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CPG Sec. 320.100 Ear Piercing Devices

FinalCenter for Devices and Radiological Health Office of Regulatory Affairs09/23/1987
Good Guidance Practicessoftware validationgood laboratory practicesData integrityGood Manufacturing Practices

Description

For the past several years it has been the Food and Drug Administration's position that articles intended to be used for ear-piercing were devices which should be restricted to prescription dispensing in accordance with 21 CFR 80l.l09. The Food and Drug Administration has attempted to regulate such devices on an ad hoc basis, but this has not resulted in any broad compliance by the industry.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

3
in vitro diagnostic devices

Devices compared to reference methods or gold standards

cytology devices

The emphasis is on FDA's particular concerns in the review of cytology devices for gynecologic specimens.

Cervical Cytology Devices

Subject of the points-to-consider document; Guidance document title and subject of clinical study requirements; The primary subject of the guidance document.; Subject of the guidance document regarding points to consider for regulatory submission.

Stakeholders

3
Sponsor

Entity responsible for submitting applications under section 524B

cytotechnologist

Role responsible for screening specimens; Laboratory professional involved in screening and interpreting slides.

pathologist

professional who views the image on a computer monitor to arrive at a diagnosis

Regulatory Context

Regulatory Activities

4
premarket submission

Regulatory filing such as a 510(k) or PMA submitted to the FDA.; Submission including ASCA testing results

510(k)

Premarket notification submission type

Investigational Device Exemption

A medical device submission type (IDE).

PMA

Premarket Approval Application

Document Types

4
Points to Consider: Cervical Cytology Devices

This points-to-consider document supplements existing FDA guidance for premarket submission of in vitro diagnostic devices.

study protocol

Definitions, algorithms, and data elements should be included in the study protocol.

Clinical Studies

Section of the guidance detailing study design requirements

IRB-approved written protocol

Required documentation for using negative archival slides

Attributes

5
Stability

A functional role of sodium in food

workload limit

Evaluation required for all gynecologic cytology devices submitted for FDA approval.

Clinical sensitivity

the biomarker's clinical sensitivity, specificity, and positive and negative predictive values should be well characterized

Clinical specificity

used to inform the choice of a biomarker cutoff

Disease prevalence

Required data for pediatric population estimates

Technical Details

Testing Methods

9
Real-time studies

Provide real-time studies from three different manufacturing lots which include data to demonstrate the stability.

Pap test

Conventional methodology used as a baseline for comparison with new devices.

manual microscopy

Used to verify abnormal cells identified by computer-assisted devices.

Pap smear

Conventional method used as a reference or basis for sampling; Conventional reference method for cervical screening

Computer-assisted Pap test reading

Automated method compared against manual reading

Statistical significance testing

Required analysis for ordinal classification data

Cervical biopsy

A reference method for accuracy, though less than a gold standard.

Colposcopy examination

A method used for confirmation of cytology results.

Masked manual microscopy

Acceptable surrogate reference method for specimen accuracy.

Processes

4
Colposcopy

women with ASC-US cytology from Ob/Gyn clinics will proceed to colposcopy; send a subset of those women to colposcopy

sample preparation

In vitro methods for product quality and performance assessments

Biopsy

avoiding morbidity associated with an immediate biopsy

differential separation

Processing of cervical cells from mucus and other materials

Clinical Concepts

8
Pap tests

Over 50 million Pap tests are performed each year.

fatigue factor

Data must be provided to assess this factor to establish workload limits.

atypical squamous cells of undetermined significance

TBS diagnosis category (ASCUS)

high grade squamous intraepithelial lesion

TBS diagnosis category for data stratification

ASCUS

Atypical squamous cells of undetermined significance

LGSIL

Low grade squamous intraepithelial lesion

HGSIL

High grade squamous intraepithelial lesion

Clinical accuracy

Primary end-point for validation of in vitro diagnostic methods

Identified Hazards

Hazards

1
hazard analysis

Required safety assessment for image interpretation devices

Standards & References

External Standards

2
The Bethesda System

Confirmatory test must be performed according to TBS guidelines; Standard for cervical cytology diagnoses (TBS); TBS categories used for screening diagnoses and reporting cervical/vaginal cytological diagnosis.

TBS guidelines

The Bethesda System guidelines for confirmatory testing

Specifications

2
Accuracy

Define and document a minimum set of metrics (e.g., accuracy)

Precision

Define and document a minimum set of metrics (e.g., precision)

Related CFR Sections (3)

See Also (1)

CPG Sec. 320.100 Ear Piercing Devices | Guideline Explorer | BioRegHub