Regulatory Open Forum

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  • 1.  Extension of Shelf Life

    This message was posted by a user wishing to remain anonymous
    Posted 07-Feb-2024 15:23
    This message was posted by a user wishing to remain anonymous

    I am wondering what the typical path is to extend shelf life?  We filed our 510(k) with 1 year stability testing so were cleared for that but noted that we are targeting 2 years. We have just completed 2 years and I am wondering how to inform the FDA.  Is it usually a Note to File?  We will be filing an additional label expansion 510(k) but I am wondering if we could get approval for increase shelf life without waiting for this 510(k). 



  • 2.  RE: Extension of Shelf Life

    Posted 07-Feb-2024 15:37

    In general, no new 510(k) is needed for a shelf-life extension if the extension is done using the same basic protocol that was used in the 510(k). But if a different protocol or method is used, then a new 510(k) would generally be needed.



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    Kevin Randall, ASQ CQA, RAC (U.S., Europe, Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright by ComplianceAcuity, Inc. All rights reserved.
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  • 3.  RE: Extension of Shelf Life

    Posted 08-Feb-2024 06:59

    Hello,

    I agree with Kevin, that generally no 510(k) is required provided the extended shelf life study follows the same parameters as the shelf life study submitted with the 510(k).  Best practice is to include in the submission (510(k) or PMA) the shelf life study protocol, and that extensions to shelf life are contemplated based on acceptable outcomes under that protocol.  If this is stated up front, FDA will usually include a statement in the original clearance (510(k)) or approval (PMA) letter that shelf life extensions satisfying the requirements of the shelf life protocol contained in the submission will be acceptable.  Of course, on the PMA side, any changes to shelf life should also be included as a change in the PMA annual report.  Not necessary for 510(k).

    James



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    James R. Bonds J.D.
    Director Regulatory Affairs
    Atlanta GA
    United States
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  • 4.  RE: Extension of Shelf Life

    This message was posted by a user wishing to remain anonymous
    Posted 08-Feb-2024 09:20
    This message was posted by a user wishing to remain anonymous

    Thank you, Kevin and James! I appreciate your insight.