The premarket notification process, or 510k process as it is commonly known, allows companies to fasttrack clearance of a device by claiming it is substantially equivalent to a device that has already been approved and marketed in the usa i. Our team has years of experience working with a wide variety of combination devices, materials, and pharmaceutical. Response the biocompatibility testing outlined in the 515b proposed order preamble is consistent with that recommended in the fda guidance document guidance. Dec 01, 2011 fda recommends biocompatibility testing of the device in accordance with fda blue book memo, use of international standard iso 10993, biological evaluation of medical devices part 1. This article presents some of the biocompatible materials used in medical practice. Navigating the new fda draft guidance on iso 10993. It does not create or confer rights for or on any person and does not operate to bind fda or the public. Use the blue book memo g95 1 use of international standard. For example, fda defines three different routes of exposure. Use of international standard iso10993, biological evaluation of medical devices, part 1. An alternative approach may be used if such approach satisfies the requirements of the.
Brenda seidman is president of seidman toxicology, a consulting firm. Fda published a draft guidance document on the use of international standard iso 109931 biological evaluation of medical devicespart 1. Federal register effective date of requirement for. Fda clarifies policy for color additives in medical devices. Standard guide for biocompatibility evaluation of medical. As is the case with many other us medical device regulations, fda biocompatibility testing guidance may be based on and highly similar to the iso 109931 standard, but not identical. Biocompatibility biocompatibility is the measure of the compatibility of a material with the tissue or physiological system of the patient. Consider these as you design studies for products that are intended for the us market. Given its biocompatibility and strength, titanium is the ideal material for dental supports and other oral prostheses. Biocompatibility, tests recommended in 1s0 10993 with the additional tests recommended in blue book memo, g951, for evaluation of devices in contact with mucosal membranes or breached or compromised surfaces for a limited duration, were submitted for pva sponge and results found to be acceptable.
Evaluation and testing, blue book memorandum g951, rockville, md, fda, cdrh, office of device evaluation, 1 may 1995. The iso 10993 set entails a series of standards for evaluating the biocompatibility of medical. The fda recognizes the standard iso 10993 for biological evaluation of medical devices, and specific testing requirements for a particular device are found in the guidance document required biocompatibility training and toxicology profiles for evaluation of medical devices, blue book memo, g951. Blue book memo page 1 of7 this guidance was written prior to the february 27, 1997 implementation of fdas good guidance practices, ggps. The tests that are required depend upon the length and type of contact. Combination product biocompatibility iso 10993 analysis. The timing is exquisite the guidance is released as iso tc194 holds its annual meeting in. Blue book memo page 1 of7 this guidance was written prior to the february 27, 1997 implementation of fda s good guidance practices, ggps. Evaluation and testing, dated may 1, 1995 starting on september 14, 2016. Biocompatibility assessment of synthetic sling materials for. Although not stated in a guidance, fda has historically said that biocompatibility can be shown through alternative information not.
Combination product biocompatibility testing at ekg labs. Well characterized materials widely used in the industry can produce unexpected reactions if processed in a. Fda held a conference on biocompatibility of medical devices. Mind the gap between iso 10993 and submission to fda. The fda recognizes the standard iso 10993 for biological evaluation of medical devices, and specific testing requirements for a particular device are found in the guidance document required biocompatibility training and toxicology profiles for evaluation of. K863 was much more commonsensical and pragmatic drawing upon fda s vast repository of institutional knowledge and finding similarities where they can be found. The iso 10993 set entails a series of standards for evaluating the biocompatibility of medical devices to manage biological risk. Fda finalizes biocompatibility guidance for medical devices. Draft guidance for industry and food and drug administration. Evaluation and testing within a risk management process. In addition to the tests recommended in the iso standard, the fda has identified additional tests that may be applicable for your medical device. The blue book supersedes the tripartite guidance as a guideline for planning biocompatibility testing of medical devices for the u. Which devices are required to meet usp class 6 or other. How the new fda guidance on biocompatibility affects medical.
When screening information is needed regarding the biocompatibility of the packaging, cytotoxicity testing from the supplier is typically performed. The us food and drug administration fda held a telephone conference on 21 st july, 2016, to familiarize industry leaders with the process of biocompatibility testing of medical devices, and how it is using iso 109931 standard for setting device standards. We understand the implications of each medical industry and how specialized services will benefit them. Fda invites interested persons to submit comments on all three lists, draft language on the proposed a. Biocompatibility of longterm implanted devices the biocompatibility of a longterm implantable medical device refers to the ability of the device to perform its intended function, with the desired degree of incorporation in the host, without eliciting any undesirable local or systemic effects in that host.
Fda finalizes biocompatibility guidance for medical. Regulatory guidelines for biocompatibility safety testing. Pharmacopoeia, and they supersede the usp for evaluating which studies to submit to fda in support of product registrations. The long awaited refresh of us fdas biocompatibility guidance has finally arrived. Consultants can also be of great value in helping you navigate the regulatory arena. On june 16, 2016, fda issued the final guidance use of international standard iso 109931, biological evaluation of medical devices part 1. The sponsor should provide appropriate biocompatibility testing for duration and level of contact. Biocompatibility testing is a critical part of the regulatory approval process for medical devices as even the best designed products can produce unintended complications if the materials used cause a biological reaction in the patient. Fda releases new biocompatibility draft guidance brandwood ckc. A common dictionary definition of biocompatibility is the quality of being compatible with living tissue or a living system by not being toxic or injurious and not causing immunological rejection. Medical device and its biocompatibility testing requirement table as per fda 510 k g95memorandum and iso 109931 x tests per iso 109931 o additional tests that may be applicable in the u. The ode guidance memoranda, affectionately referred to as blue book memos, clarify these guidelines and will be added to this list as they become available. Identified all the required biocompatibility testings by referencing guidance documents titled blue book memo, g951, use of international standard iso10993, and biological evaluation of medical. Per the iso 109931 standard, the downstream cartridge is categorized as an external.
Resolving issues prior to submission of a us fda 510k. Biocompatibility testing eurofins medical device testing. Fda recommends biocompatibility testing of the device in accordance with fda blue book memo, use of international standard iso 10993, biological evaluation of medical devices part 1. Apr 23, 2017 fda has published for comment a new draft guidance on application of iso 10993. The bone adheres naturally to the superficial titanium dioxide layer, thus avoiding the necessity of any additional coating. This guidance is intended to replace the 1995 blue book memo g951. Aditi tondulkar regulatory affairs specialist dexcom. Note1 tissue includes tissue fluid and subcutaneous spaces note2 for all devices used in extracorporeal circuits. This is a quantum leap from the old g951 blue book memo.
Jun 17, 2016 maybe a quieter life for these little fellows. Aug 26, 20 14 biocompatibility tests for implants fda blue book memo g951 to support premarket submission, studies conducted according to respective fda recognized standards and are in compliance with 21 cfr part 58 glp regulations are generally required. Fda compliance program guidance manual, chapter 48, good laboratory practice nonclinical laboratories program 7348. Under chapter vii, section 721 of the federal food, drug, and cosmetic, color additives are subject to fda approval before they may be used in medical devices that come in. Biocompatibility training and toxicology profiles for evaluation of medical devices, issued on may 1, 1995 g951, with changes limited to cberspecific administrative procedures. As is the case with many other us medical device regulations, fda biocompatibility testing guidance may be based on and highly similar to the iso 109931. Final us fda guidance on biocompatibility testing and iso.
The biocompatibility of the material is affected by devicespecific features, including the manufacturing processes, tissue contact type and duration of contact. Fda has published for comment a new draft guidance on application of iso 10993. Usp class plastics tests usp class vi pacific biolabs. May 04, 2006 although i cant claim to be an expert in this area but, i believe that iso 10993 is being used instead of the usp for medical device biocompatibility testing. Fda releases final guidance regarding biocompatibility. Resolving issues prior to submission of a us fda 510k application. This memo was a huge step toward international harmonization of device biocompatibility testing, although there are still some significant differences between fda and european requirements. Brenda seidman is president of seidman toxicology, a consulting firm located in falls church, va. This document, known as the blue book, was the basis of biocompatibility regulation for decades. Sep 23, 2016 the us food and drug administration fda held a telephone conference on 21 st july, 2016, to familiarize industry leaders with the process of biocompatibility testing of medical devices, and how it is using iso 109931 standard for setting device standards. Although i cant claim to be an expert in this area but, i believe that iso 10993 is being used instead of the usp for medical device biocompatibility testing. Food and drug administration fda held a webinar to clarify their current policy in relation to the use of color additives in medical devices. Biocompatibility is defined as presence of the mildness of the relation between a physical and its biological environment on the basis of drug delivery 3. All biocompatibility testing and evaluation methods used to mitigate risks should be well documented.
The contract laboratories are going to have the greatest amount of experience in knowing exactly what the regulators have been expecting. The food and drug administration fda or agency is announcing the. Fda blue book memo g951, required biocompatibility training and toxicology profiles for evaluation of medical devices, may 1995. Response the biocompatibility testing outlined in the 515b proposed order preamble is consistent with that recommended in the fda guidance document guidance for. We call ourselves specialists, who are informed and vigilant about the different industries that need biocompatibility testing for developing their medical devices. The commenter seeks clarity regarding the specific biocompatibility testing fda believes should be conducted and a rationale for any testing not outlined in the blue book memo.
Assessment takes place after a number of investigations as defined in usp u. The guidance is firmly rooted in a risk based approach, and provides detailed advice on all aspects of biological safety evaluation. Fda biocompatibility new risk based guidance on iso 10993. Our experienced professionals are trained in designing and conducting biocompatibility testing as per different industry. Use of international standard iso 109931, biological. The guidance is firmly rooted in a risk based approach, and provides detailed advice on all aspects. As a general rule, the blue book memo and iso documents take a broader and more thorough view of biocompatibility than does the u. The long awaited refresh of us fda s biocompatibility guidance has finally arrived. Biocompatibility, tests recommended in 1s0 10993 with the additional tests recommended in blue book memo, g951, for evaluation of devices in contact with mucosal membranes or breached or compromised surfaces for a limited duration, were submitted for pva sponge and results found to. Alperts guidance letter provides general background about fdas previous use of the tripartite guidance and the agencys reasons for adopting the iso 109931.