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
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Original Message:
Sent: 07-Feb-2024 13:20
From: Anonymous Member
Subject: Extension of Shelf Life
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).