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  • 1.  "Clean up 510k"

    This message was posted by a user wishing to remain anonymous
    Posted 27-Jun-2019 16:30
    This message was posted by a user wishing to remain anonymous

    Hello, 

    We are in the process of preparing a 510k that will include a change that we have deemed to require a 510k submission, which has not yet been implemented in the commercial device" as well as a series changes that we deemed to not require a 510k, and which have already been implemented. 

    We are clear from the guidance that all of these changes should be included and that the full device will be included in the device description. However, in the presentation of the substantial equivalence and performance data, do we separate the two types of changes in some way. For example, do we need to mention the 'non 510k changes'  in the SE and do we need to submit performance data?

    Any experience you have in doing these effectively is helpful. 

    Cheers!



  • 2.  RE: "Clean up 510k"

    Posted 28-Jun-2019 01:40
    No, the "non-significant" changes you've made to the device are not separated out in your SE justification.  The SE justification is a comparison of the application device, as you want cleared, against the predicate that was your cleared device. 

    If the changes you made along the way in the device are pertinent to an SE decision, then you talk about them as if they are new.

    I would, however, be very clear in your device description of what changes you've already made so that it's clear that you believe that it was legitimate to include those changes in a device that is currently in commercial distribution.

    ------------------------------
    Craig Coombs
    President, Coombs Medical Device Consulting
    Alameda CA
    United States
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  • 3.  RE: "Clean up 510k"

    Posted 28-Jun-2019 07:04

    You must mention all changes from the cleared product and should be clear as to which change(s) have been implemented and which have not.  You also need to provide data to support the product as described, which must include product with the changes already made.

     

    Lee Leichter

    President

    P/L Biomedical

    10882 Stonington Avenue

    Fort Myers, FL 33913 USA

    Office: +1-239-244-1448

    Cell: +1-239-994-6488

    Email: leichter@plbiomedical.com