FDA and Internationally Regulated Medical Devices
Frequently Asked Questions
is
vested with statutory authority to protect and enhance the public
health. The original Food and Drugs Act establishing the FDA was
passed by Congress on June 30, 1906 and signed by President Theodore
Roosevelt. It prohibits interstate commerce in misbranded and
adulterated foods, drinks and drugs.
The FDA is responsible for protecting the public health by
assuring the efficacy, safety, and security of food, drugs,
biologicals , medical devices, animal feed and drugs, cosmetics,
and products that emit radiation.
FDA's Center for Devices and Radiological Health (CDRH) is
responsible for regulating companies that manufacture, repackage,
re-label, perform specified processes, and/or import medical
devices sold in the United States.
Foreign establishments that export devices into the United
States are also required to list their devices with FDA and
are subject to on-site inspections. The CDRH also regulates
radiation-emitting electronic products (both medical and non-medical)
such as lasers, x-ray systems, and ultrasound equipment.
FDA classifies medical devices into three regulatory categories—class
I, II, and III—each of which depends on the level of regulatory
control necessary to assure safety and efficacy.
- Class I devices are subject to minimal requirements including
Good Manufacturing Practice (GMP) and other general controls.
- Class II devices must comply not only with general controls,
but also with any applicable performance standards developed
to assure safety and efficacy.
- Class III devices are subject to Premarket approval in addition
to general controls; generally these are life sustaining or
life supporting devices such as implants.
You can read more about device classification and link to the
Product Classification Database by visiting the FDA official government
website:
http://www.fda.gov/cdrh/devadvice/313.html.
There are basic regulatory requirements with which manufacturers
of medical devices distributed in the United States must comply.
They include:
- Submitting a Premarket notification 510(k), unless exempt,
or Premarket approval (PMA)
- Registering establishments with FDA
- Achieving a medical device listing by FDA
- Complying with the quality system (QS) regulations
- Meeting labeling requirements including directions for
use
- Maintaining complaint records and follow-up investigations,
as well as adhering to the medical device reporting (MDR)
process
No. Compliance with FDA regulations goes a long way toward
preparing your organization to meet the ISO quality system standard
for medical devices, namely ISO 13485. However, for organizations
distributing medical devices in the United States, whereas ISO
conformance is voluntary, FDA regulations are law and take precedence.
There are differences between the regulations and the standard
that are significant enough to require independent attention.
For example, ISO 13485 requires continual improvement as a
formal process whereas FDA has no such requirement.
These differences remain despite significant activity in North
America, Europe, Japan, and other countries toward harmonizing
standards and regulations governing medical devices.
As a recognized leader in FDA compliance, STAT-A-MATRIX has
been involved in this type of training and consulting for many
years.
While our work with each client remains strictly confidential,
the strategies and tactics we have developed can provide your
organization with the guidance, understanding, and tools you
need to effectively and efficiently achieve FDA compliance and
ISO conformity.
In fact, the STAT-A-MATRIX 14-step implementation process is
applicable to companies seeking compliance with the FDA's Medical
Device Quality System Regulation as well as to ISO 13485 registration.
STAT-A-MATRIX has programs and consulting capabilities to help
guide all types of organizations through the often overwhelming
maze of regulatory compliance and standard certification requirements.
Our highly experienced consultants—most of whom have
been through this process in the corporate world themselves—understand
and address individual needs within small and large organizations.
STAT-A-MATRIX works with Fortune 500 companies to sharpen skills
and capabilities, providing experts in specific subject areas
as needed, as well as to educate and inform their new employees.
Likewise, STAT-A-MATRIX works with start-up companies to jump-start
their programs and cost-effectively address new initiatives.
FDA's Center for Devices and Radiological Health (CDRH) has
created cross-cutting collaborative product groups to better
integrate Premarket, post-market and enforcement efforts.
The Center is pursuing the development of unique identifiers
(UDI) for medical devices, in collaboration with industry and
health care providers, in order to easily identify specific
devices when post-market questions are raised. CDRH also is
considering making electronic reporting of adverse event data
mandatory ("eMDR").
STAT-A-MATRIX is continually involved in the development and
interpretation of regulations facing the medical device industry.
FDA continually reviews its programs and annually publishes
new regulatory initiatives and goals based on its oversight
experience and Congressional input.
Staying linked to STAT-A-MATRIX programs and consultants is
an effective means of staying on top of the ever-changing regulatory
environment.
There are several changes to FDA's inspection approach. One
important area for device manufacturers to better understand
is the quality system inspection technique (QSIT) for evaluating
device manufacturers’ compliance.
QSIT is a “top-down” approach that focuses on key
control elements or subsystems of the regulations, including
management controls, design controls, corrective and preventive
actions (CAPA), and process controls. Understanding this inspectional
technique can help you determine the best approach to compliance
for your organization. STAT-A-MATRIX has the experience and
resources to guide you in this area.
Awareness is growing in the medical device industry that organizations
not only need to know how to comply with regulations and standards,
but how to integrate the regulations and standards into value
-added business processes.
To that end, STAT-A-MATRIX provides guidance in designing customized
processes and compliance pathways, which support your business
goals.
For instance, we emphasize process models that link the compliance/conformance
needs with business activity-interface management and control
systems.
Another strategy is tying together the various elements of
a robust quality management system with the methods to monitor,
control, and sustain those elements.
And still another approach is to align problem solving and
project management linked to compliance activities.
STAT-A-MATRIX offerings are comprehensive and robust. They
include—but are not limited to—programs in the following
areas:
- FDA’a medical device regulations
- FDA quality system inspection techniques
- Process and software validation
- Risk management and analysis
- Design control and management
- ISO 13485 Implementation
- ISO 13485 and ISO 9001 internal and leader auditor certification
training
- CAPA (Corrective Action/Preventive Action) for the medical
device industry
Customized consulting services, auditing and documentation review,
are also available to meet the specific needs of your organization.
For more information on Medical Device offerings, click
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