Overview of Premarket Approval (PMA) Application for Class III Medical Devices

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Premarket Approval (PMA) is the FDA's process for reviewing Class III medical devices to ensure their safety and effectiveness. These devices sustain or support life, are crucial for preventing health issues, or pose a significant risk of illness or injury. Because of these risks, they need a PMA application for FDA approval before they can be sold.

 

PMA is the strictest type of device approval required by the FDA. The application must show valid scientific evidence proving the device's safety and effectiveness. The applicant, usually the device's owner or developer, must get FDA approval before marketing the device.

The rules for PMA are found in Title 21 of the Code of Federal Regulations (CFR) Part 814. A Class III device that doesn't meet PMA requirements cannot be marketed.

 

When is PMA Required?

PMA is needed for Class III devices, which are the highest-risk category. You can find device classifications by searching the Product Classification Database. This database gives details about the device and its classification and links to relevant regulations.

 

The CFR provides a regulation number and the requirement for PMA for devices marketed before 1976. If there is no effective date for PMA, a Class III 510(k) should be submitted. New high-risk devices not equivalent to existing devices must also get PMA approval before being sold in the US. Some devices not substantially equivalent to cleared devices may qualify for the De Novo process, allowing them to be classified as Class I or II.

 

Data Requirements for PMA

A PMA application must scientifically prove the device's safety and effectiveness. Good scientific evidence and writing are crucial. Only complete or well-organized applications can ensure approval and lead to acceptance. Manufacturers should perform a quality check before applying.

Technical Sections:

  1. Non-Clinical Laboratory Studies: Includes data on microbiology, toxicology, biocompatibility, stress, and other lab tests. These studies must follow Good Laboratory Practice standards.
  2. Clinical Investigations: Includes study protocols, safety and effectiveness data, adverse reactions, device failures, patient information, and statistical analyses. Studies under an Investigational Device Exemption (IDE) must be identified.

Applications must include Form FDA-3674, certifying compliance with ClinicalTrials.gov requirements. Follow FDA guidance documents and industry standards for study design and data presentation to avoid common problems and ensure approval.