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  FDA Regulatory Assistance 
  In the US, the marketing of medical device innovations are regulated by the 
  Food and Drug Administration's Center for Devices and Radiological Health 
  (CDRH) in Silver Spring, Maryland.  Regulation is risk-based and three risk 
  classifications are identified: Class 1 (low risk; FDA registration & listing), 
  Class 2 (moderate risk; FDA premarket notification), and Class 3 (high risk; 
  FDA premarket approval).   Risk depends primarily upon intended use and 
  the uncertainty regarding establishing safety and effectiveness of a new 
  medical device.  The figure on the right, based on the well-known 1990 
  Henderson-Clark product innovation model, describes this in greater detail 
  for Class 2 and 3 devices.  New devices that have a legally marketed 
  predicate are required to provide premarket notification and obtain 
  administrative clearance prior to marketing in the US.  New devices that 
  have no legally marketed predicate are required to obtain premarket 
  approval (which is very different from administrative clearance) prior to 
  marketing in the US.  Clinical trials are required for all premarket approval 
  requests and for a minority of premarket notification requests.
  We can assist you with:
  •
  obtaining FDA small business certification for lower cost user fees;
  •
  completing/maintaining your establishment registration and device 
  listing(s);
  •
  preparing/submitting a request for a device classification ruling, also 
  known as a 513(g);
  •
  preparing/submitting Traditional, Abbreviated, or Special premarket 
  notifications, also known as a 510(k) and the now mandatory e-Copy;
  •
  preparing/submitting a request for an Investigational Device 
  Exemption (IDE) and then preparing/submitting a study proposal, 
  including an Informed Consent compliant with 21 CFR Part 50, for 
  Institutional Review Board (IRB) approval; please note that an IDE is 
  NOT an exemption from Design Controls (21 CFR 812.1(a));
  •
  preparing, justifying, and submitting a request for a de novo 
  reclassification, if your device is found to be Not Substantially 
  Equivalent (NSE) to your claimed predicate;
  •
  preparing/submitting a request for premarket approval (PMA) and then  
  post-PMA supplements;
  •
  preparing/responding to FDA District Office inspection deficiencies, 
  also known as Form 483 observations;
  •
  preparing/submitting reports under the Medical Device Reporting 
  (MDR) rule; and
  •
  various other medical device regulatory services. 
   Please see next sections for assistance with: 
  Design Controls, Risk Management, & Human Factors.
  They are all interconnected!
  
 
   
 
 
  Keys to rapid, successful 510(k) clearance:
  •
  correctly identifying one (or more) legally marketed 
  predicate(s), 
  •
  correctly identifying the required testing for your 
  specific device, as specified in (international) 
  consensus standards and FDA special controls,
  •
  correctly and completely doing the required testing 
  and testing documentation, 
  •
  preparing a submission that includes all the 
  requisite elements for your type of device, and
  •
  preparing the now mandatory, validated e-Copy.
 
 
   
 
  
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
  
  
 