AdvaMed Seeks Examples of Low-risk Manufacturing Site Changes
Advanced Medical Technology Association (AdvaMed) says FDA needs to provide more input on device manufacturing site change submissions. In just-posted comments on an FDA draft guidance on “Manufacturing Site Change Supplements: Content and Submission,” the group says more details are needed on the types of manufacturing site changes that would not affect the safety and effectiveness of the device because these could be reported to the agency in PMA periodic report or 30-Day Notice filings.
AdvaMed says that the guidance notes that a PMA supplement must be submitted for review and approval before making a change that affects the device’s safety or effectiveness, unless such change is a modification in a manufacturing procedure or method of manufacture, which would be eligible for a 30-day notice. However, it says, no specific guidance is given for manufacturing site changes that may be implemented without a PMA supplement. “Provide some examples of possible cases that might not affect safety and effectiveness,” AdvaMed says. “For example, contract manufacturing site changes for low-risk accessories approved under a PMA may not affect the safety or effectiveness of a device.”