss any final edits to your draft labeling if needed.

    April: Ask for a manager or other experienced 510(k) writer to review the draft. Try not to take their criticism personally or emotionally—focus on how their review improves the document. Assemble the final document with attachments. You may find it helpful to print the file and review a paper copy along with the checklist. After final review, submit your ESTAR 510(k) via the CDRH portal.

    Good Luck!


    ------------------------------
    Ian Broome, M.S., RAC
    Needham, MA
    United States
    ***Any posts or activity shared on RAPS Forums are my own personal views; I do not speak on behalf of Boston Scientific Corporation (BSC).***
    ------------------------------


  • 5.  RE: 510(k) submission preparation timeline

    This message was posted by a user wishing to remain anonymous
    Posted 01-Feb-2023 08:41
    This message was posted by a user wishing to remain anonymous



    Hello!
    With regards to Ruichard's and Ian's comments on asking someone to review the draft - what are your thoughts on the use of Third Party Review Program, assuming the device is eligible? Has anyone had any experience and what would be the pros / cons of such engagement. 

    Many thanks for your comments.


  • 6.  RE: 510(k) submission preparation timeline

    Posted 01-Feb-2023 12:20
    I don't have any experience with TPR, but the TPR program has been discussed on this forum in the past. Search "Third Party Review" in the bar at the top right and you'll find several threads with varying opinions and experiences.


    ------------------------------
    Ian Broome, M.S., RAC
    Needham, MA
    United States
    ***Any posts or activity shared on RAPS Forums are my own personal views; I do not speak on behalf of Boston Scientific Corporation (BSC).***
    ------------------------------



  • 7.  RE: 510(k) submission preparation timeline

    Posted 01-Feb-2023 12:24
    Adding to the advice already provided, also consider whether the sponsor is eligible for small business designation, and if so, get this process started early. Here is more information on this Small Business Designation Program

    As Ian mentioned using a spreadsheet to plan and track progress is really helpful to organize the project and keep the team informed. Section by section, include input sources needed to draft the section, who is responsible for providing the input, due dates, status, along with planned appendices and associated responsibility and due dates. I also add links to relevant guidance documents and clarify which sections are not applicable. I would also recommend drafting the submission sections in separate documents to facilitate review.

    It is important to do a careful review of the final complete submission for consistency, etc. but breaking it down into pieces makes it easier to manage in the earlier phases. A review of the final or near-final file by an experienced regulatory person who has not been involved in the creation of the document package can add a lot of value.

    In general, investing time up front to plan thoroughly can save a lot of time and headaches later in the process.

    Good luck!

    ------------------------------
    Marianne Jacklyn
    Principal Consultant
    West Linn OR
    United States
    ------------------------------