Use of Voluntary Consensus Standards Guidance Explained

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A 10/25 CDRH Webinar explained a recent guidance on appropriate use of voluntary consensus standards in premarket submissions for medical devices. During the program, CDRH director of the standards and conformity assessment program Scott Colburn reviewed the evolution of the guidance from its 2014 draft to changes that were incorporated in the final version issued 9/14.

“The take-home messages from stakeholders who commented on the draft guidance were for the agency to follow least burdensome principles when requesting test reports; provide consistency across the Center with regards to data requests, test summaries, or complete test reports; and to provide increased transparency about how standards are applied across review offices and divisions,” Colburn said.

He said the final guidance incorporated the 21st Century Cures Act and clarified that deviations may be made to a standard but not within the context of a Declaration of Conformity. FDA also clarified its position on promissory statements in that if a company chooses to rely on a recognized standard or guidance for any part of a device, design, or testing, it may include either a Declaration of Conformity or a statement that testing will be conducted and meets specified acceptance criteria before the device is marketed.

“Because the Declaration of Conformity is based on results from testing,” Colburn said, “we believe you cannot properly submit a Declaration of Conformity until you have completed the testing the standard describes.”

The agency adopted ISO/IEC 17050-1 and -2 that clarifies the content of a Declaration of Conformity and the accompanied supporting documentation that underpins the extent of the conformity and how it was assessed, Colburn explained. Form 3654 was eliminated because its elements are addressed by the Declaration of Conformity.

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