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Which 510k would be appropriate? Special or Abbreviated?

  • 1.  Which 510k would be appropriate? Special or Abbreviated?

    Posted 16-May-2017 18:21
    If a manufacturer  of preface abutments has a 510k for a Cobalt-Chromium (CoCr) type of the product and would like to now get clearance for a Titanium (Ti) version of the same device, can it be done through a Special or Abbreviated 510k? If so, which would be more appropriate?

    A preface abutment is a regulated product that is milled (machined) into an abutment which is placed on a dental implant inside patient's mouth.
    Of interest to regulators, is the design and integrity of the portion of the abutment which mates with the implant.

    The only difference in this case is a material change.  There is significant data available for on both CoCr and Ti preface abutments.

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    Robert Nami
    Carlsbad CA
    United States
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  • 2.  RE: Which 510k would be appropriate? Special or Abbreviated?

    Posted 17-May-2017 03:28
    It would be a Special 510(k), Robert. Here's a link to the latest draft guidance from FDA on when to submit a new 510(k) for a design change: 'Deciding When to Submit a 510(k) for a Change to an Existing Device - Draft Guidance for Industry and Food and Drug Administration Staff'.

    Hope this helps.

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    Roger Gray
    VP Quality and Regulatory
    Donawa Lifescience Consulting
    Rome, Italy
    +39 06 578 2665
    rgray@donawa.com
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  • 3.  RE: Which 510k would be appropriate? Special or Abbreviated?

    Posted 17-May-2017 07:56
    Ideally it would be a Special 510(k). However, the Special 510(k) guidance calls out materials changes as an example of a "significant technical change" that would preclude using a Special 510(k) in that situation. You'd have a couple possibilities.

    1) call the review branch and ask, or
    2) just submit the Special and see what happens. Probably the worst case is FDA flips it to a traditional 510(k) and you need to send in more of your testing data. In my experience Abbreviated take just as long as Traditionals anyway, so you wouldn't be losing much and could gain a lot of time

    g-

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    Ginger Glaser RAC
    Vice-President, Quality and Regulatory Affairs
    Maplewood MN
    United States
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  • 4.  RE: Which 510k would be appropriate? Special or Abbreviated?

    Posted 17-May-2017 08:26
    Robert,

    Metals (e.g., cobalt-chromium) may be getting obsolete and it is being replaced by the metals of choice (e.g., titanium) in the world of dental implants. 

    A special 510(k) should be a choice to consider!  Sometimes, even for special 510(k)s, it has taken almost or longer than 90 days.  Some firms wouldn't bother with a special and rather go with a traditional 510(k).

    It is your call that matters!   

    Thank you.

    s/ David
    ______________________________________________
    Dr. David Lim, Ph.D., RAC, ASQ-CQA 
    REGULATORY DOCTOR
    Phone (Toll-Free): 1-(800) 321-8567

    NOTICE: This communication (including any attachments) may contain privileged or confidential information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this communication and/or shred the materials and any attachments and are hereby notified that any disclosure, copying or distribution of this communication, or the taking of any action based on it, is strictly prohibited.







  • 5.  RE: Which 510k would be appropriate? Special or Abbreviated?

    Posted 17-May-2017 17:19
      |   view attached
    Hello Robert

    Well, you could try an Abbreviated 510(k) because there is a Special Controls Guidance Document, but I strongly suspect FDA will convert it to a Traditional 510(k). And note the provision in this special controls for potentially required clinical studies if the abutment is angled over a certain amount which would definitely result in a Traditional 510(k).


    The change in material is considered significant and you will need to plan that FDA will expect all of the data supporting an abutment submission, based on FDA's guidance document for abutments.  The last time I looked, review/clearance time lines for abutments were running at about 9-12 months from date of submission to FDA, and most have been cleared via the Traditional route.

    Be sure you look at the new FDA Final Guidance  on use of 10993-1 from last June 2016 (attached here). 

    FDA is really becoming strict on this, and there is where your change in materials will hit you, even if titanium, you will have questions on biocomp testing of the final sterilized packaged device, and which implants you are certifying it is compatible with.

    Good luck, and let me know if you need additional assistance with this filing. 

    Best regards,

    Ginger Cantor, MBA, RAC
    Centaur Consulting LLC
    +1 (715) 307-1850





  • 6.  RE: Which 510k would be appropriate? Special or Abbreviated?

    Posted 17-May-2017 17:24
    Hi Robert,

    I agree with the feedback from the others.

    The following is from FDA guidance (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/HowtoMarketYourDevice/PremarketSubmissions/PremarketNotification510k/ucm134573.htm#criteria):

    Criteria for a Special 510(k)

    Under the New 510(k) Paradigm, a manufacturer should refer to 21 CFR 807.81(a)(3) and the FDA guidance document entitled, "Deciding When to Submit a 510(k) for a Change to an Existing Device," to decide if a device modification may be implemented without submission of a new 510(k). If a new 510(k) is needed for the modification and if the modification does not affect the intended use of the device or alter the fundamental scientific technology of the device, then summary information that results from the design control process can serve as the basis for clearing the application along with the required elements of a 510(k) found in 21 CFR 807.87.

    To optimize the chance that a Special 510(k) will be accepted and promptly cleared, 510(k) submitters should evaluate each modification against the considerations described below to insure that the particular change does not: (1) affect the intended use or (2) alter the fundamental scientific technology of the device.

    (Be aware that the referenced guidance document is from 1997; there is a newer draft of this document which Roger kindly linked earlier.)

    The guidance also states the following, which may be of interest to you as you indicated that your product is an implant:

    In addition, FDA is concerned with changes in materials in certain devices. While FDA acknowledges that many such changes can be processed as Special 510(k)s, there are certain types of changes in materials that may raise safety or effectiveness issues that continue to warrant a more intensive evaluation. This includes a change in material(s) in an implant, or other device that contacts body tissues or fluids, to a material type that has not been used in other legally marketed devices within the same classification regulation for the same intended use (i.e., "legally marketed predicate device").

    Following up from what Ginger and David said, I would say that it is possible to submit a Special (providing a clear rationale as to why the fundamental scientific technology of the product is not altered per the guidance), however I think that there is a good chance that your submission could get converted to a Traditional 510(k).  You could consider different plans, as Ginger mentioned, which may include submitting a Special but preparing the additional documentation required for a Traditional while your submission is under review to minimize any response time if your submission were to be converted.  I have minimal experience with Special 510(k)s, but the ones that I have seen did get converted, although it would have been under a different review division than your product.

    Hope this helps!
    Liz



    ------------------------------
    Elizabeth Goldstein RAC
    Regulatory Affairs Specialist
    Medtronic Vascular
    Santa Rosa CA
    United States
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  • 7.  RE: Which 510k would be appropriate? Special or Abbreviated?

    Posted 17-May-2017 17:32
    One more point - just to elaborate on the Special-to-Traditional conversions that I've seen - I don't remember the exact feedback, but it was something along the lines of - if you need testing to support the change, then it doesn't qualify for a speical (which almost begs the question of what's left that falls into that category)...  But per what others have said, it seems that FDA can get quite strict about what they will allow in a Special 510(k) - and biocompatibility testing to show safety of the material in an implant/patient-contacting device is likely to push that threshold.

    ------------------------------
    Elizabeth Goldstein RAC
    Regulatory Affairs Specialist
    Medtronic Vascular
    Santa Rosa CA
    United States
    ------------------------------



  • 8.  RE: Which 510k would be appropriate? Special or Abbreviated?

    Posted 18-May-2017 10:29
    Thank you everyone for the feedback.
    With the volume of data available on both CoCr and Ti abutments, I was even thinking a letter to file would be sufficient but that having clearance through a S510k would be a "safer" alternative.

    ------------------------------
    Robert Nami
    Carlsbad CA
    United States
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  • 9.  RE: Which 510k would be appropriate? Special or Abbreviated?

    Posted 18-May-2017 16:12
    Hi Robert,

    An LtF is definitely not appropriate here as your core material is changing. However, I agree with most of the comments made before. One thing that may help it stay as a special is if your performance testing hasn't changed and that the product w/ new material, and you can still meet the same acceptance criteria, using the same methods as the original 510(k).

    Mike

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    Michael Nilo
    Network Regulatory Partners
    Nilo Medical Consulting Group
    Portland OR
    United States
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  • 10.  RE: Which 510k would be appropriate? Special or Abbreviated?

    Posted 19-May-2017 08:05
    Hello Robert,

    There has been so much focus in the Dental Division on abutments.... I would almost eat my socks if this was not converted into a Traditional 510(k). 

    As was mentioned before, the 510(k) guidance states that if any testing data is included in the submission, it is not appropriate for a Special.  There is just no realistic way I see the Dental Division allowing this. My last 7 years  at 3M were at 3M ESPE, their dental division. I had enough FDA interaction there to convince me if this.

    Ginger Cantor, MBA, RAC
    Centaur Consulting LLC
    (715) 307-1850