Registering a new device with the FDA can be tricky. The first step is to choose what pathway to follow for the submission. One of the most common submission pathway ways used is the 510K pathway. Even after choosing the 510K pathway, a company will still have to choose which type of 510K to choose from – traditional, abbreviated, or special. While each type has the same basic structure there are significant differences between them, to learn more about those differences check out this blog. Regardless of what type of 510K is being submitted there are a few basic tips that can be applied.
First and foremost, be prepared. Understanding everything the 510K submission will require will help a company submit the application in a smoother manner. 510Ks often require the same specific documentation no matter the device. Where the biggest difference can come in is the testing documentation required. Some devices may require a large amount of testing while others may only require a handful of tests. Testing that is often required is sterilization testing and biocompatibility testing. The FDA has drafted guidance documents that apply to specific devices or types of devices that list the testing requirements for the 510K. Knowing what testing is needed and having the documentation ready will enable a company to complete their submission all the quicker.
The next tip is to know the predicate device. A 510K requires that there be a predicate device to the device the submission is being made for. A predicate device is one that has already been approved by the FDA and equivalence is being drawn to.[1] Essentially the device that the new 510K is being submitted will be compared to this predicate device. The company submitting the new 510K gets to choose which device to list as the predicate device and it can be any device already approved by the FDA, even ones from other companies. Examining the 510K of the predicate device and seeing what that submission entailed will give insight into what is needed for the 510K of the new device.
Finally, have patience. Getting approved by the FDA takes and while there may be the desire to rush to submit the application to speed up the process even just a little bit, it is better to take the time to ensure that the submission is done right. The process will take time no matter what so it is better to get it right the first time. EMMA International can help prepare and submit a 510K. The team at EMMA International can also provide assistance with registering products in other countries and markets. EMMA International provides Full Circle Consulting serivces, give us a call at 248-987-4497 or email us at info@emmainternational.com to get in touch with our team of experts today.
[1] FDA (March 2020) Premarket Notification 510(K), Retrieved 12/11/2021 from https://www.fda.gov/medical-devices/premarket-submissions-selecting-and-preparing-correct-submission/premarket-notification-510k
