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  • 1.  During IUO reagent testing, what label shall be put on the instruments used for the testing? RUO? or IUO?

    This message was posted by a user wishing to remain anonymous
    Posted 09-May-2023 10:42
    This message was posted by a user wishing to remain anonymous

     



  • 2.  RE: During IUO reagent testing, what label shall be put on the instruments used for the testing? RUO? or IUO?

    Posted 09-May-2023 11:06

    The label on the instrument depends on its regulatory status.

    It is either cleared or not. If cleared it can't be IUO or ROU.

    If not cleared it is either covered under Part 812 or not. If under Part 812 it can't be IUO or RUO.

    If not under Part 812, follow the information in 809.10(c)(2).

    For an instrument in the laboratory research phase of development, and not represented as an effective in vitro diagnostic product, then label it RUO.

    For an instrument being shipped or delivered for product testing prior to full commercial marketing, then label it IUO.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 3.  RE: During IUO reagent testing, what label shall be put on the instruments used for the testing? RUO? or IUO?

    Posted 09-May-2023 11:42

    Assuming testing will take place in the United States, the label on the instrument is independent from the label on the reagent. While the reagent may be used for IUO (Investigational Use Only), the instrument could well have been previously cleared by the FDA. See below breakdown.

    Instruments Cleared under 510(k) or De Novo requests.
    Must bear label under which it was cleared and comply with 21 CFR 801 and 21 CFR 809.10. 

    Class I Instruments or 510(k) exempt Class II
    Label must comply with 21 CFR 801 and 21 CFR 809.10. 

    Class II Instrument (not cleared by FDA) used in Investigational Studies to Support Future Regulatory Submission
    Label must comply with 21 CFR 812.5.

    Class II Instrument (not cleared by FDA) used for R&D Purposes Only
    The criteria in section 812.2(c)(3) also include compliance with labeling requirements
    section CFR 809.10(c), which exempts shipments and other deliveries of IVDs from certain
    labeling requirements if either (1) the device complies with part 812, or (2) the investigation
    is not subject to part 812 and one of the following conditions is met:
    (i) For a product in the laboratory research phase of development, and not
    represented as an effective in vitro diagnostic product, all labeling bears the
    statement, prominently placed: "For Research Use Only. Not for use in diagnostic
    procedures.''


    The FDA Guidance Document further expands on this subject:  https://www.fda.gov/files/medical%20devices/published/Distribution-of-In-Vitro-Diagnostic-Products-Labeled-for-Research-Use-Only-or-Investigational-Use-Only---Guidance-for-Industry-and-FDA-Staff.pdf



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    Carol
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  • 4.  RE: During IUO reagent testing, what label shall be put on the instruments used for the testing? RUO? or IUO?

    Posted 11-May-2023 01:04

    Hello Anon,

    Just to add what has already been provided - there is a difference between Research Use Only (RUO) and Investigational Use Only (IUO) concerning in vitro medical devices (IVD).  RUO is just that - research - it is not used with, on, or in patients.  IUO are investigational meaning they are being used with human specimens as part of a clinical investigation or clinical trial.  Carol provided the reference to 21 CFR Part 812 for how research and investigational use products are to be labelled.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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