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Slide 1 Rob Packard, President www.MedicalDeviceAcademy.com [email protected] How to Prepare a Medical Device 510(k) Submission for the FDA October 25 @ Noon EDT

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Page 1: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 1

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

How to Prepare a Medical Device 510(k) Submission for the FDA

October 25 @ Noon EDT

Page 2: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 2

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

510(k) Coursehttps://medicaldeviceacademy.com/510k-course/

Page 3: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 3

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

How Long ?

BeginDHF

510(k)Clearance

Design Transfer

Pilot Phase Release Phase

HazardIdentification

Risk ControlOption Analysis

Risk Evaluation

RiskEstimation

Risk Control Effectiveness Verification

Risk Management

Plan

RequestPre-SubMeeting

Pre-SubMeeting

Begin510(k)

Submit510(k)

Development PhaseFeasibility PhaseConcept Phase

90+ Days100 Days60-75 Days

RiskManagement

Review

Benefit/RiskAnalysis

Evaluation of Overall Residual Risk

https://medicaldeviceacademy.com/risk-management-training-webinar/

Page 4: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 4

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

How Much $

• 510(k) Pre-sub – No FDA user fee• 510(k) Submission:

– $10,953 is standard user fee (FY 2019)– $2,738 is small business fee (FY 2019), but prior qualification is required

• Regulatory Consulting Fees:– $2,181 is pre-sub consulting fee– $10,911 is 510(k) consulting fee ($12,000 for both)

• Biocompatibility Testing = $13,000 min.• Electrical Safety & EMC Testing = $50,000 min.• Benchtop Testing ? – Product Specific• Animal Testing - $100K+• Clinical Study - $1 million+

Page 5: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 5

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

510(k) Process

Page 6: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 6

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Product Classification

1. Identify a device similar to yours

2. Use the registration and listing database

https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfRL/rl.cfm

3. Identify the 3-letter product code

4. Click on the code to go to the product

classification page

http://medicaldeviceacademy.com/fda-device-classification/

Page 7: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 7

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Find Classification Other Wayshttps://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpcd/classification.cfm

Page 8: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 8

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Substantial Equivalencehttps://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/Guidanc

eDocuments/UCM284443.pdf

Page 9: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 9

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Use ToC as Planning Tool

• red = the information does not appear to be available

• yellow = document requires revision and/or reformatting of content

• blue = ready for the client’s review and approval

• green = ready for submission

• Add a column to assign team responsibilities

• Prioritize task completion

Page 10: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 10

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

ToC Examplehttps://medicaldeviceacademy.com/510k-project-management-lessons-learned/

Page 11: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 11

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Planning Performance Testing

• Look for a special controls guidance document 1st.

• Look for any device-specific standards (e.g., ASTM F483)

• Review each of the possible 510(k) Summaries carefully

• Order 510(k) submissions through FOI

https://medicaldeviceacademy.com/design-controls-training-webinar/

Page 12: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 12

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

FDA Pre-Sub Meetings

• Guidance released September 29, 2017

• Consultants and RA Experts have used these for years, but weren’t called “pre-sub” meetings

• Do your homework 1st

• In-person vs. Tcon

• Timing = Prior to Performance Testing

• Identify Proposed Predicate Device(s)

https://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/UCM311176.pdf

Page 13: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 13

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Changes to RTA process

• Guidance released January 30, 2018

• Longer checklist

• Can be rejected multiple times

https://www.fda.gov/ucm/groups/fdagov-public/@fdagov-meddev-gen/documents/document/ucm315014.pdf

Page 14: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 14

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Human Factors Guidance

• Guidance released February 3, 2016• Min. 15 users per user group• Users must be representative of US population• Seldom able to use Usability Report from European

Technical Files “as is”• Must perform risk analysis to determine risks that

will be evaluated in the human factors study• Almost always required for OTC products• Not commonly required for orthopedic surgical

implants unless technique or design is unique

https://www.fda.gov/downloads/medicaldevices/.../ucm259760.pdf

Page 15: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 15

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

eCopy Hold

If you are using Windows 10, and you save your eCopy or eSubmitter zip folder on a flash drive, Windows 10 will automatically create a hidden system folder titled:

“System Information Volume”

https://medicaldeviceacademy.com/ecopy-hidden-system-files/

Page 16: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 16

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Changes to eCopy process

• Unofficial change in February 2018…only printed copy cover letter with electronic copy

• Different from eSubmitter

https://medicaldeviceacademy.com/fda-ecopy-webinar/

Page 17: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 17

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

software status

• eSubmitter Options:

– Template Ver. 1.3 (IVD)

– Template Ver. 1.2.1

– Template Ver. 3.2, Quik 510(k) Pilot

https://www.fda.gov/forindustry/fdaesubmitter/default.htm

Page 18: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 18

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Quik 510(k) Pilot

1. Refusal To Accept (RTA) Process is eliminated2. Review is interactive3. 60-Day Review “Clock”

https://medicaldeviceacademy.com/quik-510k-pilot/

Page 19: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 19

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Small Business Qualification Changes

• Form was split from guidance

• Can apply as early as August 1

https://medicaldeviceacademy.com/small-business-qualification-fee-webinar/

Page 20: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 20

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Interoperability Guidance

• Guidance released September 6, 2017

https://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/UCM482649.pdf

Page 21: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 21

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Device Modification Guidances

• https://www.fda.gov/downloads/medicaldevices/deviceregulationandguidance/guidancedocuments/ucm514771.pdf - Changes to devices

• https://www.fda.gov/downloads/medicaldevices/deviceregulationandguidance/guidancedocuments/ucm514737.pdf - Changes to software

Page 22: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 22

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Impact of De Novo Fee Changes

MDUFMA IV = De Novo is no longer free, but the FDA’s target completion date for making a decision on your De Novo application is 150 days.

• $96,644 is standard user fee (FY 2019)

• $24,161 is small business fee (FY 2019), but prior qualification is required

Page 23: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 23

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Software Requirements

• Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices –Guidance for Industry and FDA Staff, May 2005

• General Principles of Software Validation; Final Guidance for Industry and FDA Staff, January 2002

• Guidance for Off-The-Shelf Software Use in Medical Devices

• IEC 62304 Edition 1.1 2015-06 Medical device software – Software life cycle processes

Page 24: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 24

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Software Standards

Page 25: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 25

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Software Documentation

Page 26: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 26

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Cybersecurity Policies

• Content of Premarket Submissions for Management of Cybersecurity in Medical Devices - October 2, 2014

• Postmarket Management of Cybersecurity in Medical Devices - December 28, 2016

• Cybersecurity for Networked Medical Devices Containing Offthe-Shelf (OTS) Software - January 14, 2005

Page 27: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 27

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

UDI Example

Page 28: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 28

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

UDI & GUDID

• UDI = Unique Device Identifier

• GUDID = Global Unique Device Identifier Database

• All questions specific to the UDI or GUDID should be directed to the UDI Help Desk

• Next Deadline is September 24, 2018– Physically on devices that are Class II

– Labeling for Class I

– Labeling for Unclassified Devices

Page 29: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 29

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

FDA Biocompatibility Guidance

• Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process“ – released June 16, 2016

• http://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm348890.pdf

Page 30: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 30

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

RTA Checklist

• Section G – Biocompatibility– Submission must state one of the following…

• Direct or indirect patient contacting parts

• Contact information not needed…why? (e.g. software)

– Submission includes a list of all patient contacting parts and associated materials including coatings and colorants

– Type and duration of contact is specified

– Biocompatibility Assessment• Test protocol with description of test article, methods, pass/fail

criteria and results for each test

• Or Statement that testing is not required with a rationale

Page 31: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 31

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

New ISO 10993-1:2018

Only 1 Required Input:

• “physical and/or chemical information”

Expansion of Endpoints to be Considered:

• “material mediated pyrogenicity”

• “chronic toxicity”

• “carcinogenicity”

• “reproductive/developmental toxicity”

• “degradation”

Page 32: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 32

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

New Definitions

21 New Definitions:

• “3.9 geometry device configuration”

• “3.15 nanomaterial”

• “3.16 non-contacting”

• “3.17 physical and chemical information”

• “3.25 toxicological threshold”

• “3.26 transitory contact”

Page 33: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 33

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Q & A

If you would like to schedule a call with me, please use the following link:

https://calendly.com/13485cert/30min

Page 34: How to Prepare a Medical Device 510(k) Submission for the FDA...for Software Contained in Medical Devices – Guidance for Industry and FDA Staff, May 2005 •General Principles of

Slide 34

Rob Packard, President

www.MedicalDeviceAcademy.com

[email protected]

Rob Packard

[email protected]

+1.802.281.4381

rob13485

Contact Info