IEC 62304:2006: Medical device software SDLC- CE Vs. Fda 510(k) submission

sagai

Quite Involved in Discussions
only some minor observations

510k is the Act itself (and when you do so, you legally bind yourself to the Act with its all consequences), see: FD&C Act Sec.510(k)
http :// www .fda. gov/RegulatoryInformation/Legislation/FederalFoodDrugandCosmeticActFDCAct/FDCActChapterVDrugsandDevices/ucm109201.htm - OBSOLETE BROKEN 404 LINK(s) UNLINKED

Relevant amendments can be also found here:
http :// www .fda. gov/RegulatoryInformation/Legislation/FederalFoodDrugandCosmeticActFDCAct/default.htm - OBSOLETE BROKEN 404 LINK(s) UNLINKED

There are some more consequential Acts and Amendments, like:
Safe Medical Devices Act of 1990
Congress.gov | Library of Congress
Medical Device Amendments of 1992
Congress.gov | Library of Congress

510k premarket notification procedure is defined by FDA as part of the execution of the corresponding Act, see:
The New 510(k) Paradigm - Alternate Approaches to Demonstrating Substantial Equivalence in Premarket Notifications - Final Guidance
510k, premarket notification procedure is NOT the same as premarket approval, its based on your device classification (I am not going such deep).

More reading for marketing the Medical Device in the US and for premarket notification (510k), see:
How to Study and Market Your Device
Premarket Notification 510(k)


For SW contained in medical device there is a reading here:
http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm089543.htm

In general and introductory learning and investigation, I hardly suggest these materials also and of course, PASS THE TESTS !!! :) :
http :// www .fda.gov/Training/CDRHLearn/ucm162015.htm#510k - OBSOLETE BROKEN 404 LINK(s) UNLINKED

As we can see and may know, only a premarket notification (510k) is fairly complex procedure can be for an applicant and requires a LOT of knowledge and preparation in order to be successful.


Regarding "quality procedure and process" the FDA GMP in this context is 21CFR820, see:
CFR - Code of Federal Regulations Title 21

Furthermore ...
510k, the Act requires to comply with:
- registration and listing (21CFR807)
- labeling (21CFR801 , 21CFR809)
- medical device reporting (reporting medical device-related adverse events) (21CFR803)
without a complete list.
see these using:
CFR - Code of Federal Regulations Title 21


about the standards ...
There are recognized and NOT recognized standards in FDA.
to read more, see:
Standards and Conformity Assessment Program

and to search for:
Recognized Consensus Standards

62304:
Recognized Consensus Standards

The RM in 62304 does not enough alone, and actually 62304 declares it implicitly, see in the Introduction of 62304 saying:
"
The RISK MANAGEMENT PROCESS is already very well addressed by the International
Standard ISO 14971. Therefore IEC 62304 makes use of this advantage simply by a normative reference to ISO 14971.
"
"
The software RISK MANAGEMENT PROCESS required in this standard has to be embedded in the device RISK MANAGEMENT PROCESS according to ISO 14971
"
Moreover in 62304 the 14971 is a NORMATIVE REFERENCE, see Chapter 2 in the standard.

okay, that's all, br
Sz.
 
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sagai

Quite Involved in Discussions
There is a good guide for testing I have found recently to advise.
http :// www .ispe.org/galleries/members-gallery/GAMP_GPG7-TestingGxP_final.pdf - OBSOLETE BROKEN 404 LINK(s) UNLINKED
There is general Testing principles and ... yeeah :tg: templates :bonk:
You shall register to download it, it is free afterwards.
I have attached it, may not be removed.
br.
Sz.
 

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T

Taimoore

Hello Sagai
Thanks for sharing the document. I surely think it will help and guide me and my small team a lot.

Its very detailed and comprehensive. :tg:

Thanks a lot.

best wishes
Tim
 
Q

QA_RA_Lady

Hi Tim,

I would LOVE to respond to your questions.... but first I have a few for you.
1) Where is your company located?
2) Where are you currently selling your products?
3) Did you develop these products from nothing? Or were they purchsed as complete products?

The reason that I ask, is because I wonder what standards you followed to create them origially? Do you follow any regulations right now? If so which one(s)? There are a lot of quick and easy answers to this = but I get the impression that none of them apply to your situation... it sounds like you're starting a brand new company?
I can speak to both FDA and MDD - MOST of the documentation required in a submission is what you should already have created as function of good software design. Do you have a specification? If you do THAT is your template for the test plan. If you don't, you may have bigger problems that obtaining clearance in new markets. Do you follow 13485? 9001?

I'm happy to help, but as stated in an earlier response, your questions are very broad. If you could share more info about your situation it would be easier to guide you in the right direction.
 
A

AVunited7

Does anyone have a comparsion between the Technical file (CEmarking) and FDA requirements? This would really help me with identifying and closing any gaps.
Mostly it is the same just terms are different- is there a chart or checklist that identifies these?
Thanks
 
M

MangeshR

Can anybody help me with Process validation SOP please.I need it in case of API manufacturing.
Thanks, in advance.
Mangesh Ramteke
 
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