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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
Original Message:
Sent: 17-Apr-2023 12:44
From: Sravan Kumar Manchikanti, RAC
Subject: Health Canada - A non-significant/Administrative Class III Amendment Submission
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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