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  • 1.  Health Canada - A non-significant/Administrative Class III Amendment Submission

    Posted 17-Apr-2023 12:44

    Hi,

    Does any one have experience with submitting a non-significant/Administrative Class III Amendment Submission with Health Canada? I believe it is a kind of alternative (not exactly) to submitting multiple fax-back forms (to implement name/address change, non-significant changes etc.). 

    While I got to know it recently, I could not find any reference to Administrative Amendment in Health Canada website. Through this instrument change in device name (section 10 of the application form) and addition of new identifiers (section 11A of the application form) can also be completed. Multiple Fax-Back applications are not required. As I understand, we just need to submit Class III/IV Medical Device License Amendment Application Form & indicating zero dollars for an administrative amendment in Fee form. There is no need of submitting a Technical file for this kind of submission.

    I request anyone experienced with this pathway to validate my understanding and suggest what kind of ToC (Table of contents) need to be submitted to Health Canada.

    Thanks in advance.

    Sravan 



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    Sravan Kumar Manchikanti, RAC
    Hyderabad
    India
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  • 2.  RE: Health Canada - A non-significant/Administrative Class III Amendment Submission

    This message was posted by a user wishing to remain anonymous
    Posted 26-Apr-2023 08:09
    This message was posted by a user wishing to remain anonymous

    Hi Sravan,

    I have submitted this type of non-significant amendment for changes that fall outside of those described in existing fax-back forms and Health Canada's 'Guidance for the Interpretation of Significant Change of a Medical Device'. 

    I have typically used the folder structure that generally corresponds to the type of change. For example, if the change is most similar to a fax-back, I would use the fax-back folder structure and sections.    

    As you mentioned, this type of amendment is not mentioned in Health Canada guidance and there are no specified timelines.  In my experience, the timelines would be similar to a Class II application. If it is possible to utilize existing forms (e.g. multiple fax-back forms) where the reviews are associated with specified timelines, perhaps this might be preferable depending on your situation.

    I hope this is helpful!

    RAPS colleague







  • 3.  RE: Health Canada - A non-significant/Administrative Class III Amendment Submission

    Posted 26-Apr-2023 09:19

    Hello Sravan
    There is no guidance on Administrative Amendment. Usually, this is submitted for multiple changes or changes that cannot be submitted through a fax-back. Faxback is pretty limited. Follow the folder structure (ToC structure for Class II, III, IV). It's the same format for regular amendments. Write a clear cover letter clarifying what it is you are seeking.  Hope it helps.




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    Karen Zhou
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  • 4.  RE: Health Canada - A non-significant/Administrative Class III Amendment Submission

    Posted 27-Apr-2023 10:09

    Thank you Karen & Anonymous RAPS colleague for sharing your experience and guidance! 



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    Sravan Kumar Manchikanti, RAC
    Hyderabad
    India
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