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  • 1.  Abbreviated 510(k) question

    This message was posted by a user wishing to remain anonymous
    Posted 21-Oct-2020 08:50
    This message was posted by a user wishing to remain anonymous

    We have an ongoing debate.  One party in the debate believes that a predicate device is not required for an Abbreviated 510(k).  The other party believes that a predicate device is required.

    Both parties read the various guidance documents and regulations.  The difference is in the interpretation of what the guidance says.

    Any thoughts?

    Thanks


  • 2.  RE: Abbreviated 510(k) question

    Posted 21-Oct-2020 13:03
    You always have to identify a predicate device in a 510(k), regardless of whether it's traditional or abbreviated. The whole premise of a 510(k) is demonstrating that the subject device is substantially equivalent to a legally marketed device (predicate). For more information please see section V.11 and V.12 of this guidance document: https://www.fda.gov/media/130647/download

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    Jeffrey Freedman
    QA/RA Specialist III
    Lowell MA
    United States
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  • 3.  RE: Abbreviated 510(k) question

    Posted 22-Oct-2020 07:15

    Predicates are required element of the 510(k) process and necessary to establish that the proposed product has the same intended use and classification so as to be considered for a 510(k).  Otherwise, it is a PMA or needs to go through the De Novo classification process. "Abbreviated", along with Traditional and Special, are only the options available to provide the "supporting" data to FDA to make a Substantially Equivalent determination.

     

     

    Lee Leichter

    President

    P/L Biomedical

    10882 Stonington Avenue

    Fort Myers, FL 33913 USA

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  • 4.  RE: Abbreviated 510(k) question

    Posted 22-Oct-2020 08:13
    I can see why this debate started - the September 2019 guidance for Abbreviated 510(k)s does not include any mention of the need to reference a predicate device (indeed, the word 'predicate' does not occur anywhere in the guidance!), although it does state: "An Abbreviated 510(k) submission must include the required information identified in 21 CFR 807.87." You can be sure, however, that FDA will issue an RTA for any Abbreviated 510(k) that does not include a predicate device (see Section C.15.a. of the Abbreviated 510(k) RTA checklist).

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    Roger Gray
    VP Quality and Regulatory
    Donawa Lifescience Consulting
    Clinical Studies - Regulatory - Quality Systems
    Rome, Italy
    +39 06 578 2665
    rgray@donawa.com
    www.donawa.com
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  • 5.  RE: Abbreviated 510(k) question

    Posted 23-Oct-2020 07:55
    Yes, typically we think of a needed predicate.    Is the wording in the new Abbreviated guidance now reflecting the fact that perhaps more innovative technology with no clear predicate can use Abbreviated route if the performance conforms to FDA recognized consensus  standards and/or a Special Controls document?
    i thought that was FDA's point in the rewrite of the  Abbreviated 510k Guidance.  Similarly,  the revised Special 510k allows for a company to use it even if there is a change in labeled indications, under some certain circumstances.   That was never the case under a Special 510k before last fall.


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    Ginger Cantor, MBA, RAC
    Founder/Principal Consultant
    Centaur Consulting LLC
    River Falls, Wisconsin 54022 USA
    715-307-1850
    centaurconsultingllc@gmail.com
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  • 6.  RE: Abbreviated 510(k) question

    This message was posted by a user wishing to remain anonymous
    Posted 28-Oct-2020 17:23
    This message was posted by a user wishing to remain anonymous

    Thanks to all for the replies.  Also sent a question to DICE, who pointed to the guidance and 807.87 for the requirements.  Given that the RTA guidance is specific for the presence of a predicate device, I think the question is answered.