regulation of medical devices
- 1. R E G U L AT I O N O F M E D I C A L D E V I C E S K E E R T H A N A N M P H A R M P H A R M A C E U T I C S T J O H N C O L L E G E O F P H A R M A C Y
- 3. I N T R O D U C T I O N Medical device regulation is complex, in part because of the wide variety of items that are categorized as medical devices. They may be simple tools used during medical examinations, such as tongue depressors and thermometers, or high-tech life-saving devices that are implanted in the patient, like pacemakers and coronary stents. The medical device market has been described as consisting of eight industry sectors: 1.surgical and medical instrument manufacturing,2. surgical appliance and supplies, 3.electromedical and electrotherapeutic apparatus,4. irradiation apparatus, 5.ophthalmic goods, 6.dental equipment and supplies,7. dental laboratories, and 8.in vitro diagnostic products (IVDs, or laboratory developed tests).
- 4. The federal agency responsible for regulating medical devices is the Food and Drug Administration (FDA)—an agency within the Department of Health and Human Services (HHS). A manufacturer must obtain FDA’s prior approval or clearance before marketing many medical devices in the United States. FDA’s Center for Devices and Radiological Health (CDRH) is primarily responsible for medical device premarket review. Another center, the Center for Biologics Evaluation and Research (CBER), regulates devices associated with blood collection and processing procedures, cellular products and tissues.
- 5. D E V I C E C L A S S I F I C AT I O N • Under the terms of the Medical Device Amendments of 1976 • FDA classified all medical devices that were on the market at the time of enactment— the Pre amendment devices—into one of three classes. Congress provided definitions for the three • classes—Class I, Class II, and Class III—based on the risk (low-, moderate-, and high- risk respectively) to patients posed by the devices.
- 7. Device classification determines the type of regulatory requirements that a manufacturer must follow. General controls apply to all three classes of FDA-regulated medical devices, unless exempted by regulation, and are the only level of controls that apply to Class I devices. general controls include establishment registration, device listing, premarket notification, and good manufacturing practice requirements. Class I devices are those under current law for which general controls “are sufficient to provide reasonable assurance of the safety and effectiveness of the device.” Many Class I devices are exempt from the premarket notification and/or the Quality System (QS) regulation requirements, though they still have to comply with the other general controls. A device is exempt if FDA determines that it presents a low risk of illness or injury to patients.
- 8. M E D I C A L D E V I C E M A R K E T I N G A P P L I C AT I O N S 1. Pre Market approval(PMA) 2. PMA supplements 3. Evaluations of PMA and PMA supplement process 4. Humanitarian in device exemption (HDE) 5. 510(k) notification 6. Assessment of the 510(k) process
- 9. P R E M A R K E T A P P R O VA L ( P M A ) A PMA is “the most stringent type of device marketing application required by FDA” for new and/or high-risk devices. PMA approval is based on the application contains sufficient valid scientific evidence to provide reasonable assurance that the device is safe and effective for its intended use(s) PMAs generally require some clinical data prior to FDA making an approval decision. All clinical evaluations of investigational devices (unless exempt) must have an investigational device exemption (IDE) before the clinical study is initiated. An IDE allows an unapproved device (most commonly an invasive or life-sustaining device) to be used in a clinical study to collect the data required to support a PMA submission. The IDE permits a device to be shipped lawfully for investigation of the device without requiring that the manufacturer comply with other requirements of the FFDCA, such as registration and listing.
- 10. • A PMA must contain (among other things) the following information: • summaries of nonclinical and clinical data supporting the application and conclusions drawn from the studies; • a device description including significant physical and performance characteristics; • indications for use, description of the patient population and disease or condition that the device will diagnose, treat, prevent, cure, or mitigate; • a description of the foreign and U.S. marketing history, including if the device has been withdrawn from marketing for any reason related to the safety or effectiveness of the device; • proposed labeling; and • a description of the manufacturing process.
- 11. P M A S U P P L E M E N T S • If a manufacturer wants to make a change to an approved PMA device, it must submit to FDA one of several different types of PMA supplements to request agency approval of the device change.. • Devices approved via a PMA supplement have smaller fees, shorter review times, and often do not require the collection of premarket clinical data. • . The features of the PMA supplement “encourage manufacturers to implement evolving technologies to create new models of devices that are incrementally different from previously approved additions. • This helps facilitate rapid improvement in device technology.
- 12. E VA L U AT I O N S O F P M A A N D P M A S U P P L E M E N T P R O C E S S • , FDA considers a PMA to be the most stringent type of device marketing application required for new and/or high-risk devices. However, studies in the academic medical literature have questioned the quality of the data submitted to the agency in support of PMA applications. • Randomized controlled trial (RCT): participants are randomly assigned to two or more groups. One group receives the intervention (the new treatment), while the control group receives current therapy or placebo. Randomization ensures that any patient characteristics that might affect the outcome will be roughly equal across each group in the study. Any difference in outcomes between the groups is then likely due to the intervention. The RCT is often called the gold standard of evidence for a clinical trial. • Blinded clinical trial: participants, caregivers, and outcome assessors are prevented from knowing which intervention was received by the participants until the trial has ended. Using a blinded trial design is, along with randomization, another mechanism to help ensure that the trial results are not biased in favor of the intervention.
- 13. 5 1 0 ( K ) N O T I F I C AT I O N • 510(k) Notification In general, a 510(k) submission is required for a moderate-risk medical device that is not exempt from premarket review. • A 510(k) could also be used for currently marketed devices for which the manufacturer seeks a new indication (e.g., a new population, such as pediatric use, or a new disease or condition), or for which the manufacturer has changed the design or technical characteristics such that the change may affect the performance characteristics of the device. • Class II devices were either implantable, life sustaining or presented significant risk to the health, safety, or welfare of the patient. • . A predicate device can be one of two things. It can be a previously cleared Class I or II device that does not require a PMA. It can also be preamendment Class III for which the agency has not issued regulations requiring a PMA. (PMAs, which are more rigorous submissions than 510(k)s, are discussed in the “Premarket Approval (PMA)” section.) • A manufacturer may choose one of three types of 510(k) submissions for premarket clearance: traditional, special, or abbreviated. • . For novel devices without a predicate, there is another alternative called the de novo 510(k) process.
- 14. P O S T M A R K E T I N G S U R V E I L L A N C E A N D T H E N AT I O N A L E VA L U AT I O N S Y S T E M F O R H E A LT H T E C H N O L O G Y ( N E S T ) • Because the premarket review process cannot be designed to completely ensure the safety of all devices before they enter the market, it is essential to have a strong surveillance system that monitors the safety of medical devices. • When a problem is identified with a particular medical device, various corrective actions can then be implemented. • Corrective actions might include changing the device labeling and instructions for use, improving user training, continued study of the device problem via postmarket surveillance, or removal of the device from the market if appropriate
- 15. M E D I C A L D E V I C E R E P O R T I N G ( M D R ) . • FDA annually receives several hundred thousand reports of confirmed or possible medical device related malfunctions, serious injuries, and deaths. Limitations of this passive surveillance system include incomplete, inaccurate, and/or delayed data reporting; underreporting of events; and lack of information on the total number of devices on the market in clinical use. • Medical Product Safety Network (MedSun). • FDA receives about 5,000 higher quality reports each year on device use and adverse outcomes from a network of U.S. hospitals. • The network “can be used for targeted surveys and clinical research” and has specialty subnetworks that focus on particular device types (HeartNet), laboratories (LabNet), or patients (KidNet). • Post-Approval Studies. • Such studies may be ordered by FDA as a condition of approval for a PMA device. These studies are typically “used to assess device safety, effectiveness, and/or reliability including longer-term, real- world device performance.”
- 16. M A N U FA C T U R I N G • Like drug manufacturers, medical device manufacturers must produce their devices in accordance with Good Manufacturing Practice (GMP). • The GMP requirements for devices are described in the QS regulation. The QS regulation requires that domestic or foreign manufacturers have a quality system for the design, manufacture, packaging, labeling, storage, installation, and servicing of nonexempt finished medical devices intended for commercial distribution in the United States. • The regulation requires that various specifications that devices be correctly installed, checked, and serviced; that quality data are analyzed to identify and correct quality problems; and that complaints are processed. • FDA monitors device problem data and inspects the operations and records of device developers and manufacturers to determine compliance with the GMP requirements.
- 17. C O M P L I A N C E A N D E N F O R C E M E N T 1.Inspection 2.Warning letter 3.Product recall
- 18. I N S P E C T I O N • Each FDA center has an Office of Compliance (OC) that ensures compliance with regulations while pre- or post market studies are being undertaken, with manufacturing requirements, and with labeling requirements. • The objectives of CDRH’s OC’s Bioresearch Monitoring (BIMO) program are to ensure the quality and integrity of data and information submitted in support of IDE, PMA, and 510(k) submissions and to ensure that human subjects taking part in investigations are protected from undue hazard or risk. • This is achieved through audits of clinical data contained in PMAs prior to approval, data audits of IDE and 510(k) submissions, inspections of IRBs and nonclinical laboratories,
- 19. WA R N I N G L E T T E R • A Warning Letter is a written communication from FDA notifying a responsible individual, manufacturer, or facility that the agency considers one or more products, practices, processes, or other activities to be in violation of the laws that FDA enforces. • The Warning Letter informs the recipient that failure to take appropriate and prompt action to correct and prevent any future repeat of the violations could result in an administrative or judicial action. • Although serious noncompliance is often a catalyst for issuance of a Warning Letter, the Warning Letter is informal and advisory
- 20. P R O D U C T R E C A L L • A recall is a method of removing or correcting products that FDA considers are in violation of the law. • Medical device recalls are usually conducted voluntarily by the manufacturer. • Manufacturers and importers are required to report to FDA any correction or removal of a medical device that is undertaken to reduce a health risk posed by the device. • A recall may involve the removal of all or a portion of the product on the market (such as a single lot). • In rare instances, where the manufacturer or importer fails to voluntarily recall a device that is a risk to health, FDA may issue a recall order to the manufacturer
- 21. T H A N K Y O U