Covid PMA or HDE Supplement Guidance

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FDA has issued an immediately-in-effect guidance, Supplements for Approved Premarket Approval (PMA) or Humanitarian Device Exemption (HDE) Submissions During the Coronavirus Disease 2019 (Covid-19) Public Health Emergency, to provide a policy to help address current manufacturing limitations or supply chain issues due to disruptions caused by the Covid-19 public health emergency. The document applies to limited modifications affecting the safety or effectiveness of a device approved through the PMA programs that would trigger the requirement that a manufacturer submit a PMA supplement or 30-day notice to FDA under the regulations.

The policy also applies to limited modifications affecting the safety or probable benefit of a device approved through the HDE program that would trigger the requirement that a manufacturer submit an HDE supplement or 30-day notice to FDA.

The guidance says examples of such modifications may include, but not be limited to: 

  •          design and manufacturing changes to address component unavailability due to supply chain disruptions;
  •          manufacturing changes to allow the establishment to maintain operations and accommodate social distancing practices;
  •          changes in manufacturing facility or establishment; and
  •          changes to packaging procedures.

The policy does not apply to design or manufacturing changes made for reasons other than addressing manufacturing limitations or supply chain issues resulting from the Covid-19 emergency or any proposed changes described in a regulatory submission already received by FDA.

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