Page 246 - Assurance of Sterility for Sensitive Combination Products and Materials
P. 246

Regulatory pathway for labeling combination products as sterile   223


                mechanism by which it is supported. Information is provided on the sub-
              mission pathway for regulatory authorities in the European Union (EU)
              and the United States.


              9.2  Seeking FDA feedback

              In 2019, the FDA published the guidance document “Requests for Feedback
              and Meetings for Medical Device Submissions:  The Q-Submission
              Program—Guidance for Industry and Food and Drug  Administration
              Staff.” This guidance is intended to provide a summary of the pathways
              available to industry for early collaboration and discussions about medical
              device submissions with the Center for Devices and Radiological Health
              (CDRH) and the Center for Biologics Evaluation and Research (CBER).
              It is available at: https://www.fda.gov/downloads/medicaldevices/device-
              regulationandguidance/guidancedocuments/ucm311176.pdf.
                 This guidance document presents the methods through which industry can
              request feedback from or a meeting with the FDA via Q-Submissions or Q-Subs.
              Q-Subs can be related to various types of premarket submissions such as:
              •  Investigational Device Exemption (IDE) applications,
              •  Premarket Approval (PMA) applications,
              •  Humanitarian Device Exemption (HDE) applications,
              •  Premarket Notification [510(k)] Submissions,
              •  Clinical Laboratory Improvement  Amendments (CLIA)  Waiver by
                 Applications (CW),
              •  Dual 510(k) and CLIA Waiver by Application Submissions (Duals),
              •  Accessory Classification Requests, and
              •  certain Investigational New Drug Applications (INDs) and Biologics
                 License Applications (BLAs).
                 Q-Subs are requests for interaction with FDA regarding potential or
              planned medical device submissions, potential or planned device-led com-
              bination product submissions, as well as issues communicated in mar-
              keting submission hold letters, Investigational Device Evaluation (IDE)
              letters, Clinical Laboratory Improvement Amendments (CLIA) Waiver by
              Applications  (CW) hold letters, and certain Investigational New Drug
              (IND) Clinical Hold letters.
                 There are several different types of Q-Subs that provide mechanisms
              to request FDA interaction and which are discussed in this guidance doc-
              ument. Some of these include Pre-Submissions, Informational Meetings,
              Study Risk Determinations, and Submission Issue Requests.
   241   242   243   244   245   246   247   248   249   250   251