Regulatory Q&A Forum
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When a medical device manufacturer receives an FDA Form 483 with observations citing systemic deficiencies, such as an inadequate CAPA process or insufficient process validation, what are the key stra...
For a manufacturer of a Class I medical device, such as a manual surgical instrument or a basic health data application, that is exempt from 510(k) premarket notification, what constitutes a comprehen...
How to properly format a substantial equivalence comparison table?
When preparing a 510(k) submission for a medical device that has technological differences compared to its predicate—such as a patient monitoring system with a novel sensor material or a significantly...
What are the most common reasons for a 510k Refuse to Accept (RTA) letter?
Beyond common administrative oversights like incorrect user fees or missing organizational forms, what are the critical, yet often overlooked, content-related deficiencies that cause a 510(k) submissi...
How do I respond to an FDA 510k Additional Information request letter?
For a medical device sponsor navigating an FDA Additional Information (AI) request during a 510(k) review, what constitutes a best-practice framework for developing a response that is not only complet...
How to justify substantial equivalence with multiple predicate devices?
When preparing a 510(k) submission for a device that combines features from multiple legally marketed products—such as an orthopedic implant using a well-established core design from Predicate A but i...
For a manufacturer of a Class I medical device exempt from 510(k) premarket notification, what is a comprehensive and practical framework for implementing FDA’s General Controls? Moving beyond a simpl...
For manufacturers of Class I medical devices that are exempt from 510(k) premarket notification, such as non-sterile tongue depressors or elastic bandages, what are the specific, non-negotiable requir...
What is the total cost of a 510k submission including consultant fees?
For a medical device company planning a 510(k) submission for a Class II device, such as a new surgical instrument, what is a comprehensive framework for budgeting beyond the standard FDA user fee, wh...
What are common eSTAR rejection reasons for a 510k submission?
With the mandatory transition to the eSTAR format for 510(k) submissions, avoiding a Refuse-to-Accept (RTA) decision has become a critical first hurdle. While the template provides structure, it also ...
How do FDA hold days affect the 510k review clock?
While the FDA’s goal for a traditional 510(k) review is 90 calendar days, this timeline represents "FDA Days" and can be paused. A common event that disrupts this clock is the issuance of an Additiona...
What is the response time for an FDA 510k Additional Information request?
When a 510(k) submission is placed on hold due to an FDA Additional Information (AI) request, sponsors face a critical 180-day window to submit a complete response before the submission is considered ...
For manufacturers of Class I or 510(k)-exempt Class II devices, such as a basic wellness app or an elastic bandage, adhering to FDA's General Control labeling requirements under 21 CFR Part 801 is a f...
What should I do if my 510k predicate device is recalled?
When a manufacturer of a 510(k)-cleared device, such as an infusion pump or a diagnostic software tool, discovers that its primary predicate device has been recalled for a significant safety or perfor...
What are the most common reasons for an FDA Refuse to Accept letter?
Beyond obvious administrative omissions like missing user fee forms, what are the more nuanced reasons a 510(k) submission for a Class II device, such as a cardiovascular catheter, might receive a Ref...
How to determine substantial equivalence if my predicate device is old?
When a medical device manufacturer is preparing a 510(k) submission for a modern device—for instance, a digital diagnostic tool using novel software algorithms—how can they systematically establish su...
For manufacturers of Class I medical devices exempt from premarket notification (510(k)), what is a comprehensive framework for ensuring full compliance with FDA's General Controls before and after pl...
For a small medical device company aiming to leverage the FDA's Small Business Determination (SBD) program to reduce MDUFA user fees, what are the critical operational and documentation considerations...
What performance testing is required for a Class II 510k device?
When developing a performance testing strategy for a new Class II device intended for a 510(k) submission, such as a diagnostic immunoassay or an electronic infusion pump, what is a systematic process...
What are the most common reasons for an FDA RTA hold?
When preparing a 510(k) submission, what are the most critical, yet often overlooked, documentation details that lead to a Refuse to Accept (RTA) hold, moving beyond simple omissions like missing form...