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510(k) Third Party Review Program and Third Party Emergency Use Authorization (EUA) Review: Guidance for Industry, Food and Drug Administration Staff, and Third Party Review Organizations

FinalCenter for Devices and Radiological Health11/21/2024

Description

This guidance outlines FDA's current thinking on key aspects of the 510(k) Third Party Review Program and third party review of Emergency Use Authorization (EUA) requests by describing FDA's expectations for the review of 510(k) submissions and EUA requests by third party review organizations. This guidance provides updated recommendations on the 510(k) Third Party Review Program and supersedes the "510(k) Third Party Review Program" guidance.

Scope & Applicability

Product Classes

9
Class I Device

Low risk medical devices

in vitro diagnostic products

Specific category of medical devices mentioned for EUA review

in vitro diagnostic device

Specific category of medical device mentioned for EUA.

duodenoscopes

removed from eligibility for the 3P510k Review Program due to safety signals

Class II Device

Devices subject to section 522 postmarket surveillance orders; devices subject to postmarket surveillance orders

In Vitro Diagnostic

IVD device clinical studies conducted on de-identified specimens

Class III Device

Generally recommended for Enhanced Documentation; Regulatory classification mentioned for implantable sensors and HPV tests; Mentioned in the context of an in vitro nucleic acid test for CMV DNA.

In Vitro Diagnostic Product

IVDs requiring UDI on labels

Combination Product

Products combining drug, device, or biological constituents; Generally recommended for Enhanced Documentation; Requires 14971-based framework incorporating ICH Q9; A drug-device combination where the device constituent part detects ingestion.

Stakeholders

10
Third Party Review Organizations

Entities recognized by FDA to review 510(k) submissions and EUA requests.; Organizations responsible for reviewing scientific and technical data; Entities performing reviews of 510(k) and EUA submissions

Conformity Assessment Bodies

Entities that perform regulatory reviews as defined by IMDRF

Final Reviewers

Supervisory personnel at the 3P510k RO

Technical Experts

External individuals used by review organizations for specialized knowledge; Personnel involved in the evaluation of 510(k)s

Submitter

The entity providing information for the AFIC process.

3P510k RO

Third Party Review Organization for 510(k) submissions

Product Specialist

Personnel assigned by a Third Party Review Organization to conduct substantive review.; Primary reviewer responsible for leading the organization's review team; Personnel assigned to conduct substantive review of a submission; Individual within the RO performing the review.; Qualified individual required for each device type recognized

Final Reviewer

Personnel assigned by a Third Party Review Organization for final review of a submission.; Individual within the Third Party Review Organization who oversees the review process; Independent individual responsible for final supervisory assessment; Individual providing final supervisory assessment at the RO.; A cover letter signed by the Final Reviewer that clearly identifies the purpose of the submission.

Technical Expert

Personnel or external experts involved in the substantive review of a submission.; Individual who provides specific knowledge or expertise; Qualified individual added to review team for specific competency

3P510k Review Organization

Qualified third parties recognized to conduct initial reviews of 510(k) submissions

Identified Hazards

Hazards

3
Safety Signal

Information suggesting a new potentially causal association or a new aspect of a known association between an intervention and an event.

threat to public health

Condition for suspension or withdrawal of recognition

public health risk

Complaints regarding submitters that indicate safety issues

Related CFR Sections (7)

See Also (8)

510(k) Third Party Review Program and Third Party Emergency Use Authorization (EUA) Review: Guidance for Industry, Food and Drug Administration Staff, and Third Party Review Organizations | Guideline Explorer | BioRegHub