Have you applied Flowchart A and its supporting narratives from
this FDA guidance document?
Regardless of whether a new 510(k) is required or not, the labeling change to add a warning statement is a design change that must, for a class II device, be processed per 21 CFR 820.30. The LTF or 510(k) corresponds to the design output step of that process.
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Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
Principal Consultant
Ridgway, CO
United States
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Original Message:
Sent: 14-Jul-2022 01:20
From: Christopher Chin
Subject: Labeling IFU changes
In reference to a Class II device, does a change to IFU, adding a warning statement, require notification to FDA even though the intended use remains unchanged? If it doesn't require a new 510k, will a LTF suffice?
Please advise,
Christopher Chin