MITA Concerns With FDA Remanufacturing Guidance
The Medical Imaging & Technology Alliance (MITA) says it is concerned that an FDA draft guidance on remanufacturing of medical devices will not achieve its intended outcome given that the agency is relying on third-party servicers and independent service organizations (ISOs) to comply with the guidance. A MITA 9/22 comment letter says the third-party servicers and ISOs:
- are not regulated by FDA;
- do not seek or follow FDA policy, regulations, or guidance;
- conduct activities regarding medical devices that are unregistered and thus unknown to FDA;
- do not have established quality management processes and documented procedures; and
- do not report device malfunctions resulting from their servicing activities.
“Until FDA removes its enforcement discretion, requires all third-party servicers and ISOs to comply with registration, regulatory quality and safety requirements, and proactively exercises appropriate oversight (i.e., inspections) and enforcement policies, the current servicing activities constituting unregulated remanufacturing of medical devices will continue,” MITA declares.
The association says it supports expedient finalization and enforcement of the guidance and provides comments relating to regulatory requirements for remanufacturing, risk assessment, activities that likely constitute remanufacturing, considerations for labeling, and implementation and enforcement. The letter also includes line-by-line technical comments.