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"Indication for Use" used in 510(k) - Indications for Use vs. Intended Use

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510(k), indications for use, intended use (medical devices), medical devices (general)
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  Post Number #1  
Old 23rd May 2007, 06:39 AM
temujin's Avatar
temujin

 
 
Total Posts: 165
Question "Indication for Use" used in 510(k) - Indications for Use vs. Intended Use

Dear Forum,

Is the term "Indication for Use" used in 510(k) equal to the terms "Intended Use"/"Intended Purpose"

regards
temu

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  Post Number #2  
Old 23rd May 2007, 11:01 AM
chris1price

 
 
Total Posts: 178
Re: "Indication for Use" used in 510(k) - Indications for use vs. Intended use

Hi

In my experince, the Indications for Use are usually very specific and tend to be used in a regulatory framework, such as discussion with FDA on predicates or labelling. The indended use is more general and descriptive.

see

http://www.fda.gov/cdrh/devadvice/314312.html#link_6

***DEAD LINK REMOVED****

Last edited by Marc; 5th August 2010 at 12:58 PM. Reason: Dead link removed.
Thank You to chris1price for your informative Post and/or Attachment!
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  Post Number #3  
Old 23rd May 2007, 04:01 PM
yodon

 
 
Total Posts: 791
Re: "Indication for Use" used in 510(k) - Indications for use vs. Intended use

The kicker I've seen is that any statement of intended use can be construed by the FDA as "indication for use." Just about anything published can be taken as labeling so if your 510(k) limits indication for use but you have, for example, marketing literature that expands that use, the FDA can consider the broader statement as a claim. Bottom line is to be careful!
Thank You to yodon for your informative Post and/or Attachment!
  Post Number #4  
Old 24th May 2007, 01:30 PM
Madly RA'd Woman

 
 
Total Posts: 14
BIG Smile Re: "Indication for Use" used in 510(k) - Indications for use vs. Intended use

This is one of the statements you can find in the ANSI/AAMI/ISO TIR14969:2004 (guidance towards ISO 13485) document about the two terms:

7.2.1.3 For medical devices, an understanding of both stated intended use and any reasonably foreseeable misuse, and indications for use, should be documented. This is of particular importance in the development of new products. The guidance in 7.3 will help the organization to determine if requirements for design and development apply. The stated intended use and any reasonably foreseeable misuse should also be included in risk management activities (see 7.1 of this document regarding risk management activities).

I see this statement contrasting the "intended use" with "foreseeable misuse". "Indications for use" is more of the specific scenarios in which the device may be applied.

I also agree with the previous log that stated to be careful with your application remarks. If you aren't a RAPS member, you may want to check with RAPS.org about this subject. Anywhere you state what your product does is a "labelling" that is FDA reviewable and peer-debatable.

If you stray from your 510(k) permissable indications, you will have regulatory work to do beyond any labelling changes.

Hope this helps!
Thank You to Madly RA'd Woman for your informative Post and/or Attachment!
  Post Number #5  
Old 5th August 2010, 12:12 PM
cookie36

 
 
Total Posts: 5
Re: "Indication for Use" used in 510(k) - Indications for use vs. Intended use

We would like to put both our indications for use and intended use in our user manual.

Is this safe to say:

- Intended use: is the same statement as what we submit in the 510(k) in the "indications for use" page (and throughout the submission under intended use as well)

- Indications for use: is the more detailed version of the intended use. It could be made up, or summarize, the other portions of the 510(k), going into even more detail as to the contraindications, disease states, patient populations, etc.

This is confusing to me because what we submit with the 510k is known as the indications for use - but is this really known as the "intended use"?

-Elaine
  Post Number #6  
Old 6th August 2010, 01:02 AM
sagai

 
 
Total Posts: 1,094
Re: "Indication for Use" used in 510(k) - Indications for use vs. Intended use

There is a wind of change recently in this subject, see:
http://www.fda.gov/downloads/AboutFD.../UCM220784.pdf
Page 7.

br
Sz.
  Post Number #7  
Old 5th March 2014, 08:34 AM
CBAL08

 
 
Total Posts: 165
Re: "Indication for Use" used in 510(k) - Indications for Use vs. Intended Use

Can we change the intended use in the middle of 510k process? Need suggestion and help how this can be done.
  Post Number #8  
Old 5th March 2014, 02:51 PM
MIREGMGR

 
 
Total Posts: 3,682
Re: "Indication for Use" used in 510(k) - Indications for Use vs. Intended Use

Call up your examiner and tell him/her that you want to amend your submission. Assuming he/she doesn't throw up some roadblock, do a new submission that identifies what new section-information is to be substituted into the original submission.
Thanks to MIREGMGR for your informative Post and/or Attachment!
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