Drug-Device Combo Firms Quiz FDA on Specs

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The Combination Products Coalition (CPC) says its members have recently experienced FDA requesting that combination product manufacturers demonstrate how they have “validated” device user interface specifications in the intended user population. A CPC statement says its member companies are not aware of any agency guidance or recognized consensus standards that describe the expectation to validate device user interface specifications. Also, it says, FDA requests for evidence of how specifications have been validated appear to be a new request for the premarket review of both combination products and traditional medical devices.

CPC says its members are concerned that:

  • FDA has not fully defined its expectations for how combination product manufacturers should demonstrate that specifications have been validated;
  • the requests appear to be new and not associated with any agency regulation, guidance, or policy statement;
  • the requests appear to be specific to CDER-led combination product reviews and not asked as part of traditional CDRH-led medical device premarket reviews;
  • the text of the requests received seems in some cases to imply that combination product manufacturers should use usability testing to validate specifications across the full user population capability range; and
  • the text of the requests received seems in some cases to ask that sponsors design devices to accommodate a subpopulation of the intended users instead of setting device specifications broadly to suit the entire intended user population.

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