Implementing the 510 (K) correctly in compliance with the latest proposed FDA changes
A 510(K) is a premarket submission made to
FDA to demonstrate that a device to be marketed is at least as safe and
effective, meaning that which is substantially equivalent, to a legally
marketed device that is not subject to premarket approval (PMA).
There are three types of Premarket
Notification 510(K)’s that may be submitted to FDA: Traditional, Special, and
Abbreviated. Product modifications that could significantly affect safety and
effectiveness are subject to 510(K) submission requirements under 21 CFR 807 as
well as design control requirements under the Quality System (QS) regulation.
Under the QS regulation, all Class II and III devices and certain Class I
devices are required to be designed in conformance with 21 CFR 820.30 Design
Controls. The FDA provides guidance on these.
Needed:
A thorough understanding of these aspects and the FDA’s latest proposed changes
In accordance with the concern evinced by
many industry groups and associations, the FDA introduced as many as 60 proposals
in August 2010, into the manner in which the 510 (K) process could be
expedited. This was done with the intention of accelerating the speed at which
newly approved medical devices could be made available to patients across the
country. However, with the number of proposals being too many and their scope
being too wide; the medical industry suggested that the FDA select for
implementation only those proposals that enjoyed the broad consensus of the
stakeholders, such as increased reviewer training, development of specific and
relevant guidance documents, and enhancements or improvements to the de novo
review pathway, among other suggestions.
An
upcoming seminar by GlobalCompliancePanel, a leading provider of professional
trainings for the regulatory compliance industries, will clarify on these areas
taken up for immediate change by the FDA and place them in the right context.
It will address key resources when making critical decisions. This seminar will
offer important insights into the core areas of premarket notifications, as
well as the Design Control requirements under QS regulations and Design
Controls.
To
enroll for this seminar, just log on to
The
Director at this seminar is David R. Dills, a senior Regulatory Affairs &
Compliance Consultant. David provides regulatory, compliance and quality
consultative services for medical device and pharmaceutical/combination
manufacturers, and also has an accomplished record with more than 24 years of
experience with Class I/II/III medical devices, In Vitro diagnostics, and
pharmaceuticals in the areas of Regulatory Affairs, Compliance and Quality
Systems.
An
understanding of the core elements of the PMA
At this seminar, David will help
participants understand how medical device manufacturers can locate a
"predicate" device and go through the content and format of the
510(K), and offer an understanding of the De Novo process and the expectations
for possibly marketing a low risk device, and the potential impact of FDA's
proposed changes to the 510(K) process and why manufacturers need to pay
attention to these.
He will also offer understanding of all the
crucial aspects of the PMA, such as the differences between the Traditional,
Special and Abbreviated submissions, an understanding of the Substantial
Equivalence and how it is applied, who is required to submit the application to
FDA, where to submit the 510(K) and what to expect with the review and approval
process, when a device company requires this process and when it does not, the
applicable exemptions to the submission process and special considerations, and
so on.
Labels: 21 CFR, 510(K), compliance, Design Controls, fda, medical device, pharmaceutical
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