Performance testing for a 510k submission case study (Part 2) explains the performance testing required for an FDA 510k submission.
Performance testing is an essential part of new product development and is usually the last section that you can complete before your submission. In my previous 510k case study article, I showed you how to research the FDA classification database to determine if there is a special controls guidance document to follow in the preparation of your 510k submission. The example I used was for topical adhesives (i.e., MPN). Topical adhesives do not have any Recognized Consensus Standards listed. Instead, all the performance testing requirements are specified in the special controls guidance document.
How to find performance testing requirements
In this case study article, I selected a different product code that has Recognized Consensus Standards, but it does not have a special controls guidance document. After identifying the device classification and product code, if there is no Special Controls Guidance, you need to plan your performance testing based upon other sources of information. If there is no Special Controls Guidance document, I use three methods for determining what performance testing is needed:
- Look for any device-specific standards
- Review other 510k summaries
- Order previous 510k submissions via FOIA requests
To learn more about creating a 510k test plan, please see our webinar on this topic.
For this case study, the product code selected was a bone fixation screw (i.e., HWC). The number of predicate 510k submissions to choose from for this product code is extensive. There are 29 from Arthrex alone. Some of these 510k submissions include a 510k statement, while others include a 510k summary. A statement is not directly helpful in identifying any of the performance testing that was used for the clearance of the potential predicate device. However, 21 CFR 807.93 requires that the company that submitted the 510k shall provide a redacted copy of the 510k submission within 30 days of the request. If this is requested early in your 510k project, you should have a copy of the submission in time to plan your performance testing for verification and validation of the subject device. You can also order predicate 510k submissions through the Freedom of Information Act (FOIA) request process.
In the case of a 510k summary, the summary indicates what performance testing was performed to demonstrate substantial equivalence. In the case of K103705, the section titled “Substantial Equivalence Summary” states that mechanical testing data for torque and pull-out testing was submitted for the subject device and the predicate device. Other 510k summaries may provide additional data or a more descriptive list of testing that was performed. In the case of this 510k example, there is a second product code listed: HRS, bone fixation plate. The HWC bone fixation screw product code indicates that there are 5 Recognized Consensus Standards:
- ASTM F2026-14 Standard Specification for Polyetheretherketone (PEEK) Polymers for Surgical Implant Applications
- ASTM F 897-02 (Reapproved 2013) Standard Test Method for Measuring Fretting Corrosion of Osteosynthesis Plates and Screws
- ASTM F1839-08 (Reapproved 2012) Standard Specification for Rigid Polyurethane Foam for Use as a Standard Material for Testing Orthopaedic Devices and Instruments
- ASTM F983-86 (Reapproved 2013) Standard Practice for Permanent Marking of Orthopaedic Implant Components
- ASTM F565-04 (Reapproved 2013) Standard Practice for Care and Handling of Orthopaedic Implants and Instruments
Only three of the above standards are included in the list of eight Recognized Consensus Standards related to the HWS product code. One of those eight standards should probably be covered under the HWC product code, as well:
Now you have a total of six different device-specific standards that can be used for planning the performance testing of your bone screw. This is significantly more helpful than a 510k summary that says torque and pull-out testing was performed. After you have ordered and reviewed each of the standards, you then create a list of performance tests that apply to your screw and create an overall verification and validation plan.
It is essential to perform this review each time, because there may be new or revised testing methods established as the Recognized Consensus Standards are updated. If you outsource testing, then you will need to obtain a quotation from a testing lab for each of the applicable tests.
Once you have created a comprehensive testing list, and you have quotations for all the testing required, you need to schedule the testing and ship samples to the testing lab. Once testing has begun, this is the best time to start the preparation of your 510k submission. Performance testing often takes several months to complete. If you start preparing the 510k before you have ordered the testing, then you are starting too early, and you may have to change your performance testing summary multiple times.
If you start your 510k preparation after you order your testing, then you can create the entire performance testing summary. The only information that you will be missing is the final report number for each test being performed. For the most part, you do not need the specific results of the testing, because the tests are designed to show that the subject device is “equivalent” or “not worse” in performance. Quantitative comparisons between your subject device and the predicate device are not allowed by the FDA for a 510k submission. Your subject device must be “equivalent” or “not worse than” the predicate device concerning safety and efficacy.
Additional 510k Training
If you enjoyed our this performance testing case study and you would like more 510k training, please search our website for more articles. We wrote a 510k book in 2017 when we first started hiring consultants to grow Medical Device Academy from an independent consulting business to a consulting firm. The book was called, “How to Prepare Your 510k in 100 Days.” Changes to the FDA 510k process have been rapid over the past 7 years, and the content is no longer relevant, but there is an on-line 510k course series consisting of 33 new FDA eSTAR webinars. You can also purchase our webinars individually.