Comments on Physiologic Closed-Loop Guidance
Medtronic says it appreciates FDA efforts to establish appropriate considerations for premarket submissions for medical devices with physiologic closed-loop control technology. Commenting on the agency’s 12/23/21 draft guidance on the topic, the company says it also appreciates the agency’s recognition of the value of computational models as an alternative or to supplement bench, animal, and/or clinical studies.
The company further says it appreciates that the draft uses already developed standards and says the relevant requirements applicable to physiologic closed-loop controlled devices should be aligned as closely as possible with IEC 60601-1-10. “Medtronic is concerned that deviation from the IEC standard will add unnecessary burden beyond what is required by IEC 60601-1-10 and cause inconsistency with the standard without improving patient safety or device effectiveness,” the comment says.
The BD comment letter gives specific line-by-line comments, including a statement that while the draft provides a good initial list of devices that are applicable, it could be improved with additional examples that also are relevant to the proposal.
Line-by-line technical comments also came from Tandem Diabetes Care.