When to Submit a New 510(k) for Medical Device Changes?

When considering changes to a medical device, the question of whether a new 510(k) submission is required is crucial. Let's delve into the details.

Significant Changes Requiring a New 510(k)

If a legally marketed device, subject to 510(k) requirements, undergoes significant changes or modifications in design, components, method of manufacture, or intended use, a new 510(k) submission is necessary. These significant changes could potentially impact the safety or effectiveness of the device. Examples of such modifications include changing indications for use from prescription to over-the-counter or adding a new patient population.

Risk-Based Assessment

Even if changes are not expected to significantly affect safety or effectiveness, manufacturers should still evaluate them. A risk-based assessment, similar to ISO 14971, helps determine whether a new 510(k) is required. Manufacturers should also consider the unintended consequences of the change during this assessment. If the initial risk-based assessment indicates that a new 510(k) is not needed, this decision should be confirmed through routine verification and validation activities. However, if these activities produce any unexpected results, any prior decision that submission of a new 510(k) is not required should be reconsidered.

Special 510(k) Program

If a new 510(k) is likely required, manufacturers can explore the Special 510(k) Program. This program offers an expedited pathway, with processing within 30 days (as opposed to the traditional 90 days). It is particularly suitable for design or labeling changes, including alterations to indications for use. When performance data are unnecessary, or if well-established methods exist to evaluate the change, a Special 510(k) may be appropriate. All necessary performance data can be reviewed in a summary or risk analysis. If a Special 510(k) submission is deemed inappropriate, the FDA may convert it to a Traditional 510(k). This conversion could potentially result in delayed review. Therefore, manufacturers must carefully evaluate whether a Special 510(k) is the most suitable pathway.

Inappropriate Circumstances for Special 510(k)

The FDA recognizes that there are situations where a Special 510(k) is not appropriate. Examples include changes requiring evaluation across multiple scientific disciplines or use of novel sterilization methods.

In summary, manufacturers must carefully assess changes to devices, balancing safety, effectiveness, and regulatory requirements. The FDA provides guidance to enhance predictability and consistency in decision-making regarding 510(k) submissions for modified devices:

• Deciding When to Submit a 510(k) for a Change to an Existing Device 
• Deciding When to Submit a 510(k) for a Software Change to an Existing Device 
• The Special 510(k) Program

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