August 2014

Medtech insiders respond to FDA's 510(k) split-predicate ban

by Arezu Sarvestani for Mass Device

Commentary on FDA's final guidance titled The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notification [510(k)] which states a single primary predicate is needed for a 510(k) submission, as well as no longer allowing "split predicate" 510(k) submissions. Excerpts from this commentary stated the following:

...The "split predicate"...

FDA Issues Guidance on 'Substantial Equivalence' Process Used to Bring Devices to Market

by Alex Gaffney, RAC, for RAPS Regulatory News Focus

Commentary on FDA's final guidance titled The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notification [510(k)]. Excerpts from this commentary stated the following:

...companies would rely on "a single predicate" for a finding of substantial equivalence (or SE), FDA said. The rest would simply bolster an application's...

FDA issues "How to find and effectively use Predicate Devices" which states primary predicate is a must

An update was posted by the FDA on "How to find and effectively use Predicate Devices". This update stated that "Manufacturers must identify a primary predicate device which is most similar to the device under review with respect to indications for use and technological characteristics" and that "the use of split predicates is inconsistent with the 510(k) regulatory standard"....

FInal Guidance for Industry and Food and Drug Administration Staff - The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)]

Final guidance was published by FDA on July 28, 2014 titled The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notification [510(k)]. This guidance recommends the identification of a single primary predicate in all 510(k) submissions and has ruled that the use of "split predicates as inconsistent with the 510(k) regulatory standard". Multiple predicates are still allowed, but each predicate used must have identical...