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Validation of Certain In Vitro Diagnostic Devices for Emerging Pathogens During a Section 564 Declared Emergency: Draft Guidance for Industry and Food and Drug Administration Staff

DraftCenter for Devices and Radiological Health,Office of Product Evaluation and Quality,Office of In Vitro Diagnostics and Radiological Health01/06/2025

Description

FDA plays a critical role in protecting the United States from threats such as emerging infectious diseases and public health emergencies. This draft guidance describes general recommendations for the validation of in vitro diagnostic devices (IVDs) for emerging pathogens during an applicable declaration under section 564 of the Federal Food, Drug, and Cosmetic Act (FD&C Act). These recommendations apply to test data and information submitted in a pre-Emergency Use Authorization (EUA), an EUA request, or to a test offered under an applicable enforcement discretion policy. Ageneric templateis also being made available through download from FDA’s website, which reflects FDA’s current thinking on validation study recommendations.

Scope & Applicability

Product Classes

8
In Vitro Diagnostic Devices

Validation of certain in vitro diagnostic devices (IVDs) for emerging pathogens; Validation of certain IVD devices for emerging pathogens

Home Use Tests

Tests performed and interpreted by individuals in non-laboratory settings.

Multi-Analyte Panels

Tests that can detect and differentiate between pathogens causing multiple diseases with similar symptoms.

Lateral flow immunoassay tests

FDA has observed significant cross-reactivity with different brands and types of VTM

Antigen-based tests

Inclusivity of antigen-based tests should be evaluated through wet testing

Home Collection Kits

Specific test type considered in the guidance; Kits for home collection of clinical specimens to increase patient access.

Point-of-Care Tests

Specific test type considered in the guidance; Tests intended for use in near-patient settings like hospitals or urgent care.

In Vitro Diagnostic Device

IVDs for emerging pathogens during a Section 564 declared emergency

Stakeholders

4
Test Manufacturer

Entity responsible for conducting validation studies

Lay user

Untrained individual performing home collection or home testing.

Lay users

Participants in usability and user comprehension studies

Institutional Review Board

Governs top dose in clinical studies

Regulatory Context

Attributes

5
Cybersecurity

Protection of software and device data

Shelf life

Determined by the sponsor for the investigational product.; investigational product(s) are stable over the period of use and only used within the current shelf life

Specimen Stability

The stability of specimens collected and stored should be evaluated in real-world conditions

Analytical Sensitivity

The LoD provides a measure of the analytical sensitivity

Highly Sensitive Comparator

Method used to evaluate the performance of the new test

Identified Hazards

Hazards

5
Emerging Pathogens

Pathogens triggering a Section 564 declared emergency

Toxicology

Components of collection kits should be assessed for toxicological risk.

Cybersecurity

Risk of device functionality being compromised

Cross-Contamination

automated liquid handling systems can pose a risk of contamination within or between test runs

High-Dose Hook Effect

The high-dose hook effect, where false negative results occur due to the presence of very high levels of the target analyte

Related CFR Sections (2)

Related Warning Letters (10)

  • CGMP/QSR/Medical Devices/Adulterated

    Envoy Medical Inc.

    2025-12-09
  • CGMP/QSR/Medical Devices/Adulterated

    Hong Qiangxing Shenzhen Electronics Limited

    2025-11-25
  • Clinical Investigator

    Shirish M. Gadgeel, M.D.

    2025-09-09
  • CGMP/QSR/Medical Devices/Adulterated

    Spectra Therapy, LLC

    2025-08-12
  • CGMP/QSR/Medical Devices/Adulterated

    Mectronic Medicale S.R.L.

    2025-08-05
  • Clinical Investigator

    Mark J. Savant, M.D

    2025-07-15
  • CGMP/QSR/Medical Devices/Adulterated

    Aju Pharm Co., Ltd.

    2025-06-24
  • CGMP/QSR/Medical Devices/Adulterated

    Sedecal S.A.

    2025-05-27
  • CGMP/QSR/Medical Devices/Adulterated

    NeuroSync, Inc.

    2025-05-20
  • Bioresearch Monitoring Program/Institutional Review Board (IRB)

    United Health Products, Inc.

    2025-05-20

See Also (8)

Validation of Certain In Vitro Diagnostic Devices for Emerging Pathogens During a Section 564 Declared Emergency: Draft Guidance for Industry and Food and Drug Administration Staff | Guideline Explorer | BioRegHub