AdvaMed Comments on FDA Device Remanufacturing Guidance

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AdvaMed says it supports FDA efforts to clarify which activities performed on medical devices are remanufacturing or servicing. In a 9/22 comment on an agency draft guidance, the association says that much device servicing performed by third-party servicing entities is actually remanufacturing and subject to FDA remanufacturing requirements.

“Guidance clarifying the difference between remanufacturing and servicing can help guide third-party servicers in understanding when their activities are subject to FDA regulation,” the comment letter says. “Additionally, clearer distinction between these activities will appropriately limit third-party servicers to routine servicing activities or, alternatively, illustrate that it is subject to the Quality System regulation and FDA submission requirements. Such an approach preserves the intended use and performance of the device and furthers patient safety.”

Because many third-party servicers will be unfamiliar with the regulatory requirements and terminology that are intrinsic to the draft guidance, AdvaMed says, FDA should work to simplify that guidance so that individuals who are not educated in regulatory requirements and terminology will understand their responsibilities under the guidance.

The comment letter offers suggestions relating to the education of third-party servicing entities on the existence of the guidance; aligning the title with the guidance purpose; the scope of the guidance document; the definitions section; changes involving software and cybersecurity issues; considerations for labeling; and enforcement of the guidance. The letter also contains specific line-by-line comments.

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