How to Prepare a Medical Device 510k Submission for FDA | Rob Packard | Joe Hage

MedicalDevicesGroup.net/Webin... for the slides.
The Medical Devices Group presents Medical Device Academy founder Robert Packard. In an hour-and-a-half workshop, Rob covered Changes to RTA process, Human Factors Guidance, Changes to eCopy process, Small Business Qualification Changes, Interoperability Guidance, eSubmitter software status, Device Modification Guidances, Quik 510(k) Pilot, Impact of De Novo & Fee Changes, Cybersecurity Policies, UDI Requirements, New ISO 10993-1:2018 Standard.

[@imcintertech2066]

Great video!

[@oughts5638]

Very informative.Thanks for sharing.

[@davidshaw257]

Great Video, very informative.

[@Baja383]

Thanks for the information!

[@SS-mw3bi]

It is a great source. Thanks for the contribution.
Any information about Class 1 medical device registration and listing? I have some soft orthopedic goods in 10 groups and need to list them with FDA.

[@ms2pranav]

Thank you dear knowledge sharers💐💐👌👌👌👌👌👌

[@williamhui6195]

We found our N95 respirator can be registered as FDA product code MSH in FDA database with no 510(k) is needed. Once we got the establishment number issued by FDA, we can only use FDA registered for our N95 respirator. However, why we cannot declare our N95 respirators as FDA cleared? How should we do if we want to be FDA cleared eventually?

[@johncataldi1580]

That was absolutely outstanding

[@MedicalMarcom]

Yes. Rob is.

[@anniepena485]

Do 510k forms always need an Apostille when being sent abroad?

[@casade2831]

Hello Joe! For a 510k, must you do biocompatibility tests on the primary material used in your device; material that has already been approved by the FDA on other predicates?
Is the ASTM certification of your material not enough? Take PEEK or UHMWPE as an example.

[@MedicalDeviceAcademy]

The FDA guidance for biocompatibility covers this topic in detail: www.fda.gov/media/85865/download. Material certifications are never enough by themselves, because you need to consider the impact of all the manufacturing processes on the finished device. The reason for this is that there may be residuals or contaminants from the manufacturing process that could negatively affect biocompatibility. For example, if you are currently making a molded part at one facility, you need to do additional biocompatibility testing if you change to a different molding facility. If you can show that there are no new residuals or contaminants from the new molding process, then you might be able to provide a biocompatibility risk assessment with limited testing data. Differences in raw materials are important, because plastics will include plasticizers and additives that may not be obvious but the same is true for metals that have different cleaning and passivation processes. Unless you have a raw material specification that a competitor used AND you know exactly what the manufacturing process was, your justification for not doing testing will not be adequate.

[@casade2831]

@@MedicalDeviceAcademy What you say makes perfect sense. Thank you for taking the time to respond.

[@johngarlandwood3487]

Do you have any content specifically about the pre-submission process?

[@MedicalMarcom]

John, visit Rob's site at MedicalDeviceAcademy.com for lots more good stuff!

[@casade2831]

Hi Joe,
Thank you for everything you do. Quick question.
Do patient-specif class II devices require 510K clearance when they aren't sold in batches or lots?
I am aware of hospitals and universities that make their own implantables such as bone replacement with PEEK (which is FDA approved). I know they don't have 510K clearances on these single products.
Of course, hospitals and universities make these under specialized conditions and I am sure they know what they are doing, but I was wondering if anything that is considered a permanent implantable class II needs to be 510K cleared or only production devices?
Thank you

[@MedicalDeviceAcademy]

For PEEK, the material is not FDA approved. The FDA doesn't approve materials. In fact, they also don't refer to the 510(k) as approval. Technical a 510(k) is pre-market notification, and a PMA is pre-market approval. PMAs are required for high-risk implants, and 510(k) submissions are required for moderate risk devices with similar "predicate" devices that are already on the market.
In this case, you have described, a 510(k) is required for patient-matched implants. You generally do your validation using a worst-case example of the smallest or largest possible implant (e.g. 120% of someone my size - 2 meters tall and 135 kg). Hospitals that are making implants are typically doing this as part of research. The only big difference between the production of a patient-matched implant and batches of implants, is the lot size is 1 instead of many and the labeling includes a patient ID #. Both batches and patient-matched implants can have serial numbers, but only a patient-matched implant will have a patient ID # on the label. I have also seen a few companies make a spare implant for patient-matched implants, because if the original is dropped they need a spare

[@casade2831]

@@MedicalDeviceAcademy Thank you. My husband emailed Rob Packard, and he got a very similar answer.
Is this Rob?

[@MedicalDeviceAcademy]

@@casade2831 Yes, one and the same...but this post posted on Joe's TH-cam channel where we are both commenting.

[@jamescaffrey7869]

can you share that dropbox folder?

[@davidallen8611]

This host is so boring 😂