Deciding When to Submit a 5. Change to an Existing Device (K9. PDF Printer Version(4. KB)5. 10(k) Memorandum #K9. DATE: January 1. 0, 1. FROM: Director, Office of Device Evaluation. Subject: Deciding When to Submit a 5. Change to an Existing Device. TO: ODE Review Staff. Through: ODE Branch Chiefs. Purpose. The purpose of this guidance is to provide direction to manufacturers on deciding when to submit a 5. Background. On April 8, 1. FDA circulated for comment the first draft guidance entitled . As a result of these activities, FDA received over 6. On October 1. 6, 1. FDA published a Notice of Availability in the Federal Register announcing the availability of an August 1, 1. Attached is the final version of the guidance for reference by the review staff. This guidance is not intended to supplant existing definitive guidance for modifications to specific devices, e. Moreover, the guidance is not intended to apply to combination products, such as drug/device or biologic/device combinations, although it may be helpful. The guidance is also not intended to address the need for submitting a 5. FDA intends to develop additional guidance specific to these situations. Procedures. The type of modifications addressed in the draft guidance include labeling changes, technology or performance specifications changes, and materials changes. When making the decision on whether to submit a 5. That is, manufacturers may make a number of changes without having to submit a 5. In Search of Book of Mormon Geography. Below is the modern map of the area of Smith's Youth. The Book of Mormon is supposed to be a history of real people living in a.In effect, manufacturers need to submit a new 5. When any one change leads the manufacturer to decide to submit a 5. In the instance where the legally marketed device is the manufacturer's own device, the 5. The guidance includes a main flowchart to help manufacturers through the logic scheme necessary to arrive at a decision on when to submit a 5. The flowchart includes the following three logical breakouts of changes that might be made to a device: labeling changes, technology or performance specifications changes, and materials changes. To use the model, the questions posed in the flowchart should be answered until the 5. If a manufacturer's consideration of all proposed changes results in a decision merely to document the decision- making, they should document the application of the model along with the necessary records of the validation of changes to the device. In those circumstances where the proposed change is not addressed in the flowchart or in a device- specific guidance document, manufacturers are encouraged to contact the Office of Device Evaluation in CDRH to find out whether other, specific guidance exists or if additional help is available. Effective Date: This guidance is effective immediately. Susan Alpert, Ph. Please note that once you make your selection, it will apply to all future visits to NASDAQ.com. If, at any time, you are interested in reverting to our default. APA, Harvard, Chicago, and 7,000 additional formats; No advertisements! Unlimited cloud backup of all your citations. Forex Margin Call Explained - babypips.com www.babypips.com/./margin-call-exemplified.html Learn what a margin call is in forex trading and watch how quickly you. This guidance represents the Food and Drug Administration's (FDA's) current thinking on this topic. It does not create or confer any rights for or on any person and. D., M. D. This document is intended to provide guidance in the preparation of a regulatory submission. It does not bind the FDA or the regulated industry in any manner. Office of Device Evaluation. Document Issued On: January 1. Note: While this guidance document represents a final document, comments and suggestions may be submitted at any time for Agency consideration by contacting the Premarket Notification (5. Section at 3. 01- 7. For questions regarding the use or interpretation of this guidance, also contact the Premarket Notification (5. Section at 3. 01- 7. U. S. DEPARTMENT OF HEALTH AND HUMAN SERVICESPublic Health Service. Food and Drug Administration. Center for Devices and Radiological Health. Preface. On April 8, 1. FDA circulated for comment the first draft of a document intended to provide guidance to manufacturers on when to submit a new 5. That draft was the subject of an FDA/FDLI video conference on May 1. Subsequently, in response to comment letters, a second draft of the guidance (dated August 1, 1. Notice of Availability in the Federal Register (6. FR 5. 36. 24, October 1. These comments from the second round of public review have led to the current guidance document. While we are pleased to issue this guidance in final form, we recognize that, as a guidance document, it can and will need to be revised over time as we gain more experience with its application. These revisions will be based on comments and recommendations of its users, both in the industry and in FDA. CDRH continues to look at the 5. Program and ways of reengineering the review process. For example, a program to pilot test the third party review of 5. In addition, we will be looking at the better use of consensus standards and special controls in the 5. Quality Systems Regulation with the 5. TABLE OF CONTENTSPreface. Introduction. The 5. Process and Good Manufacturing Practices. Scope of the Proposed Guidance. Assumptions/Axioms. The Model. Labeling Changes. Technology, Engineering and Performance Changes. Materials Changes. Materials Changes in In Vitro Diagnostic Products. Definitions. Flowcharts. Appendix. References. Introduction. Almost from the enactment of the Medical Device Amendments to the Federal Food, Drug, and Cosmetic Act in 1. FDA staff have attempted to define with greater accuracy when a change in a medical device would trigger the requirement that a manufacturer submit a new premarket notification (5. Agency. The regulatory criteria state that a premarket notification must be submitted when: (3) The device is one that the person currently has in commercial distribution or is reintroducing into commercial distribution, but that is about to be significantly changed or modified in design, components, method of manufacture, or intended use. The following constitute significant changes or modifications that require a premarket notification: (i) A change or modification in the device that could significantly affect the safety or effectiveness of the device, e. A major change or modification in the intended use of the device. The key issue here is that the phrase . Because of this, manufacturers have frequently expressed the need for more specific guidance in applying the regulatory standard in their decision- making. Previous attempts to develop such guidance have focused generally on defining broad issues or principles that should be used in deciding when to submit a 5. These attempts have been only partially successful in clarifying the situation. The primary reason for partial success is that the variety of device types currently marketed, as well as the myriad changes that occur as technology evolves, are so diverse that one or two unifying principles cannot possibly account for all possible situations. To be certain that a decision on when to submit a 5. Given that there are thousands of individual device types and possibly tens or hundreds of enumerable changes, this would be an impossible task. Furthermore, the resultant guidance would fill volumes, would probably be difficult to use, and would be unlikely to keep pace with an ever- changing technology. Between the two extremes of broad principles and detailed enumeration is the area where models can be developed to assist in the decision- making. If created and used properly, such a model could provide guidance leading toward a rational answer as to whether a 5. This document proposes a flowchart model that can be used by manufacturers in their decision- making to analyze how changes in devices may affect safety or effectiveness. In the model, we attempt to address changes to devices at a level detailed enough so that application of the broad principles contained in the regulations would minimize disagreements between manufacturers and the Agency . The goal of the model is to provide guidance in answering a manufacturer's questions on whether a 5. Taken as a whole, this guidance, and the model it describes, provides the agency's best definition of when a change to a device could significantly affect safety or effectiveness. Back to the top. The 5. Process and Good Manufacturing Practices. Any guidance on 5. Good Manufacturing Practice (GMP) regulation plays in changes to device design. For some types of changes to a device, the Agency continues to find that a 5. GMP requirements may continue to reasonably assure the safety and effectiveness of the changed device. It is important to note that the current 1. GMP regulation does not directly address the original design of a device. In fact, it was the recognition of the need for this type of control for many types of devices that led to the inclusion of pre- production design controls in the Safe Medical Devices Act of 1. The new GMP and design control regulation, called the Quality Systems regulation, will implement the new authority granted by the Safe Medical Devices Act and require design controls for new devices. The Quality Systems regulation 3, will take effect in two stages. The entire regulation, except for design controls, will take effect on June 1, 1. The design control provisions will take place on June 1, 1. The 1. 97. 8 GMP regulation, however, is not entirely silent on device design. It requires manufacturers to document in the device master record (. It also requires process validation to assure that devices meeting the designed quality characteristics will consistently be produced (. Finally, manufacturers must have a formal approval procedure for any change in the manufacturing process of a device including those dictated by design changes (. Under the Quality Systems regulation, manufacturers are required to review and approve any changes to device design and production (new . Any process whose results cannot be fully verified by subsequent inspection and test must be validated (new . They must keep records, and these records must be made available to an FDA inspector. Thus, while the Quality Systems regulation requires design controls for many devices, those controls do not take effect until June 1, 1. Until then, manufacturers must still comply with the current GMP regulation, which imposes requirements on changes to device design. For many types of changes to a device, it may be found that a 5. Agency may reasonably rely on good manufacturing practices (either as implemented under the 1. Two different crankshafts from similar engines were studied in this research. The finite element analysis was performed in four static steps for each crankshaft. Stresses from these analyses were used for superposition with regards to dynamic load applied to the crankshaft. Further analysis was performed on the forged steel crankshaft in order to optimize the weight and manufacturing cost. Key words: FEA,CAE Analysis, Dynamic Load analysis, cost optimization, Weight reduction, Crank shaft, Crankshaft Analysis, Cost and weight reduction. Reference. 5. 11. United States Patent. Society of Automotive Engineers, Warrendale, PA, USA. Society of Automotive Engineers, Warrendale, PA, USA. Society of Automotive Engineers, Warrendale, PA, USA.
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. Archives
August 2017
Categories |