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FDA consensus standards

By
Wendy Levine
-
March 14, 2023
FDA consensus standards

FDA Standards and Conformity Assessment Program

The FDA Standards and Conformity Assessment Program (S-CAP) seeks to drive the “development, recognition, and appropriate use of voluntary consensus standards for medical devices, radiation-emitting products, and emerging technologies.” Conformity to relevant standards is voluntary, unless a standard is “incorporated by reference” directly into a regulation. However, demonstration of conformity with FDA-recognized standards in a premarket submission is encouraged by the agency and will streamline the review process.

According to the FDA, S-CAP is designed to:

  • Produce and implement clear policies to promote the appropriate use of standards in regulatory processes.
  • Anticipate the need for and leads the development of national and international consensus standards.
  • Advance initiatives to enhance confidence in conformity assessment activities.
  • Foster innovation and standardization in technologies that facilitate patient access to novel devices.
  • Provide leadership in standards quality and utilization through outreach and global harmonization.

What is a voluntary consensus standard?

The FDA recognizes standards that medical device manufacturers may use to demonstrate that they have met a relevant requirement of the FD&C act. The FDA may recognize all or part of a standard established by an international Standards Development Organization (SDO). Not all standards recognized internationally are recognized by the FDA.

The most common SDO is the International Organization for Standardization (ISO), and some of the most recognized ISO standards for medical devices include:

  • ISO 14971- Applications of risk management to medical devices
  • ISO 10993 – Biologic evaluation of medical devices
  • ISO 11137 – Sterilization of healthcare products

Note that ISO 13485 is not recognized by the FDA for use in standard market submissions, but it is recognized as a quality standard under the MDSAP program.

Some of the other recognized SDOs include:

  • ANSI – American National Standards Institute
  • ASQ – American Society for Quality
  • IEC – International Electrotechnical Commission

In some cases, FDA consensus standards have an identical U.S. adoption, such as IEC 60601-2-47 and ANSI/AAMI/IEC 60601-2-47. For a full list of recognized standards, see the FDA’s Recognized Consensus Standards database (the “Standards Organization” field lists all SDOs).

Using consensus standards in premarket submissions

Demonstrating conformity with FDA-recognized standards can facilitate the premarket review process for:

  • 510(k) submissions
  • De Novo requests
  • Investigational Device Exemption (IDE) applications
  • Premarket Approval (PMA) applications
  • Product Development Protocols (PDP)
  • Humanitarian Device Exemption (HDE) applications
  • Investigational New Drug (IND) applications
  • Biologics License Application (BLA) for devices that are regulated by CBER as biological products

It is important to recognize that conformance to a recognized standard often satisfies only a portion of the requirements of a premarket submission. When using an FDA-recognized consensus standard, a manufacturer should submit a Declaration of Conformity (DOC) to the standard and list it in the CDRH Premarket Review Submission Cover Sheet (form FDA 3514). Elements of a Declaration of Conformity include:

  1. Name and address of the applicant/sponsor responsible for the DOC.
  1. Product/device identification, including product codes, device marketing name, model number, and any other unique product identification data specific to the DOC in question.
  1. Statement of conformity.
  1. A list of standards for which the DOC applies including, for each standard, the options selected, if any.
  1. The FDA recognition number for each standard.
  1. The date and place of issuance of the DOC.
  1. Signature, printed name, and function of the sponsor responsible for the DOC.
  1. Any limitation on the validity of the DOC (ex: how long the declaration is valid, what was tested, or concessions made about the testing outcomes).

Supplemental documentation requirements in support of a DOC

Supplemental documentation in support of a DOC is often required. Adherence to a standard may not be sufficient for the FDA to make a regulatory decision. The example used in the FDA’s guidance document, Appropriate Use of Voluntary Consensus Standards in Premarket Submissions for Medical Devices, is that of ISO 14971. ISO 14971, Application of risk management to medical devices, does not list all of the detailed acceptance criteria for necessary performance tests. According to this guidance, the following general principles should be followed when determining the need for supplemental documentation:

  • When the consensus standard includes both a test method or test procedure with a single set of predefined acceptance criteria, FDA should generally not request data relating to the specific consensus standard in the DOC.
  • When the consensus standard describes a test method or procedure, but does not include acceptance criteria, the submitter should provide an assessment of the results and how conformity was determined.
  • When the consensus standard includes choices related to, for example, what is to be tested, which test methods to use, or acceptance criteria to assess conformity, the submitter should include an explanation for the choices and selections made.

Managing standards updates

When a consensus standard is replaced by a newly recognized standard, the older version is withdrawn following a transition period. That transition period is provided to allow submitters time to prepare to use a new version of the standard. During the transition period, the submitter may continue to use the old version of the standard, though a justification for use of the older version should be provided in instances where adherence with a new version would require significant questions to be addressed.

Transition periods will vary based on the scope of the change to the standard and can be found in the standard’s supplemental information sheet (SIS). When a standard changes during an active review of a premarket submission, the FDA will continue to review the submission based on the previous version of the standard.  

Learn more about how Rimsys can help your regulatory team manage standards.

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