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Joe Hage
๐Ÿ”ฅ Find me at MedicalDevicesGroup.net ๐Ÿ”ฅ
April 2018
Submitting incomplete 510(k) applications results in RTA letters
2 min reading time

Most medical devices in the US today are marketed under the premarket notification 510(k) authorities of the U.S. Federal Food, Drug, and Cosmetic Act. In order to market some types of Class I and most types of Class II devices in the United States, you need to submit a 510(k) submission to FDA and receive FDA clearance.

FDA 510(k) applicants should ensure that their submissions meet RTA screening criteria to avoid RTA letters that can delay their US market commercialization plans. Just have a look on the below five key reasons provided to avoid the RTA letter:

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1. Failure to comply with FDA guidance: Applicants should adhere to recommendations listed in the agencyโ€™s guidance documents on formatting Traditional, Special and Abbreviated 510(k) submissions. Some device sponsors may not understand how to compile and format their 510(k) submissions.
2. Failure to supply an eCopy: FDA 510(k) applicants must submit an electronic (eCopy) of their 510(k) applications to the agency.
3. Failure to understand the difference between different types of 510(k)s: There are three types of premarket notification submissions: Traditional (most common), Special (less common) and Abbreviated (rare). Some applicants do not understand the differences between these types of 510(k)s and submit the wrong type.
4. Failure to identify FDA guidance applicable to your device: In their submissions, 510(k) applicants should identify FDA guidance documents if applicable to their devicesโ€™ specific product code. If such information has not been included in a submission, FDA reviewers will deem your submission lacking.
5. Failure to provide test data applicable to your device: Virtually all 510(k) applications submitted for FDA review must include some type of test data (e.g., electromagnetic compatibility (EMC), electrical safety, sterilization, biocompatibility, shelf-life, mechanical performance, etc.)

Submitting incomplete 510(k) applications results in RTA letters

source: https://www.linkedin.com/groups/78665/78665-6389260161084592129

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Posted by Joe Hage
Asked on April 10, 2018 12:00 am
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Monir EL AZZOUZI Hi Prasnya, thanks for your article really appreciate it. I had a similar review on my article on substantial equivalence for 510k. It's one of the main reason for rejection of it and people should be ready to master it also. https://tinyurl.com/y8xj4xr9
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Julie Omohundro Has FDA published data on the number of 510(k)s it has refused to accept for different reasons?
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No ma'am
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And how about the mistakes about a de novo classification request?
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Courtland Imel Edwin,
With De novos, I have seen the reviewers be more flexible.
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Julie Omohundro Are De novos subject to an RTA review?
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Julie Omohundro I think it is useful to distinguish among 1) mistakes that can be made, 2) mistakes that are commonly made, and 3) mistakes that most commonly lead to refusal. If FDA does not publish data on the reasons for refusal, I don't think anyone outside FDA has access to 2 and 3.

I also don't think data from the first couple of years of the program is necessarily applicable today. There was a learning curve for both FDA and industry. I think the reasons/probability for rejection may changed in the last year or two, as everyone started to get the hang of it.
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Dave Gaisser Good point on the learning curve, Julie. When first introduced, the eCopy was a regular issue for companies. Now it's more of a mistake if it causes an RTA. I've had two clients modify the eCopy I've provided them to "improve" it before submission. Oops!
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Dallas L. Thomas, RAC, MHA, MPA, SSYB, Certified Lead Audit Great insights. Thanks for sharing.
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