FDA Proposes Special 510(k) Update, Clarification

Share

FDA has issued a draft guidance, The Special 510(k) Program, that would update the Special 510(k) program to clarify existing policy and expand on the types of changes eligible for the program to improve the efficiency of 510(k) review. The agency says the update includes certain changes to the indications for use and clarifies the types of technological changes that are appropriate to be reviewed as Special 510(k)s. Comments on the draft guidance will be received by the agency until 11/27.

The document says its intent “is to describe an optional pathway for certain well-defined device modifications where a manufacturer modifies its own legally marketed device, and rigorous design control procedures produce highly reliable results that can form, in addition to other 510(k) content requirements, the basis for substantial evidence. These well-defined modifications may include certain changes to indications for use that are not currently within the scope of the Special 510(k) program. The draft guidance also clarifies the types of technological changes eligible to be reviewed as Special 510(k)s. Specifically, we are proposing to evaluate whether design and labeling changes can be reviewed under a Special 510(k) by focusing on whether the method(s) to evaluate the change(s) are well-established, and whether the results can be sufficiently reviewed in a summary or risk analysis format.”

Specifically, the agency proposes that a design or labeling change to an existing device (including certain changes to indications for use) may be reviewed under a Special 510(k) when: 

  •          the proposed change is made and submitted by the manufacturer authorized to market the existing device;
  •          performance data are unnecessary, or if performance data are necessary, well-established methods are available to evaluate the change; and
  •          all performance data necessary to support substantial equivalence can be reviewed in a summary or risk analysis format.

 

 

Read more