AdvaMed on Digital Breast Tomosynthesis Reclassification

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AdvaMed says it is not taking a position on an FDA proposal to reclassify digital breast tomosynthesis systems from Class 3 into Class 2, but does have implementation concerns if the reclassification is approved. In its comment letter, the trade group says, “If FDA finalizes the proposed order, a clear, predictable, and appropriately phased transition will be essential to avoid unnecessary duplication, preserve regulatory continuity, and support consistent application of the new special controls.”

AdvaMed recommends that FDA:

  • establish clear transition provisions for approved DBT systems and pending PMAs and PMA supplements, including recognition of previously approved PMA devices as predicates under the new Class 2 framework;
  • make DBT-specific implementation guidance that explains the evidence, testing, comparator, and reader-qualification expectations associated with the special controls;
  • publish draft implementation guidance sufficiently in advance of the final order and provide an adequate implementation period;
  • apply evidence expectations proportionately to the nature and impact of a device modification and permit manufacturers to leverage prior evidence and targeted testing when scientifically justified;
  • clarify that appropriate predicate devices for DBT 510(k) submissions are other legally marketed DBT systems; and
  • clarify the regulatory treatment of accessories and auxiliary features under the reclassified DBT framework.

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