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what does MDUFA stand for?
Medical Device User Fees Amendment
What is MDUFA"?
Price list of fees med device comp have to pay FDA
Use: when register/list or submit application to bring device to market
how does CDRH define small business?
net income less than $100 million
Safety Assurance Case
Living doc
has all risk management activities
‘safety story’
what is a claim for a Safety assurance case?
claim: all reasonable foreseeable hazards have been identified
includes risk mitigation and evidence
what does FTA stand for?
fault tree analysis
what is FTA used for?
see undesired state of a system
basic event
failure or error in a system component or element (example: switch stuck in open position)
External event
normally expected to occur (not of itself a fault)
undeveloped event
an event about which insufficient information is available, or which is of no consequence
conditioning event
conditions that restrict or affect logic gates (example: mode of operation in effect)
OR gate
output occurs if any input occurs
AND gate
the output occurs only if all inputs occur (inputs are independent from the source)
exclusive OR gate
output occurs if exactly one input occurs
Priority AND gate
output occurs if the inputs occur in a specific sequence specified by a conditioning event.
inhibit gate
output occurs if the input occurs under an enabling condition specified by a conditioning event
what does FMEA stand for?
Failure Mode Effects Analysis
what is FMEA?
risk assessment
goal is to mitigate/eliminate failure
failure mode (FMEA)
way or mode in which something fails.
effects analysis (FMEA)
studying the consequences of those failures
Why does MDUFA change over time?
The intention is to give FDA funds to hire adequate staff
fees increase when there is more demand
Traditional 510(k)
used for any original 510(k)
for a change to a previously cleared device under 510(k)
who submits a Special 510(k)?
Device manufacturers
Special 510(k)
submit for changes to their own existing device if the method(s) to evaluate the change(s) are well-established
the results can be sufficiently reviewed in a summary or risk analysis
what type of device not appropriate for a special 510(K)?
biological products
3 reasons why design/label change for existing device is approp. for special 510(k)?
change submitted by the manufacturer
performance data unnecessary/necessary has well established methods for evaluating change
all performace data can be reviewed in a summary or risk analysis format.
when is Abbreviated 510(k) use?
FDA guidance docs
shows compliance with special controls for device type
voluntary consensus standard
note
510(k)s are characterized as the easy, short, less complicated pathway to market