Stakeholders Want More Device Accessories Reclassified

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Three medical device stakeholder groups have asked FDA to consider additional medical device accessories for reclassification into Class 1. AdvaMed said in a comment letter that it agrees with the down-classification of the devices and associated product codes listed in an FDA notice requesting comment, and believes there are additional devices currently on the market that should also be down-classified. Consistent with the intent of the FDA Reauthorization Act of 2017, the trade association writes, “we believe accessories currently on the market that fall within the product codes in the attached document should be administratively down-classified to Class 1 through this notice.”

In its letter, Cook Group suggests several additions to the FDA list along with a statement of the rationale that supports safety and effectiveness of those devices under the general control provision of the Federal Food, Drug, and Cosmetic Act.

Finally, the Orthopedic Surgical Manufacturers Association is asking the agency to revert to its previous longstanding practice and treat all manual surgical instruments provided with Class 2 or Class 3 orthopedic implant systems as Class 1 devices in accordance with their current classification designation. Alternatively, the association says, FDA should publish new classifications and associated product code descriptions for those instruments that the agency believes carry a higher risk and should be in Class 2 or 3.

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