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  • 1.  RAC Practice Exam (Devices) - Test Question Inquiry

    Posted 24-May-2023 21:01

    Hello, I am having trouble trying to locate the correct source documentation which clearly defines the correct answer for this question. Any feedback or insight as to how you would answer this question and what supporting reference documentation you would utilize. Any insights are appreciated! (I am also going to submit this question to FDA DICE to see what their thoughts are.)

    A company intends to add an indication for use to a 510(k) device that is currently being marketed, but has not yet been distributed. Which type of submission is most appropriate?
    A) A PMA
    B) An Investigational Device Exemption
    C) A Special 510(k)
    D) A traditional or abbreviated 510(k)






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    Orca1
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  • 2.  RE: RAC Practice Exam (Devices) - Test Question Inquiry

    Posted 25-May-2023 01:29

    Hi. I have chosen "(C) A Special 510(k) " because expanded indications may result in the need for additional verification and validation testing. Therefore, this change cannot be reviewed in a summary or risk analysis format in a Special 510(k). (C) is the most appropriate among (A)~(D).

    Please refer to the FDA guidance "The Special 510(k) Program": https://www.fda.gov/media/116418/download



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    Emi
    Tokyo
    Japan
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  • 3.  RE: RAC Practice Exam (Devices) - Test Question Inquiry

    Posted 25-May-2023 01:51

    Hello, again. I made a mistake !! My corrected answer is "(D) A traditional or abbreviated 510(k) " because expanded indications may result in the need for additional verification and validation testing. Therefore, this change cannot be reviewed in a summary or risk analysis format in a Special 510(k). I think (D) is the most appropriate among (A)~(D).

    Please refer to the FDA guidance "The Special 510(k) Program": https://www.fda.gov/media/116418/download

    I am sorry for this confusion.
    Best regards,



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    Emi YAMAGUCHI
    Tokyo
    Japan
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  • 4.  RE: RAC Practice Exam (Devices) - Test Question Inquiry

    Posted 25-May-2023 06:26

    Michaela, the most direct reference would be the FDA Guidance When to Submit a 510(k) for a Change to an Existing Device (issued Oct 2017); see example A1.



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    Jonathan Amaya-Hodges
    Director, Technical Services
    Sharon MA
    United States
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  • 5.  RE: RAC Practice Exam (Devices) - Test Question Inquiry

    Posted 25-May-2023 07:17

    Thanks for your feedback!!!!!!!!!



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    O.
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  • 6.  RE: RAC Practice Exam (Devices) - Test Question Inquiry

    Posted 25-May-2023 07:00

    My choice would be D



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    Silu Zhang
    West Vancouver BC
    Canada
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  • 7.  RE: RAC Practice Exam (Devices) - Test Question Inquiry

    This message was posted by a user wishing to remain anonymous
    Posted 26-May-2023 08:21
    This message was posted by a user wishing to remain anonymous

    A Special 510(k) is not to be used for a change to the indications for use. A traditional 510(k) or an abbreviated 510(k) would be submitted for a change involving the indications for use. D is the answer.