Say I have a class IIa device (Device A) and I submit an application to the TGA to list this kind of device on the ARTG using Device A's cleared FDA 510(k) and the manufacturer's MDSAP certificate as foreign evidence. The ARTG application is approved and Device A is now available to supply.
A few years later, we develop Device B which is the same kind of device as Device A (as defined by the TGA) and want to supply it under this same ARTG listing. My questions are:
- Can and should each device have a separate Australian Declaration of Conformity?
- Does the class IIa evidence for Device B need to be the same as the original submission (FDA 510(k) and MDSAP) or would any equivalent evidence (e.g. EC certificate) be acceptable?
For the first question, my interpretation of Therapeutic Goods (Medical Devices) Regulations 2002 is that only one Australian DoC should exist per ARTG entry since the DoC is made in relation to a "kind of device", but would there be a problem with issuing a separate DoC for each Device A and Device B despite both being of the same kind of device?
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Ian Boland
Regulatory Affairs Specialist
NJ
United States
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