• where experts go to learn about FDA
  • Adrienne R. Lenz, Principal Medical Device Regulation Expert

    • How Many Hours are Really in a Day?December 3rd, 2024

      We recently blogged on FDA’s draft guidance, Chemical Analysis for Biocompatibility Assessment of Medical Devices, which describes chemical characterization methods that may be used to demonstrate biocompatibility of a medical device as an alternative to conducting certain biological testing.  We noted that the draft guidance’s …

    • New Draft Guidance Provides Detailed (and Burdensome) Recommendations for Chemical Assessments to Support Medical Device BiocompatibilityNovember 20th, 2024

      FDA recently issued a draft guidance, Chemical Analysis for Biocompatibility Assessment of Medical Devices, which describes chemical characterization methods that may be used to demonstrate biocompatibility of a medical device as an alternative to conducting certain biological testing.  Chemical characterization identifies and quantifies chemicals that …

    • Indeterminate Change: FDA Releases Draft Guidance on Predetermined Change Control Plans for Medical DevicesOctober 3rd, 2024

      A recent draft guidance on predetermined change control plans (PCCP) for medical devices continues FDA’s effort to implement Section 515C of the Food and Drug Omnibus Reform Act of 2022 (FDORA),   which Congress enacted to make it easier for manufacturers to make post-market device changes …

    • Days Go By* – Particularly When Responding to an FDA InspectionSeptember 13th, 2024

      While we hope readers of the Blog, as our clients and friends, come out of any FDA inspection with a clean bill of health, we know that based on FDA FY2024 data to date, approximately 40% of inspections of medical device companies end up classified …

    • FDA Releases Draft Guidance on Essential Drug Delivery OutputsJuly 24th, 2024

      For several years, FDA has requested that sponsors of drug or biologic led combination products identify essential performance requirements (EPRs) related to the device constituent in their applications.  EPRs were usually requested in the context of design controls, although 21 C.F.R. § 820.30 does not …

    • Power to the Patient with Patient Generated Health DataJuly 11th, 2024

      FDA’s Center for Devices and Radiological Health (CDRH) recently partnered with the Digital Medicine Society (DiMe) to host a two-day workshop to help advance the use of patient-generated health data (PGHD) to support improved clinical trials, medical device development, and regulatory science.  The workshop included …

    • PreSTAR: a New Template for Pre Submissions and 513(g) Requests for InformationJune 27th, 2024

      FDA recently released a new eSTAR template for device pre-submissions and 513(g) Requests for Information, referred to as PreSTAR.  A pre-submission provides the submitter an opportunity to obtain FDA feedback prior to a planned medical device premarket submission.  A 513(g) Request for Information is a …

    • Women’s Health a Focus for FDA and Biden AdministrationJune 2nd, 2024

      FDA’s Office of Women’s Health (OWH) recently celebrated its 30th anniversary.  This office was formed in 1994 to promote the inclusion of women in clinical trials and to provide leadership on topics related to the health of women.  Given that FDA was founded in 1906 and …

    • Can a Device Be Found Not Substantially Equivalent Because of Cybersecurity Risks? A Review of FDA’s Draft Guidance on Cybersecurity in Medical DevicesMay 7th, 2024

      FDA recently issued a draft guidance which would update the agency’s Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions guidance.  The draft guidance provides recommendations on what is required to meet cybersecurity obligations under section 524B of the Food, Drug and …

    • Feeling the Heat (or Cold) – New Draft Guidance Addresses Requirements for Devices that Produce Thermal EffectsMarch 19th, 2024

      FDA recently issued a draft guidance, Evaluation of Thermal Effects of Medical Devices that Produce Tissue Heating and/or Cooling (link), which describes information to include in a marketing application to support the evaluation of thermal effects of medical devices that produce local, regional, and/or systemic …

    • Bad Labs! Bad Labs? Whatcha Gonna Do?March 12th, 2024

      On February 20, 2024, FDA issued a letter to the medical device industry (link) warning medical device firms of recent FDA concerns related to fraudulent and unreliable laboratory testing data in premarket submissions.  Unfortunately, the letter provides little new information to guide industry conduct.  While …

    • FDA Releases Final Guidance on Use of Digital Health Technologies for Remote Data Acquisition in Clinical InvestigationsFebruary 9th, 2024

      As an end of the year gift, FDA finalized its guidance document, Digital Health Technologies for Remote Data Acquisition in Clinical Investigations, in late December. We previously blogged on the draft guidance (here) and on FDA’s broader framework for Digital Health Technologies (DHT) (here and …

    • A Question 30 Years in the Making: Would a Final LDT Rule Withstand Judicial Scrutiny?November 2nd, 2023

      For more than three decades, FDA has claimed that the Federal Food, Drug, and Cosmetic Act (FD&C Act) gives the agency legal authority to regulate laboratory developed tests (LDTs) as medical devices (see our prior post here).  In this post, we summarize the purported basis …

    • When Should a 510(k) Include Clinical Data?October 18th, 2023

      Although it seems not widely known outside of the medical device industry, FDA can require sponsors to include clinical data as part of a 510(k) submission.  Such data may be needed to demonstrate substantial equivalence to a previously-marketed predicate device or, less frequently, to show …

    • 510(k) Modernization 2023September 12th, 2023

      On September 6, 2023, FDA announced its latest efforts to modernize the 510(k) process, outlining FDA’s latest improvements to strengthen the 510(k) Program and announcing release of three draft guidance documents.  This announcement addresses one of the commitments in FDA’s Medical Device Safety Action Plan: …