510(K) Modifications

CHPA supports FDA’s continued efforts to support medical device innovation by facilitating to the use of PCCPs for efficient Agency review of medical device modifications. When finalizing the Draft Guidance, CHPA strongly encourages FDA to provide further clarity regarding the content and process for PCCPs on several points.

CHPA strongly encourages FDA to provide further clarity regarding the appropriate human factors information in premarket submissions that involve a change from prescription use to over-the-counter use and associated changes from a predicate device as compared to modifications to a sponsor’s own device.

CHPA welcomes FDA’s efforts to modernize and streamline the process for creating and submitting 510(k) premarket notifications and generally supports the approach described in the Draft Guidance. However, CHPA recommends that FDA clarify the following key points when finalizing the Draft Guidance.

Enclosed herein are comments on "510(k) Device Modifications: Deciding When to Submit a 510(k) for a Change to an Existing Device: Public Meeting: Request for Comments".