Regulatory Q&A Forum
Ask questions, share knowledge, and get help from the regulatory community
How to prove substantial equivalence with multiple predicate devices?
When developing a 510(k) submission for a new device that combines features from multiple legally marketed devices—for instance, a novel guidewire that uses the core construction and intended use of P...
How do I justify using multiple predicate devices in a 510k submission?
When a new medical device integrates features from multiple sources, such as a patient monitor using the core physiological sensing technology of one predicate and the novel software and cybersecurity...
Beyond the basic definitions, how does the fundamental difference between FDA 'clearance' (via 510(k)) and 'approval' (via PMA) translate into distinct strategic and operational plans for a medical de...
What happens if my chosen 510k predicate device gets recalled?
When a medical device manufacturer discovers that their chosen predicate for a 510(k) submission has been recalled, what is the strategic framework for determining if the predicate can still be used t...
What to do if my 510k submission receives an RTA letter?
When a sponsor's 510(k) submission for a device, such as a new orthopedic implant or diagnostic software, receives a 'Refuse to Accept' (RTA) decision, what is a systematic and robust process for craf...
How to determine substantial equivalence with multiple predicate devices?
When a new medical device combines distinct technological features from multiple legally marketed predicates—for instance, an imaging catheter incorporating the sensor technology from Predicate A and ...
How to choose the best predicate device for a 510k submission?
When a manufacturer identifies multiple potential predicate devices for a 510(k) submission, what is a robust framework for selecting the optimal candidate, especially when no single predicate is a pe...
For a developer of a Software as a Medical Device (SaMD) or wearable technology intended to qualify under the FDA's General Wellness Policy, what constitutes a robust and defensible internal justifica...
For a manufacturer preparing to market a new Class I or simple Class II device in the U.S., how can the broad requirement of "General Controls" be translated into a practical, audit-ready documentatio...
What should I do if my 510k predicate device gets recalled by the FDA?
For a manufacturer of a 510(k)-cleared Class II device, what is a comprehensive, step-by-step framework for responding when their primary predicate device is recalled due to a significant safety or pe...
What are common mistakes to avoid when using the FDA's eSTAR 510k template?
Given that the FDA's eSTAR template is now mandatory for 510(k) submissions, what are the most common eSTAR-specific pitfalls that lead to a Refuse to Accept (RTA) decision, particularly for a Class I...
How to determine the necessary performance testing for a 510k?
When developing a 510(k) submission for a device with technological differences from its predicate—such as an infusion pump incorporating updated software and a new user interface—how can sponsors con...
How do I justify substantial equivalence with multiple predicate devices?
When pursuing a 510(k) using a 'split predicate' strategy, such as for an orthopedic screw combining a novel thread design from one predicate with a unique biocompatible coating from another, what is ...
For sponsors of Class I or low-risk Class II devices, navigating the FDA's General Controls for labeling can present subtle but significant compliance risks. Beyond simply listing the device name, wha...
For a medical device manufacturer, particularly one developing a novel technology like an AI-powered diagnostic software or a new type of wearable sensor, what is a systematic process for determining ...
For a small medical device company or startup, successfully navigating the Medical Device User Fee Amendments (MDUFA) Small Business Determination (SBD) process is often a critical financial step befo...
How do you respond to an FDA Additional Information (AI) request for a 510k?
When a sponsor receives an Additional Information (AI) request for a 510(k) submission, such as for a Class II diagnostic imaging software, what is a comprehensive framework for developing a strategic...
What cybersecurity documentation does FDA require for a 510k submission?
When preparing a 510(k) for a 'cyber device,' such as a Software as a Medical Device (SaMD) or a network-connected monitor, how can sponsors construct a cybersecurity documentation package that provid...
What is the average review time for a 510k after an AI request?
After a sponsor submits a comprehensive response to an FDA Additional Information (AI) request for a 510(k), the review clock restarts. While this is a standard part of the process, it creates signifi...
How to properly document substantial equivalence to multiple predicate devices?
When a medical device sponsor develops a novel product by combining key features from two or more legally marketed devices—such as integrating a specific sensor technology from one cleared device with...