Regulatory Open Forum

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  • 1.  510k availability for advanced wound care product

    Posted 19-Apr-2018 03:13
    Hi, all.

    We are Japanese chemical company and looking for a good FDA consultant for our advanced wound care product.

    We are going to launch it first in US and then expand to other regions. The product is made of unique genetically-recombined protein, but we want 510k application.

    As we have no experience in US, it would be appreciated if some of you might help us.

    Sayaka
    Sanyo chemical, Japan


  • 2.  RE: 510k availability for advanced wound care product

    Posted 19-Apr-2018 14:34
    You cannot get your product cleared through FDA via the 510(k) process unless FDA determines it is substantially equivalent to a predicate.  It must have the same intended use AND

    1.  technological characteristics that are the same as those of the predicate device.

    OR


    2.  technological characteristics that are different from those of the predicate devices, AND

         the device is as safe and effective as the predicate device AND

         the technological differences do not "raise new questions of safety and effectiveness."

    If by "we want," you are saying that your company management is stubbornly insisting on a 510(k) even though it is clear that the above criteria are not going to be met, I recommend you tell consultants that you are looking for someone who will assist you with the content of the submission, but will not be responsible for advising you on whether or not the data are adequate to support substantial equivalence.  That's a happy situation for most consultants, since it is usually the latter responsibility that is the regulatory PITA, not the submission itself.

    On the other hand, if you really want to know, clarify that you are looking for someone who can also help you assess the likelihood that FDA will accept the data as supporting SE.



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    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
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  • 3.  RE: 510k availability for advanced wound care product

    Posted 20-Apr-2018 03:08
    Hi,

    First of all you have to find a predicate device to proof the equivalence of your product and you have to proof the safety and efficacy of your product. I suggest you have to again work on your Technical file and submission dossier.

    Let me know if you need any additional support or advice.

    Regards,
    Sandeep Malakar
    sandeep.malakar@stryker.com
    Ph: +91 9911510333
    Staff Engineer
    Gurgaon
    India

    ------------------------------
    Sandeep Malakar
    sandeep.malakar@stryker.com
    Ph: +91 9911510333
    Staff Engineer
    Gurgaon
    India
    ------------------------------



  • 4.  RE: 510k availability for advanced wound care product

    Posted 20-Apr-2018 07:16
    ​Without knowing details about your product, the only advice I can offer is to look into the product code FRO. This is the code assigned to wound dressings that make a drug claim and are thus combination products. Jurisdiction is assigned to the device branch.

    Normally, wound dressings are devices, because they provide a barrier or irrigation effect. However, any kind of drug claim (e.g. the claim that the wound dressing has an antimicrobial effect) will make it a combination product.

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    Jean Bigoney PhD, RAC
    Managing Member
    Murphy NC
    United States
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  • 5.  RE: 510k availability for advanced wound care product

    Posted 20-Apr-2018 07:51
    Hello Sayaka

    From your post it sounds as if this product is not approved by PMDA. What classification is this, I would imagine given the technology, it would be highest class. And the recombinant is animal derived?

    Julie is right that a 510(k) would probably be difficult unless you have identified a suitable predicate you think could pass muster, but you will want to work with a consultant experienced in classification requests, De Novos and pre-submissions. I worked on tge first regulatory filings for a combination wound dressing Tegaderm-CHG when I was at 3M and we first approached FDA with antimicrobial claims.  That Division can be a "tough nut to crack" when it comes to new technologies. That was in the mid-2000s. 

    I have a former Japanese colleague who consults and has for years, pretty much exclusively with Japan companies helping them to register here, or helping US companies register there.  Her name is Rica Morris, and she can be found on LinkedIn. In the event there are many with that name, she worked at 3M, and AMS, major medical device companies in the US, and may be a helpful resource for you. 

    Best regards,

    Ginger Cantor, RAC, MBA
    Centaur Consulting LLC centaurconsultingllc@gmail.com
    (+1) 715-307-1850





  • 6.  RE: 510k availability for advanced wound care product

    Posted 20-Apr-2018 15:16
    Hi I'm Mark DuVal, our firm does lots of wound dressing submissions.  We know that FDA Branch and Division very well.  If you want to talk to us about your product/project contact me at duval@duvalfdalaw.com or 612.338.7170 x1.  Our website is DuVal & Associates, PA | Drug, Device, and Food Lawyers

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    Mark DuVal FRAPS, JD
    President & CEO
    Minneapolis MN
    United States
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  • 7.  RE: 510k availability for advanced wound care product

    Posted 22-Apr-2018 21:57
    Dear all,

    Thank you all! We are much clearer about the 510k procedure now and realise there are still a lot of things we must clarify internally by ourselves. Thanks to all of your kind advice!

    Kind regards,

    sayaka


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    Sayaka Takami
    Japan
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