PDF Classification Overview
[Pages:31]Classification Overview
FDA Small Business Regulatory Education for Industry (REdI)
Silver Spring, MD September 29, 2015
William M. Sutton
Deputy Director Division of Industry and Consumer Education
Office of Communication and Education Center for Devices and Radiological Health
U.S. Food and Drug Administration
Learning Objectives
? Understand the history and terminology associated with device classification
? Identify and describe the three classes of devices
? Describe general controls and special controls ? Search the product classification database
2
Classification History
May 28, 1976 ? Medical Device Amendments ? Section 201(h) of Federal Food, Drug &
Cosmetic Act (FD&C Act)
? Provides definition of a medical device
? FDA classification panels conducted initial classification of preamendments medical devices, i.e., Class I, II, III
? Initial classification completed in mid-1980s
3
A medical device is...
Section 201(h) of the FDCA defines a medical device as any product that does not achieve its purposes by chemical action or metabolization.
? As simple as a tongue depressor
? As complex as robotic surgery devices
. 4
What is a Preamendments Device?
? In commercial distribution before May 28, 1976
? Preamendments Class III devices require premarket approval (PMA) after FDA publishes regulation in the Federal Register (FR)
? Preamendments Class III devices may require premarket notification [510(k)], i.e., until FDA publishes a regulation
5
What is a Postamendments Device?
? First distributed commercially on or after May 28, 1976
? Automatically classified as Class III PMA, until FDA publishes a regulation
? Equivalent requirements to preamendments Class III devices, e.g., PMA or 510(k)
6
What is a Transitional Device?
? Regulated as new drug before May 28, 1976, e.g., intraocular lenses
? Any Class III transitional device now regulated as a PMA
? FDA application number begins with letter "N" ? Some have been downclassified to Class II
7
Is my Product a Device?
? If unable to determine if product meets the definition of a medical device, may seek FDA advice.
? Contact CDRH Office of Compliance by email at: DeviceDetermination@fda.
? Provide product description, draft labeling, and intended use
Device Advice Reference:
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