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US FDA Launches a Pilot Program for Modular 510(k) Submissions

In 510(k), Design Verification, Medical Device, Novelblogg, US FDA on June 28, 2012 at 8:22 am

Sorry if you feel mislead, but this is a regulatory fantasy. I thought I would experiment with something different to celebrate 5,000 views! I call it a novelblogg. I should probably trademark the term but that’s just nonsensetalk. I hope you enjoy the music video selection this week, because listening to The Smiths never goes out.

April 2013

Jim, the Director of Engineering at The Cat’s Meow (TCM), bumps into Caroline in the hallway as they both rush to the board room for a surprise meeting with the CEO. Caroline is the Director of QA/RA, and Steve is the CEO.

“Caroline, do you know what the meeting is about?”

“No, but I’m sure it must be related to AAOS. Steve has been pissed ever since he got back from the show.”

Steve enters the conference room with a stack of handouts which he hands to Caroline and asks her to pass the stack around to the rest of the group.

“Thank you for being on-time everyone. I have important news related to The Bees Knees [TBK], and I want everyone to take this information back to their individual teams after this meeting. TBK had a small group of orthopedic surgeons in one of the private meeting rooms at the show. One of these surgeons is friendly to TCM, and they were kind enough to give us the inside track. [pause] TBK is developing a new metal-on-ceramic total knee system, and they plan to launch it at AAOS next year.”

Jim made a low whistle, and Caroline said, “None of the ceramic materials cleared by the FDA could withstand impact from a metal femoral implant. Is it a new material?”

“Great question Caroline. I have been researching that question ever since I got back from AAOS and I finally discovered which material they are using. The femoral component is titanium with a nitride coating, and the tibial component is a single piece of ceramic with a nano-coating. The combination was invented by a start-up company developing a new ceramic wheel bearing, but the company went out of business. They never followed-up their provision patent with a patent application. Now the material has no patent protection and TBK has already started their verification testing.”

“Who’s selling the ceramic?”

“I can’t be 100% certain, but I think the original company supplied TBK with prototype samples for durability testing. Now they are developing an in-house casting process. The chemist I spoke with believes that the nano-coating is a special mold release agent that becomes fused with the ceramic when they sinter the parts in a vacuum furnace.”

“So what’s our counter attack?”

“That’s why you are all here. I was hoping the team might have some ideas for a new product we can launch by next year’s AAOS meeting. In order to launch by AAOS, we need to submit the 510(k) by when Caroline?”

“Well…actually the FDA just announced a pilot program for 510(k) submissions using a new software system. They promise it will dramatically reduce review timescales, but I don’t have any details yet. I already took the on-line training webinar, and I received a password to the beta version of the software. Pilot programs are risky, but this might be the only way we could catch TBK.”

“Jim, what would we need to change about the Orion Knee in order to adapt it for use with a ceramic tibia?”

May 2013

Caroline and Jim have a pre-submission conference call with an FDA reviewer involved in the pilot program.

“Jim and I were reading through the guidance documents you sent to us, and we were hoping you could explain the optional modular submission pathway to us.”

“Sure Caroline. The FDA’s PMA process has a modular submission pathway as well. This was the basis for the modular 510(k) pilot process. The intent was to allow companies to define the content of the submission up-front and allow the company to submit modules as they are completed instead of waiting until all testing is completed.”

“The durability testing of our ceramic tibial component is expected to be the last verification testing protocol that we complete. Can we submit this as a separate module?”

“Exactly. Shelf-life and durability testing is typically the last testing completed prior to submission. Since these tests have well-defined ASTM test methods, I can assign a reviewer independent from the other modules. You mentioned that this ceramic component will be cast and then sintered in a vacuum furnace to create the nano-coating?”

“Yes, that’s our plan.”

“Make sure you use production material rather than production equivalents for the durability testing. The FDA cannot accept verification data for ceramics based upon prototype material. This has resulted in recalls and adverse events for other ceramic implants.”

“That could be a problem. Jim tells me that we will have twenty different size castings, and the process validation won’t be completed on all the sizes prior to the start of our durability testing.”

“Have you identified which size casting represents the worst-case device?”

“Yes. The smallest size is the thinnest and will therefore be the most susceptible to damage. Therefore, we plan to use this for our verification testing.”

“That’s good, but you will also need to demonstrate that the samples used were made under conditions that are validated to produce the weakest implant such as the extreme high or low temperature in your process range.”

“We have determined that the sintering process is the most critical factor in producing a strong implant. At lower temperatures the sintering is not sufficient to produce a dense implant and the implants are sometimes brittle. At higher temperatures, the sintered implant is nearly indestructible.”

“You will need to provide some preliminary data to this affect before I can agree to using implants sintered at the lower temperature limit, but this seems like an appropriate solution.”

“Can we submit the verification protocol along with the preliminary data in order to get the FDA’s acceptance of the durability testing protocol?”

“Yes, you should submit the protocol and the preliminary data prior to submission of that module. I will assign a reviewer with expertise in ceramics to ensure that the protocol and data are reviewed thoroughly.”

June 2013

Caroline and Jim submit the protocol and preliminary data to the reviewer. The reviewer identifies a problem with the protocol. The force chosen for cyclic testing simulates the average theoretical weight of a person walking down a flight of stairs. However, the reviewer indicates that adverse event trends for ceramic implants indicate that most of the device failures occur with heavier patients walking down stairs. Therefore, the reviewer indicates that the force should simulate the 99th-percentile of weight for an adult male walking down stairs. Jim decides to repeat finite element analysis (FEA) with the higher force requirement. The FEA report indicates that implants sintered at the lower temperature may not be thick enough for this force. Therefore, Jim has to modify the casting mold for the four thinnest implant molds. The smallest was sent back to the manufacturer to be modified first and the testing protocol was updated.

July 2013

The revised casting for the smallest implant was received and implants were sintered at the lower limit of the temperature range for sintering. The protocol was executed in early August and the duration is 104 days. Therefore, the final report and module should be completed just before Thanksgiving 2013.

In parallel with TCM’s durability testing, TBK is conducting its own durability testing on prototype material, because the process validation of the new casting is not completed. Their regulatory director has drafted a rationale for use of production equivalents, but there has been no discussion with the FDA regarding TBK’s traditional 510(k) submission. Therefore, no reviewer is identified and no sections of the submission will be reviewed until all testing is completed in October.

September 2013

TCM receives confirmation that all submitted modules have been cleared by the FDA—including labeling and other marketing materials. The initial marketing content included a claim that the new metal-ceramic material “lasts longer than conventional UHMW polyethylene implants.” The FDA reviewer, however, would not allow comparison statements in the marketing literature because the 510(k) process only allows for substantial equivalence. Caroline and the Director of Marketing spoke with the reviewer directly the Tuesday after Labor Day. The Director of Marketing asked if it would be acceptable to share side-by-side video of the durability testing that is in progress with a caption that states “TCM’s new metal-ceramic materials are ‘not inferior’ to TCM’s current UHMW polyethylene implants.” At the time of the question, the metal-ceramic materials were showing almost no signs of wear, while the UHMW polyethylene implants were showing signs of creep and pitting on the polished surface. By the end of the verification testing, everyone expected catastrophic failure of the UHMW polyethylene implants. “Not Inferior” would be a gross understatement, but an accelerated video demonstration of the 104-day study would be more powerful than words or pictures.

TBK has all of the sections of their 510(k) submission ready—with the exception of the durability testing.

October 2013

TCM is waiting to complete the durability testing. TBK hires a courier to deliver the 510(k) submission on October 22, 2013.

November 2013

TCM has delays in compiling the final durability report, and the submission of the final module is not until Tuesday, December 2, 2013.

TBK has not received any questions regarding the submission yet.

December 2013

TCM receives a 510(k) clearance letter on Friday, December 19—only 17 days after submission of the final module.

TBK’s Director of Regulatory Affairs receives a request for data demonstrating that the prototype ceramic material used for durability testing represents worst-case for durability testing.

January 2014

TCM’s 510(k) letter is posted on the FDA website the first week of January. TBK’s regulatory director is fired the second week of January.

March 2014

AAOS is a huge success for TCM. TBK does not exhibit at AAOS in 2014.

Q2 2014

TCM sets an all-time quarterly sales record. Caroline and Jim get big bonuses. TBK receives a 510(k) letter on June 23, 2014—244 days after submission. The new Director of RA starts work on at TBK on the same day. The person is already trained on the new modular 510(k) submission process and received their first 510(k) letter using the pilot process in January.

The Smiths Collage

You can find the original at: http://www.layoutsparks.com/pictures/smiths-0. Thank you for sharing.

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  1. […] US FDA Launches a Pilot Program for Modular 510(k) Submissions (13485cert.wordpress.com) 37.398730 -122.071465 Rate this:Share this:EmailDiggTumblrRedditFacebookLinkedInTwitterStumbleUponPrintPinterestLike this:LikeBe the first to like this. This entry was posted in Biotechnology and life sciences, Digital strategy, E-learning and change management, Government and regulatory affairs and tagged Business, Business Services, California Institute of Technology, Consulting, Harvard University, Master's degree, Medical and Life Sciences, Nature Biotechnology, Office of Information and Regulatory Affairs, Regulatory affairs by timbatchelder. Bookmark the permalink. […]

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