510(k) Clearance and PMA

Rami.Azulay February 23rd, 2011 Posted by Rami Azulay( ) 510(k), Pre Market Approval (PMA), Software Lifecycle Management

PMA = Pre Market Approval

Risk Classification

Class I: Simple devices with a minimal risk to the user. Most of these devices are exempt from FDA clearance or approval. Examples: crutches, elastic bandages, bedpans.

Class II: Moderate level of risk to the user. Almost all of these devices require a regulatory submission before they can be legally marketed. As a rule, class II devices require 510(k) submissions. Examples: administration sets, sutures, inflatable blood pressure cuffs.

Class III: These devices pose a serious level of risk to the user, mostly because they are implants or sustain life. All of these devices require a regulatory submission before they can be legally marketed. As a rule, class III devices require a PMA (Premarket Approval) submission. Examples: implantable pacemakers, blood vessel stents, breast implants.

510(k) Clearance
The purpose of a 510(k) submission is to demonstrate that a device is “substantially equivalent” to a predicate device. The 510(k) submitter compares and contrasts the subject and predicate devices, explaining why any differences between them should be acceptable. Manufacturers may also submit a 510(k) if they alter their device. Not all changes require a 510(k) submission. In general, changes to a device’s intended use, contraindications, or basic operation require a new 510(k) clearance. Changes to blood-contacting materials, sterilization method, or performance specifications may also require a new 510(k).

The FDA does not “approve” 510(k) submissions. It “clears” them.

Premarket Approval (PMA)

A PMA submission is used to demonstrate to the FDA that a new or modified device is safe and effective. This standard is higher than is required for 510(k) submissions. Human use data from a formal clinical study is almost always required in addition to laboratory studies.

PMA devices can be legally advertised as “PMA-approved” or “FDA-approved.”

Source: http://www.devicewatch.org/reg/reg.shtml

About the author, Rami Azulay

Rami has over 24 years of experience in various software development and QA roles. Using his extensive knowledge of operations and quality, Rami was a main architect of the Orcanos software back in 2005 and later became Orcanos VP sales & marketing. Rami holds an MSC degree in Computer Sciences.



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