Regulatory Open Forum

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  • 1.  Product Name Change for submission

    Posted 29-Oct-2019 05:18

    Hi All.

    During development we have decided to change the marketing name of our device and I was wondering where best to describe this once we are ready for our 510(k) submission? I was thinking of summarizing in the cover letter and wondered what other people thought? 

    I want to highlight in the Technical File because we have had a pre-sub under one product name but will be submitting under a new name! There is no change in the product in any way from what the FDA has seen, it is purely a marketing name change.

    Thanks 

    James



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    James
    Head of QARA
    UK
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  • 2.  RE: Product Name Change for submission

    Posted 30-Oct-2019 08:03
    The best way that I have seen to address this it that there is a "project" name that is applied in the R&D phase, then a "product" name that is applied when the device is ready to market.  This is not an uncommon situation, and in fact there are some devices that have multiple product names across different geographies.  This can easily be explained, either in the cover letter or Executive Summary.

    Regards,
    James






  • 3.  RE: Product Name Change for submission

    Posted 30-Oct-2019 09:11
    I was thinking of just the cover letter but might reference in both places actually, thanks James.

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    James
    Head of QARA
    UK
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  • 4.  RE: Product Name Change for submission

    Posted 31-Oct-2019 12:58
    We handle any product name changes by including this in a "Change Summary" section at the beginning of the main 510(k) document, where we also describe any changes made to the device itself since our last communication with the agency (usually a presub).

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    Kristen Kanack PhD
    SVP, Regulatory and Clinical Affairs
    Salt Lake City, UT
    United States
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  • 5.  RE: Product Name Change for submission

    Posted 30-Oct-2019 09:32
    Hi James,
    If you have any prior communication with FDA about your product (e.g., presubmission(s)), you'll want to include a regulatory history in your pre-market submission. This is a great place to explain the device name change too (in addition to the cover letter). 
    Best,
    Danni

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    Danielle Briggeman MS
    Clinical & Regulatory Affairs Manager
    Portland ME
    United States
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  • 6.  RE: Product Name Change for submission

    Posted 31-Oct-2019 10:05
    A cover letter should be OK, but you should also indicate that it is a name change only and that the "new" device has identical properties, materials etc. to the "old" product particularly if your test reports carry the "old" product name.
    Regards

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    Steve Baker
    i-SMART Consulting US
    US +1 267 432 1045
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