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Closed container Packaging validations (shipping/primary barrier)

  • 1.  Closed container Packaging validations (shipping/primary barrier)

    This message was posted by a user wishing to remain anonymous
    Posted 23-Oct-2017 11:24
    This message was posted by a user wishing to remain anonymous

    ​Hi All,

    I have a question about my company wanting to use packaging validations on the worst case packaging for a different product in our portfolio that was over 10 years ago in support of a product in a PMA. T validations are for shipping and to show the product remains sterile. However, the testing  it is not the actual product and FDA may not consider it simulated.
    I suggested they repeat the testing for our actual packaging since its PMA and not a 510k where they have used these other adoptions. and got clearance.
    any thoughts on  this. I was going to try and find a happy medium by suggesting a small sample size to redo testing 30 for 95% confidence) 
    IMO, we may need to redo it since its in support of an Original PMA and we need to create a baseline to support future PMA Supplements.

    Thoughts or suggestions.  I have never worked with this group before and they have never done a PMA so I am confused by the resistance to not have current state of the art testing.

    thanks