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Streamlining Medical Device Development: Investigational Device Exemptions and 21 CFR 812 – RegDesk

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This article highlights the key elements of 21 CFR 812, Investigational Device Exemptions and their impact on the medical device industry.

FDA Draft Guidance on VMSR Program: Supplemental Reports and Summary Reporting

Table of Contents

The FDA oversees the regulation of medical devices in the United States to ensure their safety and effectiveness. Before a medical device can be sold to the public, it must undergo a thorough review and approval process by the FDA.

However, before a medical device can even be submitted for FDA review, it must first undergo a clinical investigation to gather data on its safety and effectiveness.
This involves testing the device in human subjects to determine if it is safe and effective for its intended use.

This process is regulated under 21 CFR part 812- Investigational Device Exception.

IDE OVERVIEW

An Investigational Device Exemption (IDE) enables medical device manufacturers to conduct clinical investigations on humans before securing FDA clearance or approval.

The primary objective of an IDE is to collect essential safety and effectiveness data that will support future marketing applications for the device.

IDEs are mandatory for investigational medical devices, particularly high-risk devices.  USFDA may require IDEs for non-significant risk devices if needed.

Obtaining an IDE involves a formal application process submitted to the FDA.
It includes comprehensive details about the medical device, its intended use, the design of the clinical study, and the qualifications of the investigators.

 The FDA reviews each application to determine its alignment with IDE regulations and relevant guidance documents.
This ensures that the proposed study meets all requirements and standards set forth by the FDA.

Do All Medical Devices Need FDA Approval

Requirements of an IDE

21 CFR 812 establishes several requirements that must be met by the manufacturer and the investigators conducting the clinical study. Some of the key requirements include:

  • Investigational plan
     The manufacturer must develop a detailed investigational plan that outlines the objectives of the study, the study design, the endpoints that will be evaluated, and the criteria for subject selection.
  • Informed consent
     The manufacturer must obtain informed consent from each subject participating in the clinical study. Informed consent involves providing the subject with detailed information about the study and the risks and benefits associated with participation. 
  • Monitoring
    The manufacturer must establish procedures for monitoring the study to ensure that it is being conducted in accordance with the investigational plan and the regulations.
  • Adverse event reporting
     The manufacturer must promptly report any adverse events that occur during the study to the FDA and the investigators.
  • Labelling
     The manufacturer must label the investigational device with appropriate warnings and caution statements.
  • Records and reports
     The manufacturer must maintain accurate and complete records of the study and submit periodic reports to the FDA.

 21 CFR 812 for Investigational Device Exemptions (IDEs)

21 CFR 812 plays a crucial role in governing the Investigational Device Exemption (IDE) process in the United States.
The key subparts of 21 CFR 812:-

Subpart A-General Provisions
Defines the foundational concepts of IDEs, their purpose, and requirements. It outlines the responsibilities of various stakeholders in IDE lifecycle.

Subpart B – Application and Administrative Action
This subpart outlines the process of applying for an IDE and  FDA’s role in reviewing and managing IDE applications. It forms the initial step for initiating a clinical investigation.

Subpart C – Responsibilities of Sponsors
This section outlines the responsibilities of sponsors, including labeling, record-keeping, and the reporting of adverse events.

Subpart D – IRB Review and Approval
This subpart the  role of Institutional Review Boards (IRBs) in the IDE process, including the criteria for IRB approval and their ongoing responsibilities in safeguarding study participants.

Subpart E – Responsibilities of Investigators
This section highlights the importance of obtaining informed consent, following the investigational plan, and promptly reporting safety concerns to safeguard the well-being of study participants.

Subpart F – Reserved

Subpart G – Records and Reports
This section requires thorough record-keeping and reporting throughout the investigational process to enhance transparency and accountability.

Impact of 21 CFR and Investigational Device Exemption

21 CFR 812 regulations profoundly impact Investigational Device Exemptions (IDEs) within the medical device industry.
These guidelines meticulously define the IDE process, ensuring strict adherence to safety and efficacy standards.

One of the key impacts of 21 CFR 812 is its focus on patient safety. It enforces informed consent, robust monitoring, and prompt adverse event reporting, instilling confidence in ethical research practices.
Additionally, it mandates transparent record-keeping and reporting, fostering data integrity and compliance.

Impact of IDEs on the Medical Device Industry
Investigational Device Exemptions (IDEs) have a profound impact on the medical device industry, influencing innovation, collaboration, and credibility.

IDEs enable manufacturers to conduct clinical investigations in humans before FDA approval, expediting device development and market entry.

One major impact of IDEs is their role in accelerating medical device innovation. They allow manufacturers to gather safety and efficacy data efficiently, expediting research and development.
IDEs also foster collaboration in the industry, promoting knowledge exchange and enhancing device designs and treatments, benefiting both patients and the industry.

Furthermore, IDEs enhance industry credibility by ensuring only safe and effective devices reach the market, instilling trust among healthcare providers and patients.

Conclusion

The impact of 21 CFR 812 on IDEs and the subsequent impact of IDEs on the medical device industry are intrinsically linked. Together, they promote innovation, safety, transparency, and accountability, ultimately driving advancements in medical technology for the betterment of patient care and healthcare as a whole.

How Can RegDesk Help?

RegDesk is a holistic Regulatory Information Management System that provides medical device and pharma companies with regulatory intelligence for over 120 markets worldwide. It can help you prepare and publish global applications, manage standards, run change assessments, and obtain real-time alerts on regulatory changes through a centralized platform. Our clients also have access to our network of over 4000 compliance experts worldwide to obtain verification on critical questions. Global expansion has never been this simple.

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