Regulatory Open Forum

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  • 1.  duration of contact

    Posted 08-May-2019 17:53
    Edited by Kristina Cook 08-May-2019 17:59

    Hi all, 

    I have a question about duration of contact.

    The duration of contact is broken down into limited (<24h), prolonged (24h-30d) and long term (30d+). I'm under the impression that it is the total time that the user is in contact with the device that should be taken into consideration (assuming of course, no residual material remains on the user after use) - is that correct?

    For example, if one uses a device for 1 minute per day for 3 months (say a total of roughly 90 minutes), this would fall into the limited contact category as it is less than 24h, even though they are using the device over multiple months. 

    Any input is appreciated!

    Thanks!

    - Tina



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    Kristina Cook
    San Francisco CA
    United States
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  • 2.  RE: duration of contact

    Posted 09-May-2019 01:58
    Hello Kristina,

    The short answer is yes.  There is emphasis now on accumulated use that may occur when the device is immediately replaced with another device of the same kind.  Discussions revolve around what is meant by immediately, i.e. few seconds to few minutes, but the idea being accumulated use should be considered.  It is also important to look at the actual intended use and purpose of the device, how it is used by the patient, is there are strict exposure that is obtained from patient use.  Your example is in the correct thinking though some would say 1 minute of use even accumulated might not push into the next duration level; you definitely have the right idea though.  What it was looking at is devices like wound care dressings where it is on for 2 - 5 days, but then immediately replaced by another wound care dressing that may be used for months at a time for diabetic ulcer patients, e.g. it would not be prolonged term use, but long term use.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 3.  RE: duration of contact

    Posted 09-May-2019 07:09

    Yes, you have that right.  It is the cumulative time of contact of the device (or devices for single use devices) with the patient for the duration of use or treatment, not the time over which it is used (weeks, months) unless the contact is continuous during that time.

     

    Lee Leichter

    President

    P/L Biomedical

    10882 Stonington Avenue

    Fort Myers, FL 33913 USA

    Office: +1-239-244-1448

    Cell: +1-239-994-6488

    Email: leichter@plbiomedical.com

     






  • 4.  RE: duration of contact

    Posted 09-May-2019 07:51
    Just to clear up some possible confusion here, the text in the first paragraph (total contact duration governs) is correct, and what I believe other responders have agreed with.

    On the other hand, the example in the 2nd paragraph of the OP is not consistent with the first, and is incorrect. Multiple uses of devices that have individual uses less than 24 hours but are cumulatively on the order of 90 days would categorize them as long term—not limited use.




  • 5.  RE: duration of contact

    This message was posted by a user wishing to remain anonymous
    Posted 11-May-2019 19:41
    This message was posted by a user wishing to remain anonymous

    For my own understanding, when you refer to the second paragraph of the OP stating daily exposure over 90 days (regardless of duration of contact each day), is it the total days that determines the total contact duration?  I ask, because my limited understanding would have led me to the same conclusion of "1 minute per day for 3 months (say a total of roughly 90 minutes), this would fall into the limited contact category as it is less than 24h, even though they are using the device over multiple months."   

    In this instance is the potential patient impact greater with a small dose over the 90 days, rather than the ~90 minute exposure when taken cumulatively?

    Thank you!


  • 6.  RE: duration of contact

    Posted 12-May-2019 07:49

    Unless there is something unique about the material or use of the device that would cause repeated short contacts to be somehow different than a single long contact, then these are equivalent. One of the other reasons behind the insistence on adding up repeated contacts was to ensure that contact with the same type of single use device over multiple uses was counted as cumulative use of the same device (e.g. a daily injection for the rest of your life captured as permanent instead of the 30 - 60 second contact of an individual injection captured as limited)

     

    Lee Leichter

    President

    P/L Biomedical

    10882 Stonington Avenue

    Fort Myers, FL 33913 USA

    Office: +1-239-244-1448

    Cell: +1-239-994-6488

    Email: leichter@plbiomedical.com

     






  • 7.  RE: duration of contact

    Posted 12-May-2019 09:11
    Ah, thank you for the follow-up question. It seems the confusion was on my part, as it is the summed up contact duration that governs. Kristina (the original poster) was entirely correct, as were all the respondents (except me).

    Ted




  • 8.  RE: duration of contact

    Posted 09-May-2019 07:57
    Hello Kristina

    That is a correct conclusion.

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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
    ------------------------------



  • 9.  RE: duration of contact

    Posted 12-May-2019 14:53
    Thank you all for the feedback, as well as the clarification on the follow up questions! Much appreciated!

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    Kristina Cook
    San Francisco CA
    United States
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