Changes Sought in Device Animal Study Guidance
Cook Group says that while an FDA draft guidance on general considerations for animal studies for medical devices is generally well written and reasonable in terms of the types of controls and level of detail that need to be specified in studies to develop valid scientific data, there are cases in which it is unnecessarily restrictive or overly burdensome. There also are cases, it says, when it is not clear what the document is proposing.
AdvaMed’s comment letter says it is important to note that the guidance’s stated scope is not consistent with statements in its introduction and various other parts and confuses a reader. The association says that in its Scope section, the guidance says it applies to in vivo laboratory studies, which are defined as safety studies submitted in support of a regulatory submission. However, it says, other parts of the document refer to supporting the safety and performance of a medical device, including performance and handling, and evaluating a device’s efficacy or demonstrating proof of principle. “A clear definition of the scope of the guidance will avoid confusion and misunderstanding,” AdvaMed says. “It might be helpful to expand on what FDA considers to be ‘safety,’ how it is defined, how it can be determined, and what influences it.” AdvaMed also requests clarifications and revisions through many line-by-line comments.
Johnson & Johnson associates itself with AdvaMed’s comments and identifies several key issues for additional focus.