Hi friends!!!
In our previous blogs, we have discussed about the following topics.
US FDA Premarket Notification 510(k)
EU MDR Timeline, Annex, Chapter
EU MDR Post Market Surveillance
EU MDR Technical Documentation - Part 1
EU MDR Technical Documentation - Part 2
EU MDR General Safety and Performance Requirement
EU MDR Information on the Label
EU MDR Post Market Clinical Follow Up
EU MDR Unique Device Identification - Part 1
EU MDR Unique Device Identification - Part 2
EU MDR Chapter & Articles - Part 1
EU MDR Chapter & Articles - Part 2
EU MDR Procedure for Custom-Made Devices
EU MDR Certificates Issued by Notified Body
In today's blog, we will explore about Premarket Approval & its requirements. Whether you're a startup or established manufacturer, understanding the Premarket Approval is vital for ensuring regulatory compliance and bringing your product to the market
It is also important for Medical Device QA/RA Professionals to know in detail about Premarket Approval.
Let's get into the topic.
Premarket Approval (PMA)
High
risk category medical devices (Class III) are subjected to Premarket Approval
requirements.
Medical
Devices which possess following functions can be considered as high-risk
category medical devices but are not limited to the following:
Support
or sustain human life, substantial importance in preventing impairment of human
health, potential for unreasonable risk of illness or injury
Also,
medical devices which cannot assure safety and effectiveness solely based on
general and special controls shall be subjected to PMA requirements.
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Contents of Premarket Approval
Name
and address of applicant
Table
of contents
Indications
for use
Description
of device and functional components or ingredients
Reference
to performance standards
Environmental
assessment
Manufacturing
(methods, facilities and controls used in manufacturing process)
Bibliography
of published reports
Sample
of device, if practical
Proposed
labeling
Financial
certification or disclosure
Information
concerning uses in pediatric patients
Pre-clinical
studies: Test reports, summaries and conclusions of all pre-clinical studies
shall be submitted. (The pre-clinical
studies shall include but not limited to Bench and animal testing, Biocompatibility,
Software, Engineering, Electromagnetic Compatibility (EMC), Electromagnetic
Interference (EMI))
Clinical studies: Any information related to clinical studies conducted within and outside United States which supports safety and effectiveness, benefit-risk determination shall be submitted. The clinical study data shall include all methods, results, conclusions that are reasonably obtainable by the submitter which can be either adverse or supportive
Post Approval Controls
PMA regulatory controls for post approval includes the following:
Post approval studies and reports:
To ensure continued safety and effectiveness of
the device (Eg: Long time performance data). The Post Approval Study reports
need to be submitted as prescribed by FDA at a regular interval to ensure
compliance.
Supplements:
Changes which affects the safety and effectiveness of PMA approved devices
shall be informed to FDA in the form of Post Approval Supplement prior to
implementing the change.
Amendments:
Changes which are time sensitive and do not affect the safety and effectiveness
of PMA approved medical device shall be reported to FDA in the form of Post
Approval Amendment. (Eg: Change in contact information, etc.,)
30-day
notice of manufacturing changes.
Post approval periodical reporting (Annual Reports):
The PMA Annual reports shall be
submitted to FDA annually. The PMA annual reports shall include the following
information but are not limited to:
Information
about the changes submitted as supplements along with any other changes which
are not submitted previously.
Information
about the sales of the device.
The
summary and bibliography of published and unpublished reports.
PMA Review Process
The
PMA review process will take approximately 180 days and is a four-step review
process, it includes the following:
Acceptance
and filling review:
The
FDA checks the completeness of the PMA application against to pre-determined
checklist. It checks the adequacy of the application to proceed with further
in-depth reviews. If the PMA application is adequate, within 45 days from
receiving the application, the FDA will notify the applicant with the
information about the filling of PMA application in a letter along with PMA
reference number and the date when FDA filled the application. The 180 days
review process starts from the date of filling the application.
Substantive
review:
In Substantive review, the in-depth review of the PMA application happens. The FDA may notify the applicant of any deficiencies or information needed via a letter. The applicant shall discuss the review status of the application with the FDA by submitting a request to meet with FDA within 100 days of filling the PMA application.
Panel
review:
The
FDA may prefer outside panel of experts to review the PMA application. Generally,
FDA may go for external review for first of its kind device PMA applications
FDA Final decision
The
FDA shall issue the final notification to the applicant to approve or reject
the PMA application.
Now I hope you have acquired some basic knowledge about the requirements of US FDA Premarket Approval. We will meet again with another valuable topic related to MedTech Quality & Regulatory, Biomedical Engineering, Medical Device, Healthcare.
NOTE: Dear friends!!!... Please do comment a topic related to Biomedical, so that we can discuss it in future blogs.
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