Hi! I am trying to find confirmation that the definition of "commercial distribution" in 807.3(b) includes devices for human use that are sold, provided at no-charged and/or loaned to a customer?
One of our R&D staff seems to believe that full design validation isn't required if the device will initially be provided to a small number of KOLs for free, with the intent that the devices be used on humans. This is not a clinical study and there is no IDE - it's a limited market release.
Please help me put this madness to bed!
One of our R&D staff seems to believe that full design validation isn't required if the device will initially be provided to a small number of KOLs for free, with the intent that the devices be used on humans. This is not a clinical study and there is no IDE - it's a limited market release.
Please help me put this madness to bed!