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US FDA 510K
A 510k is a premarket submission made to FDA that demonstrates the device to be sold is as safe and effective, that is, substantially equivalent, to a legally marketed device. A technical file, known as 510(k), needs to be submitted to the FDA for devices meant to be used on humans.
A 510(k) submission must be made for devices that do not need a Premarket approval (PMA) and are not exempt from the 510(k) requirements by manufacturers of medium-risk medical devices or IVD who wish to market their devices in the U.S. The 510(k) submission or premarket submission includes technical, performance and safety information about the medical device.
An FDA 510k is required for introducing most Class II medical devices, some Class I and Class III devices and IVDs in the U.S. market, a 510(k) submission needs to be made by
The Premarket approval (PMA) is the regulatory pathway chosen for class III devices used to sustain/ support human life and present substantial risks. This method is used to prove the safety and performance of a new medical device using data obtained from laboratory testing and clinical trials with human participants in most cases.
How to approach FDA for FDA 510k Approval?
The medical device 510k process consists of the following steps:
FDA will send a confirmation whether the submission is accepted for review in about 2 weeks. The evaluation of substantial equivalence by the FDA generally takes 90 days and is based on the information found on the data submitted. But, it may take longer if a Refuse-to-Accept or Additional Information letter is issued, the reply to which needs to be submitted within 180 days.
Once the review is completed successfully, a 510(k) clearance letter with a unique 510(k) number for the device will be sent by the US FDA, along with a copy of the device’s approved Indications for Use.
A 510(k) clearance is the status granted by the US FDA to a medical device at the end of the review of the premarket or 510(k) submission if the manufacturer can successfully establish that the device undergoing review is at least as safe and effective as the chosen predicate device. A clearance letter with a unique 510(k) number for the device along with a copy of the device’s approved Indications for Use will be sent by FDA once 510(k) clearance is obtained. The manufacturer can then legally market the device in the US.
How do I file a 510k with FDA?
To file the 510(k) submission with FDA, the following steps will have to be followed:
FDA 510k Approval Process
service related FAQ’s
The 510(k) file includes documents used to establish the safety and efficiency of the proposed medical device through substantial equivalence. The documents included in the 510(k) file are:
- Form FDA 3601: Medical Device User Fee Cover Sheet (MDUFC sheet)
- FDA Form 3514- CDRH Premarket Review Submission Cover Sheet: This document includes basic administrative and device information.
- 510(k) Cover Letter: This document provides a brief idea about the purpose of the submission, device, manufacturer and the U.S agent (if any).
- FDA Form 3881: Indications for Use Statement
- 510(k) Summary or 510(k) Statement: This includes a summary of the device undergoing the 510(k) clearance.
- Truthful & Accuracy Statement: This is to certify that the 510(k) submission contents are truthful and accurate and no information omitted.
- Class III Summary and Certification: If the proposed device is a Class III exempt from PMA, otherwise, this can be marked as not applicable.
- Financial Certification or Disclosure Statement: This is applicable only if clinical studies were conducted
- Declarations of Conformity and Summary Reports: Lists the voluntary consensus standards used and includes DOC to such standards.
- Device Description: This document includes the description of the device design requirements and performance specifications.
- Executive Summary: a brief description of the device & comparison table with the predicate device identified.
- Substantial Equivalence Discussion: Detailed comparison between the proposed device and the predicate device chosen.
- Proposed Labeling: Is discussed in detail to comply with 21 CFR 807.87(e) for general medical devices and 21 CFR 809.10 for IVD’s
- Sterilization and Shelf Life: This document provides details regarding the sterilization and shelf life claim being made.
- Biocompatibility: This document is applicable if the proposed device comes into direct or indirect contact with the human body tissue.
- Software: This includes the documentation for any software used in the proposed device
- Electromagnetic Compatibility and Electrical Safety- If the proposed device is powered electrically, in which case the EMC must be evaluated.
- Performance Testing – Bench: This document included details of the bench tests performed to evaluate the efficiency of the proposed device.
- Performance Testing – Animal: This document included details of the animal testing performed to evaluate the efficiency of the proposed device.
- Performance Testing – Clinical: This document included details of the clinical studies performed to evaluate the efficiency of the proposed device.
The completed FDA 510(k) file is submitted in electronic format as an e-copy to the FDA. The submission package is sent to the CDRH through registered mail or commercial delivery service.