First I'd like to thank everyone who responds to these posts. It's my first question, but I routinely search the forums and often find what I'm looking for....so, thanks!
The question is: how is it that the FDA has recommended I use the parent device as the predicate for an accessory, when the accessory will have a different intended use than the parent device (the needles provide access to a part of the body, and our device will prevent needle sticks)? I want to take their advice, but I'm having a hard time understanding how I'll frame the 510k submission and establish substantial equivalency when we don't meet this basic requirement.
Background: We submitted a pre-sub for a needle-stick prevention accessory for a specific set of needles. We proposed a predicate device with similar intended use from a different regulatory classification than the parent device. In their written response they responded that we *could* do that, but they recommend using the specific set of needles as the "parent predicate device." For the follow-up Pre-Sub Teleconference we submitted a question asking specifically how we could use the parent device as the predicate when it has a different intended use. During the meeting they confirmed that that is the FDA's recommendation, but they declined to answer this specific question and instead told us to review the accessory guidance (which we took to mean this guidance doc: Medical Device Accessories - Describing Accessories and Classification Pathways (no link b/c it's my first post!)). I have reviewed it several times. I just don't see that this question is covered.
Anyone out there have any thoughts? Thanks in advance.
The question is: how is it that the FDA has recommended I use the parent device as the predicate for an accessory, when the accessory will have a different intended use than the parent device (the needles provide access to a part of the body, and our device will prevent needle sticks)? I want to take their advice, but I'm having a hard time understanding how I'll frame the 510k submission and establish substantial equivalency when we don't meet this basic requirement.
Background: We submitted a pre-sub for a needle-stick prevention accessory for a specific set of needles. We proposed a predicate device with similar intended use from a different regulatory classification than the parent device. In their written response they responded that we *could* do that, but they recommend using the specific set of needles as the "parent predicate device." For the follow-up Pre-Sub Teleconference we submitted a question asking specifically how we could use the parent device as the predicate when it has a different intended use. During the meeting they confirmed that that is the FDA's recommendation, but they declined to answer this specific question and instead told us to review the accessory guidance (which we took to mean this guidance doc: Medical Device Accessories - Describing Accessories and Classification Pathways (no link b/c it's my first post!)). I have reviewed it several times. I just don't see that this question is covered.
Anyone out there have any thoughts? Thanks in advance.