AdvaMed Says 3-D Guidance is ‘Confusing’

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The Advanced Medical Technology Association (AdvaMed) says FDA’s draft guidance on “Technical Considerations for Additive Manufactured (AM or 3-D Printed) Devices” is confusing regarding recommendations on patient-matched devices (patient-specific, personalized or customized). In just-posted comments to the agency, AdvaMed says that to “mitigate this confusion, there is significant benefit to creating a separate, companion guidance for patient-matched devices that addresses not only AM, but also other manufacturing technologies. If patient-matched devices are maintained solely in this guidance, and patient-matched recommendations versus conventional-device considerations are not clearly delineated, then the requirements for patient-matched devices will remain an ongoing source of confusion for both the agency and industry... While we acknowledge that additive manufacturing will drive a surge in patient-matched products, current manufacturing technologies (for example: computer-controlled milling machines) that create affordable, high-quality, patient-matched products are in use today. In this regard, additive manufacturing becomes another technology to manufacture medical devices.”

AdvaMed says that the draft guidance also needs FDA’s current thinking on issues such as data-handling aspects of patient-specific information, privacy, use of patient data for optimization purposes, and informed consent that are not unique to additive manufacturing alone. “Guidance on patient-matched products would certainly qualify as a ‘leap-frog’ guidance, allowing the agency to express current thinking on these critical topics.”

 

 

 

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