This regulatory pathway case study is provided by Medical Device Academy for 510k submission, CE Marking application and Canadian Medical Device License application.
Manufacturers considering global expansion need to master the process of creating a regulatory pathway analysis. That analysis must be product-specific. I used to create long documents that were tedious to read, but in the past month I found a better way. I now use webinar recordings to help clients analyze the regulatory pathway for their products. I create a slides for each market that my client is considering for expansion. At the end of the 20-30 minute presentation, my client asks clarification questions and we discuss the possible next steps toward regulatory approval.
A Typical Regulatory Pathway Analysis
A typical regulatory pathway analysis involves 3 major markets for a new product: 1) USA, 2) Europe, and 3) Canada. There will be one slide per market identifying the classification rationale for each market, and if there are exceptions this will be explained. Exceptions often arise for specific indications for use, duration of contact and for unique components such as:
Recommended Regulatory Pathway Document Content
There will be a slide per market identifying the regulatory approval process. For devices without predicates, this will be a De Novo application or a PMA submission in the USA. For Canada, you might need an Establishment License or a Medical Device Distribution License.
There will be a slide per market identifying QMS requirements customized to reflect the QMS my client already has. If you already have ISO 13485 certification you only need 2-3 new procedures to launch in Canada, while there are typically more procedures required for launching a product in the USA due to differences between ISO 13485 and 21 CFR 820. Even in Europe, a Japanese company will need: 1) a vigilance reporting procedure, changes to their Advisory Notice Procedure, and 3) a procedure for creating a technical file.
Finally, most clients need help identifying the testing requirements for safety and efficacy. If the FDA has a recent special controls guidance this is much easier. If guidance is non-existent or outdated, then you need experts like Leo to help navigate international and European National (EN) Standards that might be applicable for safety and efficacy testing.
Regulatory pathway case study
In 2015 I published a series of three blogs explaining how to identify the regulatory pathway for different markets:
- CE Marking Approval of a Medical Device (Case Study)
- 510k Submission to the FDA (Case Study – Part 1)
- Obtaining a Health Canada Medical Device License (Case Study)
The blogs were specific to a hypothetical product–a tissue adhesive for topical approximation of skin. Therefore, I decided to use the same hypothetical product for this case study regulatory pathway. If you are interested in watching a recording of this regulatory pathway, click here to download the case study recording.
Are you planning a submission in 2016?
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