Premarket Approval (PMA)
is a scientific and regulatory review to evaluate the
safety and effectiveness of Class III medical devices.
515 of the FD&C Act
- It is a marketing approval
application. Manufacturer shall receive FDA
approval of its PMA application prior to marketing the device.
- Devices fails
to meet PMA requirements is adulterated
under section 501(f) of the FD&C Act and may not be marketed.
Types of PMA
Traditional PMA
- Common method for achieving FDA approval.
- Ideal
method for devices with already completed clinical studies.
- complete PMA
application is submitted to FDA at once.
Modular PMA
- Ideal
method for devices with not completed clinical studies.
- PMA
contents are divided into modules (example modules are preclinical, clinical,
manufacturing etc.). Each module is submitted
to FDA as soon as the applicant has completed the module
Product
Development Protocol
- Ideal method for devices in which the
technology is well established in industry
- Manufacturer
can have an early agreement with FDA as to what would be done to demonstrate
the safety and effectiveness of a new device
Humanitarian
Device Exemption
A
Humanitarian Use Device (HUD) is a medical device intended to benefit patients in the treatment or diagnosis of a disease or
condition that affects or is manifested in not more than 8,000 individuals in
the United States per year (Section 3052 of the 21st Century Cures Act
(Pub. L. No. 114-255)
PMA can be amended before approval.
Click here to know more about HUD/HDE
PMA supplements: Any significant changes in approved PMA may require PMA
supplements
Types of PMA supplements:
- Panel-Track supplement: Significant change requiring new
substantial clinical data
- 180-Day supplement: Significant change requiring new preclinical test data, no clinical data
required.
- Real-Time supplement: Minor changes supported by pre-clinical or animal testing, with no new
clinical data. Involves review within a single scientific discipline.
- Special PMA supplement: Changes Being Effected: This change Must enhance safety. Change
may be implemented prior to FDA approval order
- Manufacturing site change supplement: Use of a different site or moving the
manufacturing site require a 180-day PMA supplement (referred to as a “site
change supplement”). Supplement must demonstrate compliance with QS regulation.
- 30-Day Notice: Written notification of change in manufacturing procedure or method,
affecting safety and effectiveness
Annual (periodic) Report or 30-day Supplements: FDA will notify the manufacture for
certain changes to be reported in an annual report instead of a PMA
supplement submission
Common
documents included in PMA
There is no pre-printed form for a PMA Application. Required elements
are listed in 814.20
PMA
content consists of below listed administrative and technical data.
1. The name and address of the applicant.
2. A table of contents
3. The summary shall contain the following information:
a. Indications for use.
b. Device description.
c. Alternative practices and procedures.
d. Marketing history.
e. Summary of non-clinical and clinical studies.
f.
Conclusions
drawn from the studies.
4. Device Description of device and functional components
or ingredients
5. Manufacturing
6. Reference to any performance standard
7. Q-Submission(s)
8. Results of Nonclinical Laboratory Studies: results of
the nonclinical laboratory studies with the device including microbiological,
toxicological, immunological, biocompatibility, stress, wear, shelf life, and
other laboratory or animal tests as appropriate.
9. Results of clinical investigations involving human
subjects Conducted inside US and Outside US
10. Statements of Compliance for Clinical
Investigations
11. FORM FDA 3674, Certification with
Requirements of ClinicalTrials.gov Data Bank?
12. A bibliography of all published reports not submitted
13. Sample of device, if practical
14. Copies of all proposed Labeling for the device. Such Labeling
may include, e.g., instructions for installation and any information,
literature, or advertising that constitutes Labeling
15. Environmental assessment
16. A financial certification or disclosure statement or
both
a.
A
signed and dated Certification Form (3454)
b. A signed and dated Disclosure Form (3455)
17. Information concerning uses in pediatric patients.
Once FDA approve the PMA,
Manufacturer will receive an Approval Order and Summary of Safety and
Effectiveness Data (SSED)
The following are
posted on the FDA’s public PMA database:
· Approval Order
· Summary of Safety and Effectiveness Data (SSED)
· Labeling
FDA Review
1.Sponsor submits the
ecopy to FDA
CDRH's or
CBER’s Document Control Center (DCC). FDA will send the acceptance status. (15 days) Assess
administrative completeness of application and required elements per 21 CFR
814.20.
Decision: Accepted or Not
accepted
2.FDA Filing Review:
Threshold determination that application is sufficiently complete to review.
Manufacturer can use Acceptance and Filing Reviews for PMAs
Within 45 calendar days FDA
will notify below to manufacturer: Decision: Accepted
or Not accepted
3. Substantive Review: Lead reviewer will assess the application and share the
below information to manufacturer (Day 90)
· Interactive review
· Issue Major Deficiency
Letter.PMA request will be placed on hold.
· Advisory Panel Meeting.Public meeting to review the
PMA in accordance with 21 CFR 14.
· Manufacturing facility inspection
· Day 100 Meeting (Requested by Applicant)
Decision:
Approval
Order:Device may be marketed.Identifies
conditions of approvalApprovable
Pending Deficiencies Letter: Device can
not be marketed.deficiencies to be addressedApprovable
Pending GMP Letter: Device can
not be marketed.GMP not confirmed Not
Approvable Letter:Device can
not be marketed
References:
PMA : https://www.fda.gov/medical-devices/premarket-submissions/premarket-approval-pma
PMA database: https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpma/pma.cfm
PMA Guidance: https://www.fda.gov/medical-devices/premarket-approval-pma/pma-guidance-documents