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"MODERNIZING" THE 510(k) – Other Criteria

  • 1.  "MODERNIZING" THE 510(k) – Other Criteria

    Posted 07-Jul-2019 11:56
    Edited by Julie Omohundro 08-Jul-2019 02:13

    I identified 10 commenters as having responded to FDA's question about whether it should consider criteria other than the age of the predicate "to inform our point of reference."  I interpreted this phrase to mean "to identify devices for inclusion on a public list."  One commenter said no, because they thought that "the current substantial equivalence process is robust." Since the current process doesn't include a list, I gathered this commenter interpreted FDA's somewhat murkily worded question to mean other criteria it should use "to inform a determination of substantial equivalence." 

    The other 9 commenters suggested a variety of criteria, including:

    • Commercial availability and viability
    • Type of and changes to technology
    • Nature of and changes to intended use
    • Scope and rapidity of innovation for that device type
    • Conformance to standards, guidelines, specifications
    • Demonstrated safety and effectiveness
    • Clinical track record
    • History of adverse events, recalls, market removals
    • Risk class, risk profile, risk analysis, risk to benefit
    • Specific concerns about a particular device or device type


    Most of those who offered suggestions had shown little to no enthusiasm for a list, and appeared to be offering these suggestions just in case FDA decided to publish one despite everyone's best efforts to persuade it not to.

    One patient group suggested a clinical record of at least a 95% survival rate at 10 years from entry to market. Sigh.



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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
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