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Developing and Responding to Deficiencies in Accordance with the Least Burdensome Provisions: Guidance for Industry and Food and Drug Administration Staff

FinalCenter for Devices and Radiological Health Center for Biologics Evaluation and Research10/26/2022

Description

This guidance document is intended to help Food and Drug Administration (FDA) staff develop a request for additional information needed to make a decision on a medical device marketing application in accordance with the Least Burdensome Provisions of the Food, Drug, and Cosmetic Act (FD&C Act). Such an FDA request for additional information is known as a “deficiency.” In addition, this guidance describes suggested formats for FDA staff to communicate deficiencies, and for industry to use for responses to such requests, in order to make efficient use of industry and FDA’s time. This guidance includes examples of well-constructed deficiencies and industry responses to facilitate an efficient review process. This guidance also details supervisory review, major/minor deficiencies, additional considerations, and prioritization of deficiencies in FDA deficiency letters.

Scope & Applicability

Product Classes

1
Medical Device

FDA intends to assess device cybersecurity based on a number of factors; demonstrate or maintain its safety and effectiveness; ensuring cybersecurity has become essential to FDA’s ability to protect the public health; Cyber-resiliency capabilities for medical devices

Stakeholders

1
Applicant

Entity submitting development data and knowledge; Entity performing the work process for change

Regulatory Context

Attributes

4
Reasonable Assurance of Safety and Effectiveness

Standard for PMA approval

Substantial Equivalence

Standard for 510(k) clearance

Safety and Effectiveness

Cybersecurity is part of device safety and effectiveness

Puncture rate

Performance parameter for handpiece testing.

Identified Hazards

Hazards

2
burn from overcharge

ESD can damage the battery's electronic components leading to patient harm

cement extravasation

can cause nerve root compression and pulmonary embolisms

Related CFR Sections (3)

See Also (8)