Regulatory Open Forum

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  • 1.  Custom Made Device

    Posted 24-Apr-2019 10:29
    Hello Members,

    Is anyone here with prior experience on custom made devices? I would appreciate if anyone could provide me some insight on the  regulations behind custom made device. My interpretation of the custom made device guidance is that we cannot sell or make no more than 5 devices per device type in an year.  If we are using multiple devices of a device type to treat a patient in different anatomical locations then it will be accounted as one device. Also, if multiple devices of a device type are used in a same anatomical location then it will be considered as one device.

    Am I interpreting the no more than five units per year of a device type correctly? What are the other regulatory challenges around custom made devices?

    FDA guidance on custom made devices- https://www.fda.gov/downloads/medicaldevices/deviceregulationandguidance/guidancedocuments/ucm415799.pdf

    Thank you,
    Kind regards,

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    Shubhajit Mitra
    Senior Regulatory Affairs Specialist
    Hopkinton MA
    United States
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  • 2.  RE: Custom Made Device

    Posted 25-Apr-2019 09:16
    Hello Shubhajit

    In my experience, your company should determine how to define "device type" for your specific device and be prepared to defend it.  FDA currently requires annual reporting for devices that are released to the market under the custom device exemption.

    Best Regards,  Lauren

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    Lauren Kamer RAC
    Director of Regulatory
    United States
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  • 3.  RE: Custom Made Device

    Posted 25-Apr-2019 12:58

    Hi Shubhajit,

     

    I have a friend who has been a med device consultant for 30+ years I can connect you with. I think he'd be happy to talk with you for an initial complimentary conversation. Let me know your email when you can, and I'll connect the two of you. It would be just for this.

    Cheers, Deric