Submitted by kBLASTER Team on
by M. Elizabeth Bierman and Michele L. Buenafe for Morgan Lewis
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:
--"In the new guidance, FDA encourages manufacturers to identify a single predicate device to demonstrate substantial equivalence"
--"Although the guidance does not state explicitly that split predicates will not be accepted, the clear implication is that using split predicates will not lead to a finding of substantial equivalence."
--..."the guidance recommends that there be a “primary predicate,” with indications for use and technological characteristics that are most similar to the device that is the subject of the 510(k)."
