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  • 1.  FDA Database Search - De Novo

    Posted 11-Feb-2020 09:39

    Hi All. 

    I am looking at a De Novo application and I would like to (as recommended by the FDA) perform a database search to "establish that no legally marketed device and classification regulation for the same device exists" for inclusion in a pre-sub request. 

    Looking at the FDA database, this only brings up a maximum of 500 hits. I am able to download files from previous years but this data is given per month and will be very time consuming to go through.  Is there an easier way of doing this, am I missing something?

    How have others performed this search as part of a De Novo?

    Thanks

    James



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    James
    Head of QARA
    UK
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  • 2.  RE: FDA Database Search - De Novo

    Posted 11-Feb-2020 22:15
    Usually that search is completed prior to the decision to file a De novo.  You looked for a predicate, you couldn't find one, and so your device cannot be cleared via 510(k).  Then your only options are De novo or PMA.  I'm not clear on how one would arrive at the decision to do a De novo otherwise.


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    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 3.  RE: FDA Database Search - De Novo

    Posted 12-Feb-2020 02:34
    Hi Julie. 

    We have already done a small search and I am 100% sure there is not a predicate. I was looking for something more searchable to meet this point from the FDA guidance...."Provide list of regulations and / or product codes that may be relevant and a rational for why the device doesn't fit within or is different from any identified classification regulations or product codes"

    James


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    James
    Head of QARA
    UK
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  • 4.  RE: FDA Database Search - De Novo

    Posted 12-Feb-2020 09:18
    The guidance doesn't say anything about a need to search anything.  I would focus on the rationale, not the list, and cite any specific devices and product codes you looked at to arrive at your conclusion that the device has no predicate.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 5.  RE: FDA Database Search - De Novo

    Posted 12-Feb-2020 10:09
    Hi James,
    This is always a fun exercise :) 
    One path you could take is to start with the product code database: https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfPCD/classification.cfm
    Enter the regulation number or review panel you think your product would fall under (you likely already know this given that presubmissions are typically funneled to a reviewer who operates in that panel assuming this is a general presub). From there identify the product code(s) you believe might apply by selecting them and reviewing the regulation number link that defines them. You're looking to identify intended uses and technology that would be close to what you are planning for your own product (check out the TPLC product code report to see applicable manufacturers and their products cleared with that code or query the 510k/De novo/PMA clearance databases to see their specific indications and technology). For your own records, you should document these codes you are considering (A regulatory strategy/plan apart of your design history file is a great place to discuss this). When it comes time for the actual de novo application you can state what you looked at and how you confirmed the currently approved products under that code don't align. If you have the time now in your product development, I would suggest submitting another presub to review your findings and have their alignment that there are no predicates OR filing a 513(g) for $$. You may find that FDA would push for the 513(g) and not presub, but you could get lucky. Once you have this settled prior to the actual application, then all you need to state is a reference to that presub or 513(g) where this was established. 
    Best,
    Danni

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    Danielle Briggeman MS
    Clinical & Regulatory Affairs Manager
    Portland ME
    United States
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  • 6.  RE: FDA Database Search - De Novo

    Posted 12-Feb-2020 10:37
    Danielle, I agree this is how many people determine whether or not their device has a predicate.  But James has already determined that his device is a De novo device.  I don't see any point in gong through this exercise, just for the sake of doing it. 

    This not anything like a literature search for a CER.  CDRH should not care whether you have an actual list or have done a search, nor want to know your search methodology.  Its focus should be entirely on your rationale.  Since it is very hard, if not impossible, to provide a rationale for a device not having a predicate without having looked at any product codes, you will probably need to cite some in your rationale.  If you know your sector well, a formal search is often not necessary.

    I think this may be another instance of CDRH "just trying to help" (or at least look like it is trying to help) without being all that helpful.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 7.  RE: FDA Database Search - De Novo

    Posted 12-Feb-2020 10:31
    James,
    We have a database that integrates data from device product approvals, summary documents, and product codes.  With it we can do full text searches of all 510(k), De Novo, or PMA summaries.  The database also has indications for use statements that are extracted from the summaries. Simple to then export whatever is found.  Happy to explain further on a call and see if this will get you what you are looking for.
    Cheers,
    Melissa

    ------------------------------
    Melissa Walker RAC
    President & CTO
    St Louis MO
    United States
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  • 8.  RE: FDA Database Search - De Novo

    Posted 13-Feb-2020 04:46

    Thanks for all the comments and the discussion on this. 

    I am new to the Regulatory world and trying to navigate through the requirements in a sensible way, whilst also trying to make things easier for discussing the De Novo! I have performed a simple search with what I believe are the most relevant product codes, adding in some key words for good measure and we will write a justification accordingly. This is what I plan to submit in our De Novo to support there being no predicate. The product code will probably just follow the existing LLZ although It would be great to find a predicate and save some ££££ on the submission!

    To perform due diligence I thought there might be a database somewhere that people use to perform some quick searches rather than navigating through the FDA website, like @Melissa Walker has noted above. I agree that this route is a little over-kill but ​if such a database was to hand, it would be useful. 

    Thanks
    James



    ------------------------------
    James
    Head of QARA
    UK
    ------------------------------



  • 9.  RE: FDA Database Search - De Novo

    Posted 14-Feb-2020 08:33
    Eric Eggers had a program I used at one point which had taken every 510(k) clearance and loaded them into their database, such that you could search on indications, description or product type and see what similar devices with similar indications were out there.

    Interesting concept and helped with quick searches. I would sign up for a month subscription when I was first discussing potential classification with a client.  

    The software was called 510(k) Blaster.  Not sure if he and his team are still maintaining it but might be worth looking into; for $50 month subscription (which you can cancel after use, or keep), might save you some time and money.