Predetermined Change Control Plan Principles

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FDA, Health Canada, and the UK’s Medicines and Healthcare Products Regulatory Agency have published five guiding principles for predetermined change control plans (PCCPs) for machine learning-enabled medical devices (MLMDs). An FDA post says the principles “draw upon the overarching good machine learning practice guiding principles the three agencies adopted in 2021.

The document says there is international medical device community discussion about the use of PCCPs as a way of managing certain device changes where regulatory authorization before marketing is typically required. It says PCCPs can be used to help:

  • align regulatory procedures with the rapid and ongoing approach to change management in MLMDs;
  • manage risks in a timely and ongoing fashion through monitoring, maintenance, and/or improving device performance; and
  • uphold high regulatory standards to ensure device safety and effectiveness.

For this joint document, it says, a PCCP describes a plan proposed by a medical device manufacturer that specifies:

  • certain planned modifications to a device;
  • the protocol for implementing and controlling these modifications; and
  • the assessment of impact from modifications.

The guiding principles are:

  • focused or bounded, by limiting proposed changes to modifications within the intended use or intended purpose of the original MLMD;
  • a risk-based approach that adheres to risk management principles;
  • evidence-based;
  • transparent, so that stakeholders stay aware of a device’s performance and use before and after changes are implemented; and
  • total product lifecycle perspective.

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