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  • 1.  510k summary vs. executive summary vs. substantial equivalence discussion sections

    This message was posted by a user wishing to remain anonymous
    Posted 21-Sep-2020 11:04
    This message was posted by a user wishing to remain anonymous

    Hi all, 
    I am trying to create my own 510k template following the FDA guidance on 510k format. I am not sure I get the difference between sections 5, 11 and 12 of the 510k:
    5) 510(k) Summary
    11) Executive Summary/Predicate Comparison
    12) Substantial Equivalence Discussion

    I understand that section 5 is the summary that will be publicly available to competitors in the FDA database. I understand what should go in the section 11.SE discussion, i.e., a tabular comparison of technological characteristics and a discussion of the differences. 

    What about section 12. Executive summary/Predicate comparison? Isn't this a duplicate of section 5 and section 12? What is the scope of such a chapter? The description in the guidance sounds very similar to what goes in section 12.
    Thanks for your help.
    Best


  • 2.  RE: 510k summary vs. executive summary vs. substantial equivalence discussion sections

    Posted 21-Sep-2020 15:49
    Hi Anon.

    It has been quite a while since I did 510(k) work but as I remember this, the section labeled as Executive Summary is supposed to be tabular or over-arching review of the predicate versus the subject device.  The discussion is meant to be just that - a more detailed discussion explaining the logic that was used to make the SE decision and is usually used as your opportunity to "convince" the FDA reviewer that the products are, in fact, substantially equivalent.  This becomes especially important in the event that there is a difference between the two items.  This is your opportunity to explain why the difference(s) would not impact the safety or efficacy of the product.

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    Victor Mencarelli
    Global Director Regulatory Affairs
    MelvilleNY
    United States
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  • 3.  RE: 510k summary vs. executive summary vs. substantial equivalence discussion sections

    Posted 21-Sep-2020 16:17
    Some 510(k)s have been released via the Freedom of Information Act here:

    https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm

    Maybe one of those can help your templating process.

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    Edward Panek
    VP, QA/RA
    Blue Spark Technologies
    Research into Neural Nets - https://www.twitch.tv/edosani
    ------------------------------



  • 4.  RE: 510k summary vs. executive summary vs. substantial equivalence discussion sections

    Posted 22-Sep-2020 00:27

    Hi

    For Section 12 :Substantial Equivalence;  Run it through the SE determination flowchart in Appendix A of the guidance document "The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications"  https://www.fda.gov/media/82395/download

     Compare your device to the predicate using both narrative as well as a tabular format (Similarities and Differences). Detailed comparison between device and predicate
    sufficient to demonstrate the substantial equivalence of the devices that explains the below;

    • Indications for use
    • Technology
    • Performance specifications including any testing

    Section 5 : Could be either a summary or a statement . Refer to the link for details https://www.fda.gov/medical-devices/premarket-notification-510k/content-510k#link_7

    ( Other useful links " Format for Traditional and Abbreviated 510(k)s" https://www.fda.gov/media/130647/download )

    Hope this helps!

    Best 





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    Shilpa Pillai
    Naperville IL
    United States
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  • 5.  RE: 510k summary vs. executive summary vs. substantial equivalence discussion sections

    Posted 22-Sep-2020 06:35
    Hello,

    This can be confusing because indeed while you are writing the submission often times the content in Section 5, Section 10, and Section 12 (and even Section 11) often are quite the same.  How we like to separate these sections out is including the information in the following sections:

    • Section 5, 510(k) Summary (or 510(k) Statement though we never use Statement because too much of a pain if a request is made):  This is the actual 510(k) Summary, the document that gets loaded up onto the FDA's 510(k) database.  it includes information like device description, regulatory description, predicate device, predicate device comparison (a table), and summary of the (bench) performance and any clinical performance testing done.  As mentioned this is a public document, so you will want to write this accordingly.  We always use the content of Section 10 and 12 and "pear it down" meaning we take out proprietary information, confidential information, or other non-essential information.  As an example, in Section 12 SE comparison table we may specific 302SS anodised with such and such, but in Section 5 SE comparison table, we just put stainless steel.
    • Section 10, Executive Summary: This often has a lot of repeat information from Section 5 and Section 12, but also includes much more information if required.  As an example, if there was a Q-Submission done all of this information is included here.  If there are reference devices used or marketing history or previous generations of the device needing to be explained, this is done in this section.  We do provide a comparison table between the subject device and predicate device, but do not have a column for why there is no differences - this is kept for Section 12.  If we use any reference devices, this is where we discuss this in much more detail than Section 12.  This section also should be used if you had submitted a previous 510(k) which was withdrawn or cancelled.  You should go point-by-point on how all the deficiencies in the previous submission have been addressed.  So yes, there is a reason Section 10 is used, because having Q-Submissions, IDEs, or previous submissions withdrawn, this is the place and opportunity to describe how this 510(k) addresses all those points !
    • Section 12, Substantial Equivalence Discussion: To continue we do not want Section 12 to get "convoluted" with lots of unnecessary information.  We may have a very short discussion on reference devices we use, but the majority of the section is the SE comparison table where we compare the subject device and predicate device - with now a column supporting any differences between the device and an explanation of why there is no additional questions of safety or efficacy.  As mentioned, we do put the SE comparison table in Section 5, but it definitely is summarised and confidential/proprietary information removed.
    Hopefully that helps, while there is some redundancy in the information presented in these different sections, there are reasons for each of these sections.  The biggest thing to make sure is the information between the sections is consistent, i.e. the indications for use statement is the same between the sections.  If the device is a well recognised device, been on the market for a long time, often Section 5, 10, and 12 become an exercise in cut and paste !  However, for complicated devices or new technology introduced into existing devices, Section 10 and Section 12 do have necessary information there.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 6.  RE: 510k summary vs. executive summary vs. substantial equivalence discussion sections

    Posted 22-Sep-2020 06:47
    Hi Anon,

    Even though the material presented in these sections may seem redundant, they are not.  As you well noted, the (5) 510(k) Summary is publicly available, and should be written such that a lay person can understand the substantial equivalency argument.  The Executive Summary (11) is at a higher level, more technical, but is still just a summary to draw a conclusion of substantial equivalence.  The substantial equivalence discussion (12) is where you really get down to brass tacks and need to not only draw conclusions of substantial equivalence to the predicate but also point out differences between your device and the predicate and how they do not invalidate your selection of the predicate.  I think that the latter is the most convincing argument to the FDA reviewer, and if you do not address in your submission you are leaving yourself open to challenge.

    Regards,
    James

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    James Bonds J.D.
    Director Regulatory Affairs
    Atlanta GA
    United States
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  • 7.  RE: 510k summary vs. executive summary vs. substantial equivalence discussion sections

    This message was posted by a user wishing to remain anonymous
    Posted 22-Sep-2020 14:29
    This message was posted by a user wishing to remain anonymous

    Greenlight Guru also has a great free e-book on the 510(k). The key difference between Executive Summary and 510(k) summary is the latter is public, so it has less detail. Also, FDA has said to put a summary of your studies into the Executive Summary, per the format in the Bench testing guidance.


  • 8.  RE: 510k summary vs. executive summary vs. substantial equivalence discussion sections

    This message was posted by a user wishing to remain anonymous
    Posted 25-Sep-2020 16:29
    This message was posted by a user wishing to remain anonymous

    Thank you all. Very helpful feedback.