AdvaMed Wants Early Engagement on Device Safety Notices
The Advanced Medical Technology (AdvaMed) Association has reiterated to FDA that early stakeholder engagement is critically important when the agency is considering medical device safety communications about currently marketed devices. In comments submitted to the agency regarding an 11/17/2020 public meeting on “Communications About the Safety of Medical Devices,” AdvaMed said early engagement with relevant manufacturers and healthcare providers “helps to ensure that the communication reflects accurate – and where appropriate, actionable – information from the outset.”
The device lobbying organization contends that “emerging signal communications issued prior to the agency having adequate, fully analyzed, validated and confirmed evidence, and without appropriate instructive recommendations, will create unnecessary confusion for healthcare providers and patients and could have unintended consequences including an adverse impact on public health and long-lasting reputational damage to valuable devices.”
AdvaMed also took issue with FDA’s position that it may not be efficient for the agency to engage with each of the impacted manufacturers in instances involving a large device class safety signal. “However, even in these instances, we strongly encourage FDA to offer the opportunity for dialog with, and collective input across, the relevant manufacturers, which can be facilitated by industry trade associations and other FDA partners,” the group says. “FDA’s leadership in engaging cross-industry discussion can help facilitate more rapid understanding of the issue and alignment of consistent messaging, and where applicable, identification of any differences within the class that should be noted for purposes of patient management.”
Additionally, AdvaMed says it supports standardizing the safety communication process, including clear identification and distinction of different types of communications. For example, if the communication involves a recall, then the communication should be grouped with other device recall communications on FDA’s Web site and separated from traditional safety communications or letters to healthcare providers to avoid confusion. “We also encourage the use of a template format for each type of communication to facilitate ease and consistency of use and comprehension,” the group says.