Archive for May, 2012


Posted on May 31, 2012. Filed under: Syringe Blog | Tags: , , , , , , , , , , , , , , , , |

WARNING ~ DEADLY Luer connections


Hospitals and other healthcare facilities depend on a variety of catheters, tubing and syringes to deliver medications and other substances to patients through vascular, enteral, respiratory, epidural and intrathecal delivery systems.

These delivery systems frequently employ fittings called Luer connectors to link various system components. The male and female components of Luer connectors join together to create secure yet detachable leak-proof connections. Multiple connections between medical devices and tubing are common in patient care.

Unfortunately, because Luer connectors are ubiquitous, easy-to-use and compatible between different delivery systems, clinicians can inadvertently connect wrong systems together, causing medication or other fluids to be delivered through the wrong route. Such errors have occurred in diverse clinical settings, causing serious patient injuries and deaths. The Food and Drug Administration (FDA), The Joint Commission (TJC), the Institute for Safe Medication Practices (ISMP), the United States Pharmacopeia (USP), the ECRI Institute and others have all received reports of misconnection errors. The problem is well-known and well documented. Yet despite efforts on the part of FDA and other organizations to reduce misconnections through education, protocol and monitoring, the use of Luer connectors in incompatible medical delivery systems continues to create situations where dangerous misconnections can, and do, occur.

To further reduce the occurrence of these misconnections, FDA is actively participating in an international effort to develop and implement standards for noninterchangeable connectors for small bore medical connectors. A joint working group established by the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC) leads this effort to develop a series of standards for incompatible connectors used in intravascular (IV), breathing systems, enteral, urethral/urinary, cuff inflation and neuraxial applications. Once implemented, these connectors will facilitate correct connections and eliminate incompatible tubing misconnections.

Until standards are completed and manufacturers design and produce products that can’t be misconnected, all interested parties must continue their efforts to keep these dangerous misconnections from happening. “Actions must be taken at the patient bedside, within all levels of health care organizations and throughout the channels of regulation, manufacturing and distribution of these devices in order to eradicate the serious problem of tubing misconnections,” said Peter B. Angood, M.D., Vice President and Chief Patient Safety Officer for The Joint Commission (TJC).

These Medical Device Safety photos are one of those efforts. These photos provided a graphic depiction of misconnection cases that have occurred, coupled with recommendations from TJC on ways to prevent these types of errors.

We hope you’ll post these Medical Device Safety photos as a reminder to staff that these errors can occur in any clinical setting. We also urge you to use the case synopses and recommendations as ongoing training materials. To that end, we have made the photos, case studies and additional resources available, free of charge, at We encourage you to visit this web site to download and make further use of these materials. Let’s continue to work together to prevent these tragic errors.

Daniel G. Schultz, M.D.
Director, Center for Devices and Radiological Health
U.S. Food and Drug Administration
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What to Do if You Can’t Find a Sharps Disposal Container?

Posted on May 30, 2012. Filed under: Syringe Blog | Tags: , , , , , , , , , , |

I Can’t Find a Sharps Container!


The safest way to dispose of a used needle is to immediately place it in a sharps disposal container to reduce the risk of needle sticks, cuts and punctures from loose sharps. If you cannot find a sharps disposal container right away, you may need to recap the needle or use a needle clipper until you have an opportunity to dispose of sharps in an appropriate sharps disposal container. Never throw away loose needles and other sharps in trash cans or recycling bins, and never flush them down the toilet. 



If you need to put the cap back on the needle (recap), do not bend or break the needle and never remove a hypodermic needle from the syringe by hand. This may result in accidental needle sticks, cuts or punctures. Recapping should be performed using a mechanical device or the one-handed technique (see below for step-by-step instructions). Recapped needles should be placed in a disposal container at the next available opportunity.

The One-Handed Needle Recapping Method

Step 1: Place the cap on a flat surface like the table or counter with something firm to “push” the needle cap against
Step 2: Holding the syringe with the needle attached in one hand, slip the needle into the cap without using the other hand
Step 3: Push the capped needle against a firm object to “seat” the cap onto the needle firmly using only one hand.


Needle Clippers


Needle clippers make syringes unusable by clipping off the needle. Clippers may be used for needle disposal of small syringes (such as insulin syringes), but not for clipping lancets.
After the needle clipper clips off the needle from the syringe, the needle is automatically and safely retained within the clipper.
Do not attempt to clip a needle with any tool except a needle clipper designed to safely clip a needle.

Before using any of the above procedures, check your community guidelines for acceptable sharps disposal methods.

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510k Frequently Asked Questions

Posted on May 29, 2012. Filed under: Syringe Blog | Tags: , , , , |

510k  Q & A


I would like to distribute a manufacturer’s product under my own company name. Do I need to submit a 510(k)?



No, the manufacture should submit the 510(k), if required for the device. As required under 21 CFR 801.1(c), where a device is not manufactured by the person whose name appears on the label, the name shall be qualified by a phrase that reveals the connection such person has with such device; such as, “Manufactured for ABC Company,” “Distributed by ABC Company,” or any other wording that expresses the facts.  The distributor should forward all product complaints to the manufacturer for evaluation in accordance with 21 CFR 820.198 Complaint files.

Foreign Manufacturers


Can foreign companies submit a Premarket Notification 510(k)?

Yes. The foreign manufacturer may submit a 510(k) directly to FDA. For convenience, a foreign manufacturer may receive assistance from a U.S. entity and may use a contact person residing in the U.S.



Do I need to register my facility before I submit a 510(k)?

No. If you are a new company and do not manufacture any medical devices, you should not register until you are within 30 days of manufacturing and distributing the device. The 510(k) submission should state that you are not currently registered. Information on how to register your facility is available at Registering Your Establishment.

Quality System


Do I need to provide documentation that my facility complies with the Quality System in my 510(k)?

No. However, if you are submitting a Special 510(k), you must provide declaration of conformity with the design controls aspect of the Quality System.

Do I need to have my facility inspected to the Quality System regulations before I submit a 510(k)?

No. There is no pre-approval inspection as a prerequisite to 510(k) clearance. However, you should be prepared for an FDA inspection at any time.


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510k ~ Alternate Approaches!

Posted on May 28, 2012. Filed under: Syringe Blog | Tags: , , , , , , , , , , , , , , , , , , , , |

510k ~ Alternate Approaches to Demonstrating Substantial Equivalence


The New 510(k) Paradigm Alternate Approaches to Demonstrating Substantial Equivalence in Premarket Notifications






This document provides guidance to the regulated industry and reviewers on two alternative approaches that may be used, under appropriate circumstances, to demonstrate substantial equivalence. It establishes procedures regarding the use of consensus standards in the premarket review process (section 514 of the Act, as amended by section 204 of the FDAMA) and reflects other changes to the 510(k) Program that have resulted from enactment of the new law, such as increased reliance on postmarket controls to expedite premarket review (section 513 of the Act, as amended by section 205 of the FDAMA). In addition, it incorporates concepts that have arisen out of the Center’s organizational transformation initiative, including a new emphasis on the use of guidance documents and special controls. The alternative approaches described in this guidance document should streamline the 510(k) preparation and review processes, thus conserving industry and Agency resources while still protecting the public health.


Under section 510(k) of the Act, a person who intends to introduce a device into commercial distribution is required to submit a premarket notification, or 510(k), to FDA at least 90 days before commercial distribution is to begin. Section 513(i) of the Act states that FDA may issue an order of substantial equivalence only upon making a determination that the device to be introduced into commercial distribution is as safe and effective as a legally marketed device. Under 21 CFR 807.87, FDA established the content requirements for premarket notifications to be submitted by device manufacturers in support of the substantial equivalence decision. FDA has, however, discretion in the type of information it deems necessary to meet those content requirements. For example, to allocate review resources more effectively to the highest risk devices, FDA developed a tiering system based on the complexity and the level of risk posed by medical devices. Under this system, the substantial equivalence determination for low risk devices is based primarily on descriptive information and a labeling review, while the decision for higher risk devices relies on performance data.

In a further effort to manage FDA’s workload and allocate resources most appropriately, the Agency exempted Class I devices for which it determined that premarket notification requirements were not necessary to provide reasonable assurance of safety and effectiveness.

Between the passage of the Medical Device Amendments of 1976 and the FDAMA, FDA exempted 574 generic types of Class I devices from the requirement of premarket notification. As a result of the FDAMA, all Class I devices are exempt from the requirement of premarket notification, unless the device is intended for a use that is of substantial importance in preventing impairment to human health or presents a potential unreasonable risk of illness or injury (“reserved” criteria). Therefore, only those Class I devices that meet the reserved criteria remain subject to the premarket notification requirement. (See 63 FR 5387, February 2, 1998, for a listing of Class I “reserved” devices.)

The FDAMA also gave FDA the authority to directly exempt certain Class II devices rather than first down-classifying them to Class I before they become eligible for exemption. On January 21, 1998, FDA published a listing of Class II devices that no longer require premarket notification. (See 63 FR 3142.) In the future, additional Class II devices may become exempt from the premarket notification requirement as FDA considers additional devices for exemption.

The last phase of the Agency’s effort to evaluate which devices should be subject to 510(k) review involves the preamendments Class III devices. Preamendments Class III devices for which general controls or special controls are sufficient to ensure safety and effectiveness will eventually be down-classified to either Class I (510(k) exempt or reserved) or to Class II, respectively. Those preamendments Class III devices that are not appropriate for reclassification will remain in that class and be subject to either premarket approval (PMA) or product development protocol (PDP) requirements. It is anticipated that, as a result of this reclassification effort, the premarket notification process will be primarily reserved for Class II devices and a few “reserved” Class I devices. Until a preamendments Class III device type becomes subject to a regulation requiring premarket approval, however, the device type will remain subject to the premarket notification requirement.

The New 510(k) Paradigm

To streamline the evaluation of premarket notifications for the reserved Class I devices, Class II devices subject to premarket notification, and preamendments Class III devices for which FDA has not yet called for PMAs, the Agency has developed “The New 510(k) Paradigm.” Attachment 1 outlines the New Paradigm, which presents device manufacturers with two new optional approaches for obtaining marketing clearance for devices subject to 510(k) requirements. While the New Paradigm maintains the traditional method of demonstrating substantial equivalence under section 510(k) of the Act, it also presents the “Special 510(k): Device Modification” option, which utilizes certain aspects of the Quality System Regulation, and the “Abbreviated 510(k)” option, which relies on the use of guidance documents, special controls, and recognized standards to facilitate 510(k) review. Use of either alternative, however, does not affect FDA’s ability to obtain any information authorized by the statute or regulations.

A. Special 510(k): Device Modification

The Safe Medical Devices Act of 1990 (the SMDA) (Pub. L. 101-629) amended section 520(f) of the Act, providing FDA with the authority to issue regulations requiring pre-production design controls. Specifically, section 520(f)(1)(A) states that FDA may prescribe regulations to require “… that the methods used in, and the facilities and controls used for, the manufacture, pre-production design validation (including a process to assess the performance of a device but not including an evaluation of the safety or effectiveness of a device), packing, storage, and installation of a device conform to current good manufacturing practice, as prescribed in such regulations, to assure that the device will be safe and effective and otherwise in compliance with this Act.” This change in the law was based on findings that a significant proportion of device recalls were attributed to faulty design. Under the authority provided by the SMDA, FDA revised its current good manufacturing practice requirements to include pre-production design controls that device manufacturers must follow when initially designing devices or when making subsequent modifications to those designs. (See 21 CFR 820.30 Subpart C – Design Controls of the Quality System Regulation.)

Effective June 1, 1997, manufacturers of Class II, Class III, and certain Class I devices are required to follow design control procedures when originally developing devices and for subsequent modifications. Product modifications that could significantly affect safety and effectiveness are subject to 510(k) submission requirements under 21 CFR 807 as well as design control requirements under 21 CFR 820.30. In accordance with the Quality System Regulation, manufacturers must have a systematic set of requirements and activities for the management of design and development, including documentation of design inputs, risk analysis, design output, test procedures, verification and validation procedures, and documentation of formal design reviews. In this process, the manufacturer must ensure that design input requirements are appropriate so the device will meet its intended use and the needs of the user population. The manufacturer must also establish and maintain procedures for defining and documenting design output in terms that allow an adequate evaluation of conformance to design input requirements. Thus, manufacturers may need to refine their device design requirements as verification and validation results are obtained. The design specifications that result from this process are the design outputs, which form the basis for the device master record (DMR). (See 21 CFR 820.3(i).) The DMR is subject to inspection by FDA personnel.

Since design control requirements are now in effect and require the manufacturer to conduct verification and validation studies of a type that have traditionally been included in 510(k) submissions, the Agency believes that it may be appropriate to forgo a detailed review of the underlying data normally required in 510(k)s. For this reason, FDA is allowing an alternative to the traditional method of demonstrating substantial equivalence for certain device modifications. For these well-defined modifications, the Agency believes that the rigorous design control procedure requirements produce highly reliable results that can form, in addition to the other 510(k) content requirements specified in Attachment 2, a basis for the substantial equivalence determination. Under the Quality Systems Regulation, data that is generated as a result of the design control procedures must be maintained by the manufacturer and be available for FDA inspection.

Under the New 510(k) Paradigm, a manufacturer should refer to 21 CFR 807.81(a)(3) and the FDA guidance document entitled, “Deciding When to Submit a 510(k) for a Change to an Existing Device” to decide if a device modification may be implemented without submission of a new 510(k). If a new 510(k) is needed for the modification and if the modification does not affect the intended use of the device or alter the fundamental scientific technology of the device, then summary information that results from the design control process can serve as the basis for clearing the application.1

Under this option of the Paradigm, a manufacturer who is intending to modify his/her own legally marketed device2 will conduct the risk analysis and the necessary verification and validation activities to demonstrate that the design outputs of the modified device meet the design input requirements. Once the manufacturer has ensured the satisfactory completion of this process, a “Special 510(k): Device Modification” may be submitted. While the basic content requirements of the 510(k) (21 CFR 807.87) will remain the same, this type of submission should also reference the cleared 510(k) number3 and contain a “Declaration of Conformity” with design control requirements. Refer to Attachment 2 for the contents of a “Special 510(k): Device Modification” with a “Declaration of Conformity” to design controls.


1The terms “intended use” and “fundamental scientific technology” are used in the same manner as when used to define the limitations of exemptions from section 510(k) of the Act as found in each of the product classification regulations, 21 CFR 862-892, e.g., 21 CFR §§862.9, 864.9, and 866.9.

2Although not subject to the design control procedure requirements of the Quality System Regulation, manufacturers of reserved Class I devices may elect to comply with this provision of the regulation and submit Special 510(k)s.

3Manufacturers of preamendments devices may submit Special 510(k)s. See footnote 6 of Attachment 2 for information that should be included in a Special 510(k) under this circumstance.


Under the Quality System Regulation, manufacturers are responsible for performing internal audits to assess their conformance with design controls. A manufacturer could, however, use a third party4 to provide a supporting assessment of the conformance. In this case, the third party will perform a conformance assessment for the device manufacturer and provide the manufacturer with a statement to this effect. The marketing application should then include a declaration of conformity signed by the manufacturer, while the statement from the third party should be maintained in the DMR. As always, responsibility for conformance with design control requirements rests with the manufacturer.

In order to provide an incentive for manufacturers to choose this option for obtaining Agency clearance for device modifications, the Office of Device Evaluation (ODE) intends to process Special 510(k)s within 30 days of receipt by the Document Mail Center (DMC). The Special 510(k) option will allow the Agency to review modifications that do not affect the device’s intended use or alter the device’s fundamental scientific technology within this abbreviated time frame. The Agency does not believe that modifications that affect the intended use or alter the fundamental scientific technology of the device are appropriate for review under this type of application, but rather should continue to be subject to the traditional 510(k) procedures (i.e., “Traditional 510(k)”) or may be subject to an Abbreviated 510(k) as described below.

FDA believes that to ensure the success of the Special 510(k) option of the Paradigm, there must be a common understanding of the types of device modifications that may gain marketing clearance by this path. In this vein, it is critical that industry and Agency staff can easily determine whether a modification is appropriate for submission as a Special 510(k). To optimize the chance that a Special 510(k) will be accepted and promptly cleared, 510(k) submitters should evaluate each modification against the considerations described below to insure that the particular change does not: (1) affect the intended use or (2) alter the fundamental scientific technology of the device.

I. Intended Use

As discussed earlier, modifications to the indications for use of the device or any labeling change that affects the intended use of the device should not be submitted as a Special 510(k). Therefore, FDA recommends that submitters of Special 510(k)s highlight, or otherwise prominently identify, all changes in the proposed labeling that may result from modifications to their legally marketed device. In addition, it should be clearly stated in the Special 510(k) that the intended use of the modified device, as described in its labeling, has not changed as a result of the modification(s).


4 This use of a third party should not be confused with the Agency’s Third Party Review Program where recognized third parties review entire 510(k) submissions.


II. Fundamental Scientific Technology

Special 510(k)s should also not be submitted for modifications that have the potential to alter the fundamental scientific technology of the device. These types of changes generally include modifications to the device’s operating principle(s) or mechanism of action, such as automation of a manual device or incorporation of a sensing or feedback circuit. Specific examples that illustrate these types of changes that alter the fundamental scientific technology and thus should not be submitted as Special 510(k)s include:

  1. A change in a surgical instrument that uses a sharpened metal blade to one that cuts with at a laser;
  2. A change in an in vitro diagnostic (IVD) device that uses immunoassay technology to one that uses nucleic acid hybridization or amplification technology;
  3. Incorporation of a sensing mechanism in a device to allow the device to function “on demand” rather than continuously.

In addition, the Agency is concerned with changes in materials in certain devices. While FDA acknowledges that many such changes can be processed as Special 510(k)s, there are certain types of changes in materials that may raise safety or effectiveness issues that continue to warrant a more intensive evaluation by the Agency. This includes a change in material(s) in an implant, or other device that contacts body tissues or fluids, to a material type that has not been used in other legally marketed devices within the same classification regulation for the same intended use (i.e., “legally marketed predicate device”). For example, a change in a material in a finger joint prosthesis from a known metal alloy to a ceramic that has not been used in a legally marketed predicate, should not be submitted as a Special 510(k). Similarly, a change in a device’s active ingredient or agent to one that has not been used in other legally marketed predicate devices should not be submitted for review as a Special 510(k). For example, if a manufacturer of a contact lens disinfecting solution wanted to change from hydrogen peroxide to an antiseptic that had not been previously used in a legally marketed predicate, such a change would not be appropriate for review as a Special 510(k). Both of the above types of modifications involve major changes in the principle component of the device and thus would be considered a change to the fundamental scientific technology of the device and should be submitted for review as either Abbreviated or Traditional 510(k)s.

A change, however, in formulation in a material or a change to a type of material that has been used in other legally marketed devices within the same classification regulation for the same intended use could be reviewed as a Special 510(k). This should be true for both non-contacting devices as well as implants and devices that contact body tissues or fluids. Thus, a manufacturer of a hip implant could change from one alloy to one that has been used in another legally marketed predicate through the submission of a Special 510(k). Similarly, a contact lens manufacturer could submit a Special 510(k) for a change in their polymer to another material that has been used in a legally marketed predicate. Finally, changes in an inactive or secondary ingredient/agent should be appropriate for review as Special 510(k)s as this should not be considered a major change to the fundamental scientific technology of the device. For example, a manufacturer of a urologic catheter could submit a Special 510(k) to add an antimicrobial coating to the device if the coating has been used on another legally marketed predicate of the same material.

Device modifications that should be appropriate for review as Special 510(k)s also include those changes identified below:

a. Energy type
b. Environmental specifications
c. Performance specifications
d. Ergonomics of the patient-user interface
e. Dimensional specifications
f. Software or firmware
g. Packaging or expiration dating
h. Sterilization

It should be noted that in cases where FDA has issued guidance, established special controls, or recognized standards that address issues such as device testing or performance, manufacturers should consider this in their implementation of design control requirements. For example, if a manufacturer is modifying a contact lens, then the manufacturer’s design control inputs should include the special controls that FDA has established for this device. Further, if a manufacturer modifies an in vitro diagnostic, the manufacturer’s design inputs should include any recognized clinical standards such as those developed by the National Committee of Clinical Laboratory Standards (NCCLS) or a reasonable alternative. Thus, submitters of Special 510(k)s need to be aware of any relevant guidance documents, special controls, or recognized standards that apply to their device and that should be addressed by their design control processes.

III. Clinical Considerations

FDA recognizes that clinical evaluation may be involved in the validation of the design of a modified device. Manufacturers are reminded that all clinical investigations must conform to the applicable regulations, including 21 CFR Parts 812, 50 and 56. Therefore, collection of clinical data to support a Special 510(k) may require submission of an investigational device exemptions (IDE) application to FDA. The fact that a significant risk device investigation was conducted to support any of the activities listed above, however, does not necessarily preclude the submission of a Special 510(k).

Manufacturers who intend to conduct clinical investigations of a modified device as part of design validation are encouraged to contact the appropriate ODE review division before preparing a Special 510(k). When a clinical investigation is necessary to answer safety and effectiveness questions relating to a particular modification, the Agency believes that the modification is likely to have gone beyond that which is suitable for review as a Special 510(k). In contrast, where design validation involves clinical evaluation intended to ensure that the modified device meets user requirements as opposed to patient safety and effectiveness or to demonstrate continued conformance with a special control or recognized standard, FDA believes that the Special 510(k) may be the appropriate submission.

B. Abbreviated 510(k)

Over the past few years, FDA has been placing greater emphasis on the development of guidance documents to communicate regulatory and scientific expectations to industry. In the 510(k) area, numerous guidance documents exist, while others are under development for Class I, Class II and preamendments Class III devices. With the advent of Good Guidance Practices, device ­specific guidance documents are developed with public participation. The main focus of these guidance documents is the identification of the information recognized as appropriate for marketing authorization. FDA believes that use of these device-specific guidances may provide an effective means of streamlining the review of 510(k)s through a reliance on a “summary report” outlining adherence to relevant guidance documents. A 510(k) submission that conforms with an FDA guidance document should be easier to prepare and review, thus resulting in a more expeditious evaluation and clearance of the 510(k).

The SMDA introduced the concept of special controls as a means by which the safety and effectiveness of Class II devices can be assured. Special controls are defined in section 513(a)(1)(B) of the Act as those controls, such as performance standards, postmarket surveillance, patient registries, development and dissemination of guidelines, recommendations and other appropriate actions that provide reasonable assurance of the device’s safety and effectiveness. As in the case of guidance documents, summary information that describes how a special control(s) has been used to address a specific risk or issue should reduce the time and effort to prepare and review 510(k)s.

In addition to device-specific guidance documents (hereinafter referred to as guidance documents) and special controls, CDRH is committed to recognizing individual consensus standards. In fact, the FDAMA amended section 514 of the Act to specifically authorize the Agency to recognize all or part of national and international standards through publication of a notice in the Federal Register. Recognized standards could be cited in guidance documents or individual policy statements, or established as special controls that address specific risks associated with a type of device. IEC 60601-1 is an example of such a consensus standard. It has broad applicability to many electromedical devices. FDA’s recognition of this standard, combined with modified review procedures, should streamline the review of many 510(k)s for devices covered by the standard. Finally, by using accompanying particular standards to adapt a general standard to a specific device, the 510(k) review process may be further expedited.

Therefore, device manufacturers may choose to submit an Abbreviated 510(k) when: (1) a guidance documents exists, (2) a special control has been established, or (3) FDA has recognized a relevant consensus standard.5 An Abbreviated 510(k) submission must include the required elements identified in 21 CFR 807.87. In addition, manufacturers submitting an Abbreviated 510(k) that relies on a guidance document and/or special control(s) should include a summary report that describes how the guidance document and/or special control(s) were used during device development and testing. (See Attachment 3.) The summary report should include information regarding the manufacturer’s efforts to conform with the guidance document and/or special control(s) and should outline any deviations. Persons submitting an Abbreviated 510(k) that relies on a recognized standard should provide the information described in Attachment 3 (except for the summary report) and a declaration of conformity to the recognized standard. (See Attachment 4.) Such persons should also refer to the Agency’s guidance entitled, “Guidance on the Recognition and Use of Consensus Standards.”

In an Abbreviated 510(k), a manufacturer will also have the option of using a third party to assess conformance with the recognized standard. Under this scenario, the third party will perform a conformance assessment to the standard for the device manufacturer and should provide the manufacturer with a statement to this effect. Like a Special 510(k), the marketing application should include a declaration of conformity signed by the manufacturer, while the statement from the third party should be maintained in the DMR pursuant to the Quality System Regulation. Responsibility for conformance with the recognized standard, however, rests with the manufacturer, not the third party.

The incentive for manufacturers to elect to provide summary reports on the use of guidance documents and/or special controls or declarations of conformity to recognized standards will be an expedited review of their submissions. While abbreviated submissions will compete with traditional 510(k) submissions, it is anticipated that their review will be more efficient than that of traditional submissions, which tend to be data intensive. In addition, by allowing ODE reviewers to rely on a manufacturer’s summary report on the use of a guidance document and/or special controls and declarations of conformity with recognized standards, review resources can be directed at more complicated issues and thus should expedite the process.


5For a current list of FDA recognized standards, please refer to CDRH’s home page at or CDRH’s Facts on Demand at 1-800-899-0381.



FDA believes that the New 510(k) Paradigm will provide considerable flexibility for the medical device industry in demonstrating substantial equivalence in 510(k) submissions. The principles presented in this guidance document will be implemented through changes in the administrative processes and do not require changes to either the premarket notification regulation (21 CFR 807 Subpart E Premarket Notification Procedures) or to the Act. As experience is gained by the industry in preparing Special and Abbreviated 510(k)s and by FDA in evaluating these new types of 510(k) submissions, this guidance document may be updated and revised. CDRH will create and update a “New 510(k) Paradigm” website on the CDRH home page with information regarding this guidance as it becomes available. Device manufacturers should access this website for copies of Special/Abbreviated 510(k) coversheets, checklists, and additional information regarding implementation of the New Paradigm.

Effective Date: This guidance document is effective March 20, 1998.

Flow Chart of The New 510(k) Paradigm
Attachment 2

“Special 510(k): Device Modification”

A Special 510(k): Device Modification should include:

  • A coversheet clearly identifying the application as a “Special 510(k): Device Modification”;
  • The name of the legally marketed (unmodified) device and the 510(k) number under which it was cleared6,7 ;
  • Items required under §807.87, including a description of the modified device and a comparison to the cleared device, the intended use of the device, and the proposed labeling for the device;
  • A concise summary of the design control activities. FDA may consider the information generated from these activities to be “appropriate supporting data” within the meaning of §807.87(g). This summary should include the following:
    • An identification of the Risk Analysis method(s) used to assess the impact of the modification on the device and its components as well as the results of the analysis;
    • Based on the Risk Analysis, an identification of the verification and/or validation activities required, including methods or tests used and the acceptance criteria applied; and
    • A declaration of conformity with design controls. The declaration of conformity should include:
      1. A statement that, as required by the risk analysis, all verification and validation activities were performed by the designated individual(s) and the results demonstrated that the predetermined acceptance criteria were met; and
      2. A statement that the manufacturing facility is in conformance with the design control procedure requirements as specified in 21 CFR 820.30 and the records are available for review.
        ** The above two statements should be signed by the designated individual(s) responsible for those particular activities.
  • – Indications for Use enclosure.


6 When the legally marketed (unmodified) device is a preamendments device, the submitter should clearly state that the device is a preamendments device, is legally marketed, and has not been the subject of premarket notification clearance. (Refer to “Documentation Required for Preamendments Status” for the procedures for demonstrating preamendments status. Submitters should maintain this information in their files.)

7 In cases where the referenced 510(k) was submitted under a different name than that of the submitter of the Special 510(k), the Agency recommends that a statement to this effect be included in the Special 510(k) and that the submitter maintain adequate information demonstrating his legal right to distribute the device.

8 If a recent Quality System inspection has resulted in the issuance of a violative inspection report, the manufacturer should be prepared to describe those corrective actions taken, if needed, that form the basis for the declaration of conformity.


Attachment 3
“Abbreviated 510(k)” Content

An Abbreviated 510(k) should include:

  • A coversheet clearly identifying the application as an “Abbreviated 510(k)”;
  • Items required under §807.87, including a description of the device, the intended use of the device, and the proposed labeling for the device;
  • For a submission that relies on a guidance document and/or special control(s), a summary report that describes how the guidance and/or special control(s) were used to address the risks associated with the particular device type. (If a manufacturer elects to use an alternative approach to address a particular risk, sufficient detail should be provided to justify that approach.);
  • For a submission that relies on a recognized standard, a declaration of conformity to the standard. (The declaration should be submitted in accordance with Attachment 4.);
  • Data/information to address issues not covered by guidance documents, special controls, and/or recognized standards; and
  • Indications for Use enclosure.


Attachment 4
Declaration of Conformity to a Recognized Standard

In preparing a declaration of conformity to recognized standards, manufacturers should refer to the guidance document entitled, “Guidance on the Recognition and Use of Consensus Standards.” In accordance with this guidance, declarations of conformity to recognized standards should include the following:

  • An identification of the applicable recognized consensus standards that were met;
  • A specification, for each consensus standard, that all requirements were met, except for inapplicable requirements or deviations noted below;
  • An identification, for each consensus standard, of any way(s) in which the standard may have been adapted for application to the device under review, e.g., an identification of an alternative series of tests that were performed;
  • An identification, for each consensus standard, of any requirements that were not applicable to the device;
  • A specification of any deviations from each applicable standard that were applied (e.g., deviations from international standards which are necessary to meet U.S. infrastructure conventions such as the National Electrical Code (ANSI/NFPA 70));
  • A specification of the differences that may exist, if any, between the tested device and the device to be marketed and a justification of the test results in these areas of difference; and
  • The name and address of any test laboratory or certification body involved in determining the conformance of the device with the applicable consensus standards and a reference to any accreditations of those organizations.




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Medical Device Fellowship Program

Posted on May 27, 2012. Filed under: Syringe Blog | Tags: , , , , , , , , , , , , , , , , , , , , , , , , , |

Medical Device Fellowship Program




The Center for Devices and Radiological Health (CDRH) Medical Device Fellowship Program (MDFP) provides opportunities for health professionals to participate in the FDA regulatory process for medical devices. MDFP is part of External Expertise and Partnerships (EEP) in the Office of the Center Director (OCD) in CDRH.  In addition to MDFP, other components of EEP include Technology Transfer and Partnerships, and the Critical Path Initiative.

CDRH regulates a wide array of medical devices and is involved with the latest medical device cutting-edge technology areas such as genomics, proteomics, diagnostics for personalized medicine, percutaneous heart valves, artificial hearts, tissue engineered wound dressing with cells, and bone void fillers with growth factors, and many others.

To keep pace with the rapid development of new technology, and to make decisions based on the best scientific information and knowledge available, CDRH routinely consults with experts in the academic community, other government entities, clinical practice, and the military. By filling gaps in expertise for a finite period of time, EEP enhances the efficiency and effectiveness of CDRH operations. EEP is the focal point of all CDRH fellowships and interorganizational partnerships. EEP also fosters scientific innovation by helping offices form partnerships with academia, private sector organizations, and government agencies.

CDRH established MDFP to increase the range and depth of collaborations between CDRH and the outside scientific community. The MDFP offers short and long-term fellowship opportunities for individuals interested in learning about the regulatory process and sharing their knowledge and experience with medical devices from the relatively simple to the highly complex.

Physicians with clinical or surgical expertise, engineers in biomedical, mechanical, electrical and software areas, and individuals from many other scientific disciplines have participated in the fellowship program. Opportunities are available for students in many areas as well.

Career Development

Learn about the FDA approval process for medical devices:

  • medical device design
  • clinical trial design and data
  • safety and efficacy evaluation
  • materials, performance, bioeffects and standards
  • adverse events


Public Service

  • Join CDRH’s mission to protect the public health by ensuring that medical devices are safe and effective
  • Share your expertise on complex device issues
  • Make a difference in the lives of patients and consumers


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How to Report a Medical Device Problem

Posted on May 24, 2012. Filed under: Syringe Blog | Tags: , , , , , , , , , , , , , , |

How to Report a Medical Device Problem

What is Medical Device Reporting (MDR)?

Medical Device Reporting (MDR) is the mechanism for the Food and Drug Administration to receive significant medical device adverse events from manufacturers, importers and user facilities, so they can be detected and corrected quickly. If you are a consumer or health professional you should use the nearby link to the MedWatch program for reporting significant adverse events or product problems with medical products.

User Facilities and MDR

User Facilities (e.g., hospitals, nursing homes) are required to report suspected medical device related deaths to both the FDA and the manufacturers. User facilities report medical device related serious injuries only to the manufacturer. If the medical device manufacturer is unknown, the serious injury is reported by the facility to FDA. Health professionals within a user-facility should familiarize themselves with their institution procedures for reporting adverse events to the FDA.
There is a guidance for user facilities, “Medical Device Reporting for User Facilities”.  See its nearby link.
Note: Please do not send the actual device to FDA as stated in Block D9 of the MEDWATCH 3500A form. In Block D9 indicate that you are keeping the device or returning it to the manufacturer.

History of MDR Regulation

Legislation requiring device user facility reporting was enacted by Congress to increase the amount of information the Food and Drug Administration (FDA) and device manufacturers receive about problems with medical devices. Although manufacturers and importers of medical devices have been required since 1984 to report to FDA all device-related deaths, serious injuries, and certain malfunctions, numerous reports have shown there is widespread underreporting. A 1986 General Accounting Office (GAO) study showed that less than one percent of device problems occurring in hospitals are reported to FDA, and the more serious the problem with a device, the less likely it was to be reported. A GAO followup study in 1989 concluded that despite full implementation of the Medical Device Reporting (MDR) regulation, serious shortcomings still existed.

Under the Safe Medical Devices Act of 1990 (SMDA), device user facilities must report device-related deaths to the FDA and the manufacturer, if known. Device user facilities must also report device-related serious injuries to the manufacturer, or to the FDA if the manufacturer is not known. In addition, SMDA also required that device user facilities submit to FDA, on a semiannual basis, a summary of all reports submitted during that time period. The device user facility reporting section of SMDA became effective on November 28, 1991.

To implement SMDA, FDA published a tentative final rule in the Federal Register on November 26, 1991, and invited comments on the regulation. Over 300 comments were received by FDA. Then, on June 16, 1992, the President signed into law the Medical Devices Amendments of 1992 (Public Law 102-300; the Amendments of 1992), amending certain provisions (section 519 of the Food, Drug, and Cosmetic Act) relating to reporting of adverse events. The primary impact of the 1992 Amendments on device user facility reporting was to clarify certain terms and to establish a single reporting standard for device user facilities, manufacturers, importers, and distributors. A final rule published in the Federal Register on December 11, 1995, addresses the comments received by the FDA and the changes mandated by the Amendments of 1992.

Update on FDAMA

The Food and Drug Administration Modernization Act (FDAMA) was signed on 11/21/97 and became effective on 2/19/98. There were four changes that affected MDR:

  • Manufacturers and distributors/importers do not need to submit annual certification.
  • Domestic distributors are no longer required to file MDR reports, but must continue to maintain complaint files. [Importers (initial distributors for devices manufactured overseas and imported into the USA) must continue to file MDR reports.]
  • User facilities must now file an annual report instead of semiannual reports to summarize their adverse event reports.
  • Sentinel reporting by user facilities was proposed.
    The MDR regulation was revised on 1/26/2000 and 5/8/2000 to incorporate the changes under FDAMA

See the nearby link to amendments to the MDR regulation that implemented FDAMA changes, effective March 27, 2000.



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Requirements To Export of Legally Marketed Devices

Posted on May 22, 2012. Filed under: Syringe Blog | Tags: , , , , , , , , , , , |

Export of Legally Marketed Devices



Any medical device that is legally in the U.S. may be exported anywhere in the world without prior FDA notification or approval.

The export provisions under section 802 of the FD&C Act only applies to unapproved devices. For a device to be legally in commercial distribution in the U.S., the following requirements must be met:


  • The manufacturing facility must be registered with FDA;
  • The device must be listed with FDA;
  • The device must have a cleared Premarket Notification 510(k) or Premarket Approval (PMA) unless exempted by regulation or if the device was on the market prior to May 28, 1976 (before the Medical Device Amendments to the FD&C Act);
  • The device must meet the labeling requirements of 21 CFR Part 801and 21 CFR 809, if applicable;
  • The device must be manufactured in accordance with the Quality Systems (QS) Regulation of 21 CFR Part 820 (also known as Good Manufacturing Practices or GMP), unless exempted by regulation.

In addition, the U.S. exporter must comply with the laws of the importing country.
Please note that U.S. manufactures that export medical devices outside the U.S. are required to register their facility and list their devices (21 CFR 807).

Device Registration and Listing



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What Is A Medical Device?

Posted on May 21, 2012. Filed under: Syringe Blog | Tags: , , , , , , , , , , , , , , , , , |

A medical device is an instrument, apparatus, implant, in vitro reagent, or other similar or related article, which is intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease, or intended to affect the structure or any function of the body and which does not achieve any of its primary intended purposes through chemical action within or on the body.[1] Whereas medicinal products (also called pharmaceuticals) achieve their principal action by pharmacological, metabolic or immunological means, medical devices act by other means like physical, mechanical, thermal, physico-chemical or chemical means.

Medical devices include a wide range of products varying in complexity and application. Examples include tongue depressors, medical thermometers, and blood sugar meters.

The global market of medical devices reached roughly 209 billion US Dollar in 2006 and is expected to grow with an average annual rate of 6–9% through 2010.[2]


European Union legal framework and definition

Based on the “New Approach”, rules relating to the safety and performance of medical devices were harmonised in the EU in the 1990s. The “New Approach”, defined in a European Council Resolution of May 1985, represents an innovative way of technical harmonisation. It aims to remove technical barriers to trade and dispel the consequent uncertainty for economic operators allowing for the free movement of goods inside the EU.

The core legal framework consists of 3 directives:

  • Directive 90/385/EEC regarding active implantable medical devices;
  • Directive 93/42/EEC regarding medical devices;
  • Directive 98/79/EC regarding in vitro diagnostic medical devices.

They aim at ensuring a high level of protection of human health and safety and the good functioning of the Single Market. These 3 main directives have been supplemented over time by several modifying and implementing directives, including the last technical revision brought about by Directive 2007/47 EC.

Directive 2007/47/ec defines a medical device as: “any instrument, apparatus, appliance, software, material or other article, whether used alone or in combination, including the software intended by its manufacturer to be used specifically for diagnostic and/or therapeutic purposes and necessary for its proper application, intended by the manufacturer to be used for human beings. Devices are to be used for the purpose of:

  • Diagnosis, prevention, monitoring, treatment or alleviation of disease.
  • Diagnosis, monitoring, treatment, alleviation of or compensation for an injury or handicap.
  • Investigation, replacement or modification of the anatomy or of a physiological process
  • Control of conception

This includes devices that do not achieve its principal intended action in or on the human body by pharmacological, immunological or metabolic means, but which may be assisted in its function by such means.”

The government of each Member State is required to appoint a Competent Authority responsible for medical devices. The Competent Authority (CA) is a body with authority to act on behalf of the government of the Member State to ensure that the requirements of the Medical Device Directives are transposed into National Law and are applied. The Competent Authority reports to the Minister of Health in the Member State. • The Competent Authority in one Member State does not have jurisdiction in any other Member State, but they do exchange information and try to reach common positions.

In UK the Medicines and Healthcare products Regulatory Agency (MHRA) acts as a CA, in Italy it is the Ministero Salute (Ministry of Health)[3]

Medical devices must not be mistaken with medicinal products. In the EU, all medical devices must be identified with the CE mark.

Definition in USA by the Food and Drug Administration

Medical machine, contrivance, implant, in vitro reagent, or other similar or related article, including a component part, or accessory that is:

  • recognized in the official National Formulary, or the United States Pharmacopoeia, or any supplement to them,
  • intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment or prevention of disease, in man or other animals, or
  • intended to affect the structure or any function of the body of man or other animals, and which does not achieve any of its primary intended purposes through chemical action within or on the body of man or other animals and which is not dependent upon being metabolized for the achievement of any of its primary intended purposes.

>>> Medical Device Definition US FDA <<<

Definition in Canada by the Food and Drugs Act

The term medical devices, as defined in the Food and Drugs Act, covers a wide range of health or medical instruments used in the treatment, mitigation, diagnosis or prevention of a disease or abnormal physical condition. Health Canada reviews medical devices to assess their safety, effectiveness and quality before being authorized for sale in Canada[citation needed].


The regulatory authorities recognize different classes of medical devices, based on their design complexity, their use characteristics, and their potential for harm if misused. Each country or region defines these categories in different ways. The authorities also recognize that some devices are provided in combination with drugs, and regulation of these combination products takes this factor into consideration.


The Medical Devices Bureau of Health Canada has recognized four classes of medical devices based on the level of control necessary to assure the safety and effectiveness of the device. Class I devices present the lowest potential risk and do not require a licence. Class II devices require the manufacturer’s declaration of device safety and effectiveness, whereas Class III and IV devices present a greater potential risk and are subject to in-depth scrutiny.[4] A guidance document for device classification is published by Health Canada .[5]

Canadian classes of medical devices generally correspond to the European Council Directive 93/42/EEC (MDD) devices as follows: Class IV (Canada) generally corresponds to Class III (ECD), Class III (Canada) generally corresponds to Class IIb (ECD), Class II (Canada) generally corresponds to Class IIa (ECD), and Class I (Canada) generally corresponds to Class I (ECD) .[6] Examples are surgical instruments (Class I); contact lenses, ultrasound scanners (Class II); orthopedic implants, hemodialysis machines (Class III); and cardiac pacemakers (Class IV) .[7]

United States

The Food and Drug Administration has recognized three classes of medical devices based on the level of control necessary to assure the safety and effectiveness of the device.[8] The classification procedures are described in the Code of Federal Regulations, Title 21, part 860 (usually known as 21 CFR 860).[9]

Class I: General controls

Class I devices are subject to the least regulatory control. Class I devices are subject to “General Controls” as are Class II and Class III devices.[8][10][11] General controls include provisions that relate to adulteration; misbranding; device registration and listing; premarket notification; banned devices; notification, including repair, replacement, or refund; records and reports; restricted devices; and good manufacturing practices.[11] Class I devices are not intended for use in supporting or sustaining life or to be of substantial importance in preventing impairment to human health, and they may not present a potential unreasonable risk of illness or injury.[11] Most Class I devices are exempt from the premarket notification and/or good manufacturing practices regulation.[8][10][11] Examples of Class I devices include elastic bandages, examination gloves, and hand-held surgical instruments.[10]

Class II: General controls with special controls

Class II devices are those for which general controls alone are insufficient to assure safety and effectiveness, and existing methods are available to provide such assurances.[8][10] In addition to complying with general controls, Class II devices are also subject to special controls.[10] A few Class II devices are exempt from the premarket notification.[10] Special controls may include special labeling requirements, mandatory performance standards and postmarket surveillance.[10] Devices in Class II are held to a higher level of assurance than Class I devices, and are designed to perform as indicated without causing injury or harm to patient or user. Examples of Class II devices include powered wheelchairs, infusion pumps, and surgical drapes.[8][10]

Class III: General controls and premarket approval

A Class III device is one for which insufficient information exists to assure safety and effectiveness solely through the general or special controls sufficient for Class I or Class II devices.[8][10] Such a device needs premarket approval, a scientific review to ensure the device’s safety and effectiveness, in addition to the general controls of Class I.[8][10] Class III devices are usually those that support or sustain human life, are of substantial importance in preventing impairment of human health, or which present a potential, unreasonable risk of illness or injury.[10] Examples of Class III devices which currently require a premarket notification include implantable pacemaker, pulse generators, HIV diagnostic tests, automated external defibrillators, and endosseous implants.[10]

European Union (EU) and European Free Trade Association (EFTA)

The classification of medical devices in the European Union is outlined in Annex IX of the Council Directive 93/42/EEC. There are basically four classes, ranging from low risk to high risk.

  • Class I (including Is & Im)
  • Class IIa
  • Class IIb
  • Class III

The authorization of medical devices is guaranteed by a Declaration of Conformity. This declaration is issued by the manufacturer itself, but for products in Class Is, Im, IIa, IIb or III, it must be verified by a Certificate of Conformity issued by a Notified Body. A Notified Body is a public or private organisation that has been accredited to validate the compliance of the device to the European Directive. Medical devices that pertain to class I (on condition they do not need to be sterilised or are not used to measure a function) can be put on the market purely by self-certification.

The European classification depends on rules that involve the medical device’s duration of body contact, its invasive character, its use of an energy source, its effect on the central circulation or nervous system, its diagnostic impact or its incorporation of a medicinal product.

Certified medical devices should have the CE mark on the packaging, insert leaflets, etc.. These packagings should also show harmonised pictograms and EN standardised logos to indicate essential features such as instructions for use, expiry date, manufacturer, sterile, don’t reuse, etc.


The classification of medical devices in Australia is outlined in section 41BD of the Therapeutic Goods Act 1989 and Regulation 3.2 of the Therapeutic Goods Regulations 2002, under control of the Therapeutic Goods Administration. Similarly to the EU classification, they rank in several categories, by order of increasing risk and associated required level of control; various rules exist in the regulation which allow for the device’s category to be identified [12]

Medical Devices Categories in Australia
Classification Level of Risk
Class I Low
Class I – measuring or Class I – supplied sterile or class IIa Low – medium
Class IIb Medium – high
Class III High
Active implantable medical devices (AIMD) High

Radio-frequency identification

Medical devices incorporating RFID

In 2004, the FDA authorized marketing of two different types of medical devices that incorporate radio-frequency identification, or RFID. The first type is the SurgiChip tag, an external surgical marker that is intended to minimize the likelihood of wrong-site, wrong-procedure and wrong-patient surgeries. The tag consists of a label with passive transponder, along with a printer, an encoder and a RFID reader. The tag is labeled and encoded with the patient’s name and the details of the planned surgery, and then placed in the patient’s chart. On the day of surgery, the adhesive-backed tag is placed on the patient’s body near the surgical site. In the operating room the tag is scanned and the information is verified with the patient’s chart. Just before surgery, the tag is removed and placed back in the chart.

The second type of RFID medical device is the implantable radiofrequency transponder system for patient identification and health information. One example of this type of medical device is the VeriChip, which includes a passive implanted transponder, inserter and scanner. The chip stores a unique electronic identification code that can be used to access patient identification and corresponding health information in a database. The chip itself does not store health information or a patient’s name.[13]

Practical and information security considerations

Companies developing RFID-containing medical devices must consider product development issues common to other medical devices that come into contact with the body, are implanted in the body, or use computer software. For example, as part of product development, a company must implement controls and conduct testing on issues such as product performance, sterility, adverse tissue reactions, migration of the implanted transponder, electromagnetic interference, and software validation.

Medical devices that use RFID technology to store, access, and/or transfer patient information also raise significant issues regarding information security. The FDA defines “information security” as the process of preventing the modification, misuse or denial of use, or the unauthorized use of that information. At its core, this means ensuring the privacy of patient information.[13]

Four components of information security

The FDA has recommended that a company’s specifications for implantable RFID-containing medical devices address the following four components of information security: confidentiality, integrity, availability and accountability (CIAA).

  • Confidentiality means data and information are disclosed only to authorized persons, entities and processes at authorized times and in the authorized manner. This ensures that no unauthorized users have access to the information.
  • Integrity means data and information are accurate and complete, and the accuracy and completeness are preserved. This ensures that the information is correct and has not been improperly modified.
  • Availability means data, information and information systems are accessible and usable on a timely basis in the required manner. This ensures that the information will be available when needed.
  • Accountability is the application of identification and authentication to ensure that the prescribed access process is followed by an authorized user.

Although the FDA made these recommendations in the context of implantable RFID-containing medical devices, these principles are relevant to all uses of RFID in connection with pharmaceuticals and medical devices.[13]

Medical devices and technological security issues

Medical devices such as pacemakers, insulin pumps, operating room monitors, defibrillators, surgical instruments including deep-brain stimulators are being made with the ability to transmit vital health information from a patient’s body to doctors and other professionals.[14] Some of these devices can be remotely controlled by medical professionals. There has been concern about privacy and security issues around human error and technical glitches with this technology. While only a few studies have been done on the susceptibility of medical devices to hacking, there is a risk.[15] In 2008, computer scientists proved that pacemakers and defibrillators can be hacked wirelessly through the use of radio hardware, an antenna and a personal computer[16] These researchers showed that they could shut down a combination heart defibrillator and pacemaker and reprogram it to deliver potentially lethal shocks or run out its battery. Jay Radcliff, a security researcher interested in the security of medical devices, raises fears about the safety of these devices. He shared his concerns at the Black Hat security conference.[17] Radcliff fears that the devices are vulnerable and has found that a lethal attack is possible against those with insulin pumps and glucose monitors. Some medical device makers downplay the threat from such attacks and argue that the demonstrated attacks have been performed by skilled security researchers and are unlikely to occur in the real world. At the same time, other makers have asked software security experts to investigate the safety of their devices.[18] As recently as June 2011, security experts showed that by using readily available hardware and a user manual, a scientist could both tap into the information on the system of a wireless insulin pump in combination with a glucose monitor. With a PIN access code of the device, the scientist could wirelessly control the dosage of the insulin.[19] Anand Raghunathan, a researcher in this study explains that medical devices are getting smaller and lighter so that they can be easily worn. The downside is that additional security features would put an extra strain on the battery and size and drive up prices. Dr. William Maisel offered some thoughts on the motivation to engage in this activity. Motivation to do this hacking might include acquisition of private information for financial gain or competitive advantage; damage to a device manufacturer’s reputation; sabotage; intent to inflict financial or personal injury or just satisfaction for the attacker.[20] Researchers suggest a few safeguards. One would be to use rolling codes. Another solution is to use a technology called “body-coupled communication” that uses the human skin as a wave guide for wireless communication.[19]

Standardization and regulatory concerns

The ISO standards for medical devices are covered by ICS 11.100.20 and 11.040.01.[21][22] The quality and risk management regarding the topic for regulatory purposes is convened by ISO 13485 and ISO 14971. ISO 13485:2003 is applicable to all providers and manufacturers of medical devices, components, contract services and distributors of medical devices. The standard is the basis for regulatory compliance in local markets, and most export markets.[23][24][25] Further standards are IEC 60601-1, for electrical devices (mains-powered as well as battery powered) and IEC 62304 for medical software. The US FDA also published a series of guidances for industry regarding this topic against 21 CFR 820 Subchapter H—Medical Devices.[26]

Starting in the late 1980s [27] the FDA increased its involvement in reviewing the development of medical device software. The precipitant for change was a radiation therapy device (Therac-25) that overdosed patients because of software coding errors.[28] FDA is now focused on regulatory oversight on medical device software development process and system-level testing.[29]

A 2011 study by Dr. Diana Zuckerman and Paul Brown of the National Research Center for Women and Families, and Dr. Steven Nissen of the Cleveland Clinic, published in the Archives of Internal Medicine, showed that most medical devices recalled in the last five years for “serious health problems or death” had been previously approved by the FDA using the less stringent, and cheaper, 510(k) process. In a few cases the devices had been deemed so low-risk that they did not need FDA regulation. Of the 113 devices recalled, 35 were for cardiovacular issues.[30] This may lead to a reevaluation of FDA procedures and better oversight.

Packaging standards

Medical device packaging is highly regulated. Often medical devices and products are sterilized in the package.[31] The sterility must be maintained throughout distribution to allow immediate use by physicians. A series of special packaging tests is used to measure the ability of the package to maintain sterility. Relevant standards include: ASTM D1585 – Guide for Integrity Testing of Porous Medical Packages, ASTM F2097 – Standard Guide for Design and Evaluation of Primary Flexible Packaging for Medical Products, EN 868 Packaging materials and systems for medical devices which are to be sterilized. General requirements and test methods, ISO 11607 Packaging for terminally sterilized medical devices, and others.

Package testing needs to conducted and documented to ensure that packages meet regulations and all end-use requirements. Manufacturing processes need to be controlled and validated to ensure consistent performance.[32][33]

Cleanliness standards

The cleanliness of medical devices has come under greater scrutiny since 2000, when Sulzer Orthopedics recalled several thousand metal hip implants that contained a manufacturing residue.[34] Based on this event, ASTM established a new task group (F04.15.17) for established test methods, guidance documents, and other standards to address cleanliness of medical devices. This task group has issued two standards for permanent implants to date: 1. ASTM F2459: Standard test method for extracting residue from metallic medical components and quantifying via gravimetric analysis[35] 2. ASTM F2847: Standard Practice for Reporting and Assessment of Residues on Single Use Implants[36]

In addition, the cleanliness of re-usable devices has led to a series of standards, including the following: 1. ASTM E2314: Standard Test Method for Determination of Effectiveness of Cleaning Processes for Reusable Medical Instruments Using a Microbiologic Method (Simulated Use Test)[37] 2. ASTM D7225: Standard Guide for Blood Cleaning Efficiency of Detergents and Washer-Disinfectors.[38]

The ASTM F04.15.17 task group is working on several new standards involving designing implants for cleaning, validation of cleanlines, and recipes for test soils to establish cleaning efficacy.[39] Additionally, the FDA is establishing new guidelines for reprocessing reusable medical devices, such as orthoscopic shavers, endoscopes, and suction tubes.[40]

Academic resources

  • Medical & Biological Engineering & Computing
  • Expert Review of Medical Devices
  • Journal of Clinical Engineering [41]

A number of specialist University-based research institutes have been established such as the Medical Devices Center (MDC) at the University of Minnesota in the US, the Strathclyde Institute Of Medical Devices (SIMD) at the University of Strathclyde in Scotland and the Medical Device Research Institute (MDRI) at Flinders University in Australia.

Source ~ Wikipedia

See also

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Posted on May 18, 2012. Filed under: Syringe Blog | Tags: , , , , , , , , , , , , , , , , , |


Group purchasing organizations (GPOs) play an important role in the provision of health care services in the United States. As hospitals and other health care providers have come under pressure to reduce expenses, they have turned increasingly to GPOs to reduce the costs of the products and services they purchase. Today, virtually every hospital in the U.S. belongs to at least one GPO. More than seventy percent of all hospital purchases are made through GPO contracts, and GPOs contract for purchases with an annual value in the range of $150 billion.

The fundamental purpose of a GPO is to allow its members to join together to leverage their purchasing strength in order to purchase goods and services at lower prices, which in turn should enable them to lower their costs and become more competitive in the provision of their own services. In its basic form, a GPO is a cooperative of buyers. Over time, however, GPOs have evolved significantly to offer other competition-enhancing programs such as networking, bench marking, and educational quality improvement programs. These functions are pro-competitive and consistent with antitrust policy – they offer GPO members increased efficiency, eliminate wasteful administrative duplication, and they increase competition between manufacturers/vendors, and within the hospital members’ own markets, which translate into lower prices and higher quality for consumers.

At a time when increasing health care costs are a major policy concern, one would expect GPOs to be seen as a major force in the health care industry for increased efficiency and cost containment. In fact, GPOs currently are under attack from several different directions. On the political front, GPOs have come under attack by some manufacturers of medical devices that claim GPO contracting practices, including “sole-source contracts,” percentage of purchase or “market share” discounts, and multi-product or “bundled” discounts, favor large established manufacturers with the result that smaller companies with “innovative” products are effectively foreclosed from selling to a large number of the nation’s hospitals. These concerns have attracted the attention of the U.S. Senate, which held hearings last year scrutinizing GPO contracting practices; the Senate may hold additional hearings on GPOs in 2003. Similarly, the Federal Trade Commission (FTC) held a workshop last fall at which GPO contracting practices were a topic of discussion, and the FTC, together with the Antitrust Division of the Department of Justice (DOJ), are holding health care hearings in 2003 at which GPO contracting practices also are being discussed. Finally, a 2002 preliminary study by the General Accounting Office (GAO) raised questions about whether GPO contracts actually save hospitals money.  GPO contracts also have been the subject of recent private litigation. In Kinetic Concepts, Inc. v. Hillenbrand Indus., Inc., a jury awarded more than $500 million in treble damages against a manufacturer of hospital beds that allegedly was using GPO contracts to exclude plaintiff, its competitor. In a suit more directly implicating GPO practices, Retractable Technologies, Inc. v. Becton Dickinson, et al., a manufacturer of safety syringes sued the two largest manufacturers of standard and safety syringes along with the two largest GPOs, alleging, among other things, a conspiracy between the GPOs and manufacturers to monopolize the needle and syringe market.

The important role GPOs play in the delivery of health care services, and the criticism that has been directed at them, raise important issues under the antitrust laws. Are GPOs the agents of efficiency they claim to be, or, as their critics charge, have GPOs become a vehicle for dominant manufacturers to achieve and/or maintain monopoly power? This article analyzes GPO contracting practices under the antitrust laws and whether these practices are likely to result in anti-competitive effects. As this analysis will show, in general, GPO contracts promote significant efficiencies and are unlikely to result in sufficient market foreclosure to injure competition. The policy implications of this conclusion are clear: instead of increasing competition, restrictions on GPO contracting practices are likely to result in less competition and higher prices for health care consumers.

I. History and Background of Group Purchasing Organizations Hospital GPOs trace their history back to the late 1800s, though the first known hospital GPO was the Hospital Bureau of New York, which appeared in 1910.  Over the next half century, the GPO concept grew slowly and by the early 1970s there were forty hospital GPOs in the United States. The next thirty years witnessed an explosion of GPOs. From 1974 to 1999,the number of GPOs grew from forty to 633.  Today, there are over 900 GPOs in the United States. While some of these are “child” GPOs that rely on contracts negotiated by larger “parent” GPOs, it is estimated that approximately 200 GPOs contract directly with suppliers, and that twenty-six of these operate on a national level.

It is not a coincidence that GPOs began to grow in popularity in the late 1970s and early 1980s. During this time, for-profit hospital chains began to expand and buy up not-for-profit hospitals, forcing not-for-profits to find ways to cut costs to remain competitive. In the early 1980s, Medicare instituted the Prospective Payment System through which hospitals were reimbursed a fixed rate based on a defined service rather than the cost to the hospital of providing that service. At the same time, growing pressure in the private sector to reduce health care costs in the form of Health Maintenance Organizations (HMOs) and other types of managed care also reduced hospital reimbursement. These external market factors made it important for hospitals to control costs. Part of this effort included forming or joining a GPO to lower the cost of goods and services that the hospitals purchased.


Robert E. Bloch, Esq.
Scott P. Perlman, Esq,
Jay S. Brown, Esq.*
1909 K Street, N.W.
Washington, D.C. 20006
(202) 263-3000


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The Making Of A Syringe

Posted on May 17, 2012. Filed under: Syringe Blog | Tags: , , , , , , , , |

The Making Of A Syringe

The hypodermic syringe, also known as the hypodermic needle, is a device used by medical professionals to transfer liquids into or out of the body. It is made up of a hollow needle, which is attached to a tube and a plunger. When the plunger handle is pulled back, fluids are drawn into the tube. The fluid is forced out through the needle when the handle is pushed down. The syringe was introduced in the mid 1800s and has steadily improved with the development of new materials and designs. Today, it has become such an important medical tool that it is nearly a symbol synonymous with the practicing physician.

Since the advent of pharmaceutical drugs, methods for administering those drugs have been sought. Various important developments needed to occur before injections through a hypodermic syringe could be conceived. Early nineteenth century physicians were not aware that drugs could be introduced into the body through the skin. One early experiment that demonstrated this idea, however, was performed by Francois Magendie in 1809. In his published work, he outlined a method for introducing strychnine into a dog by using a coated wooden barb. In 1825, A. J. Lesieur described another method for administering drugs through the skin, applying them directly to blisters on the skin. Expanding on results from these experiments, G. V. Lafargue developed a procedure for introducing morphine under the skin using a lancet. A drip needle was invented by F. Rynd in 1844 for the same purpose. However, he did not publish his method until 1861, eight years after the first hypodermic syringe was described.

The first true hypodermic syringe was created by Alexander Wood in 1853. He modified a regular syringe, which at that time was used for treating birthmarks, by adding a needle. He then used this new device for introducing morphine into the skin of patients who suffered from sleeping disorders. A few years later, he added a graduated scale on the barrel and a finer needle. These modifications were enough to attract the attention of the rest of the medical community, resulting in its more widespread use.

Over the years hypodermic syringes have undergone significant changes that have made them more efficient, more useful, and safer. One such improvement was the incorporation of a glass piston within the cylinder. This innovation prevented leaks and reduced the chances of infections, making the device more reliable. The technology for the mass production of hypodermic syringes was developed in the late nineteenth century. As plastics developed, they were incorporated into the design, reducing cost and further improving safety.

The way in which a hypodermic needle works is simple. Fluid, such as a drug or blood, is drawn up through a hollow needle into the main tube when the plunger handle is pulled back. As long as the needle tip remains in the fluid while the plunger handle is pulled, air will not enter. The user can determine exactly how much material is in the tube by reading the measuring marks on the side of the tube. The liquid is dispensed out through the needle when the plunger handle is pushed back down.

The term hypodermic syringe comes from the Greek words hypo, meaning under, and derma, meaning skin. These terms are appropriate because they describe exactly how the device functions. The needle is used to pierce the top layer of the skin, and the material in the tube is injected in the layer below. In this subcutaneous layer, most injected materials will be readily accepted into the bloodstream and then circulated throughout the body.

A syringe is one of three primary methods for introducing a drug into the body. The others are transepidermal (through the skin) and oral. Using a hypodermic needle as the method of drug administration has some significant advantages over oral ingestion. First, the drugs are protected from the digestive system. This prevents them from being chemically altered or broken down before they can be effective. Second, since the active compounds are quickly absorbed into the bloodstream, they begin working faster. Finally, it is more difficult for the body to reject drugs that are administered by syringe. Transepidermal drug administration is a relatively new technology, and its effects are generally not as immediate as direct injection.

There are many hypodermic syringe designs available. However, all of them have the same general features, including a barrel, plunger, needle, and cap. The barrel is the part of the hypodermic needle that contains the material that is injected or withdrawn. A movable plunger is contained within this tube. The width of the barrel is variable. Some manufacturers make short, wide tubes, and others make long, thin ones. The exact design will depend to some extent on how the device will be used. The end of the barrel to which the needle is attached is tapered. This ensures that only the desired amount of material will be dispensed through the needle. At the base of the barrel away from the needle attachment, two arms flare out. These pieces allow the needle user to press on the plunger with the thumb while holding the tube in place with two fingers. The other end of the barrel is tapered.

The plunger, which is responsible for creating the vacuum to draw up materials and then discharge them, is made of a long, straight piece with a handle at one end and a rubber plunger head on the other. The rubber head fits snugly against the walls of the barrel, making an airtight seal. In addition to ensuring an accurate amount of material is drawn in, the squeegee action of the plunger head keeps materials off the inner walls of the tube.

The needle is the part of the device that actually pierces the layers of the skin. Depending on how deep the injection or fluid extraction will be, the needle orifice can be thinner or wider, and its length varies. It can also be permanently affixed to the body of the syringe or interchangeable. For the latter type of system, a variety of needles would be available to use for different applications. To prevent accidental needle stick injuries, a protective cap is placed over the top of the needle when it is not in use.

Raw Materials

Since hypodermic syringes come in direct contact with the interior of the body, government regulations require that they be made from biocompatible materials which are pharmacologically inert. Additionally, they must be sterilizable and nontoxic. Many different types of materials are used to construct the wide variety of hypodermic needles available. The needles are generally made of a heat-treatable stainless steel or carbon steel. To prevent corrosion, many are nickel plated. Depending on the style of device used, the main body of the tube can be made of plastic, glass, or both. Plastics are also used to make the plunger handle and flexible synthetic rubber for the plunger head.
The Manufacturing Process

There are many manufacturers of hypodermic needles, and while each one uses a slightly different process for production, the basic steps remain the same, including needle formation, plastic component molding, piece assembly, packaging, labeling, and shipping.

Making the needle

1. The needle is produced from steel, which is first heated until it is molten and then,
Retraction of the plunger creates the vacuum to draw up materials, which can then be discharged by pushing on the plunger. Its rubber head makes an airtight seal against the walls of the barrel.  Retraction of the plunger creates the vacuum to draw up materials, which can then be discharged by pushing on the plunger. Its rubber head makes an airtight seal against the walls of the barrel, drawn through a die designed to meet the size requirements of the needle. As it moves along the production line, the steel is further formed and rolled into a continuous, hollow wire. The wire is appropriately cut to form the needle. Some needles are significantly more complex and are produced directly from a die casting. Other metal components on the needle are also produced in this manner.

Making the barrel and plunger

2. There are various ways that the syringe tube can be fashioned, depending on the design needed and the raw materials used. One method of production is extrusion molding. The plastic or glass is supplied as granules or powder and is fed into a large hopper. The extrusion process involves a large spiral screw, which forces the material through a heated chamber and makes it a thick, flowing mass. It is then forced through a die, producing a continuous tube that is cooled and cut.

     3. For pieces that have more complex shapes like the ends, the plunger, or the safety caps, injection molding is used. In this process the plastic is heated, converting it into a liquid. It is then forcibly injected into a mold that is the inverse of the desired shape. After it cools, it solidifies and maintains its shape after the die is opened. Although the head of the plunger is rubber, it can also be manufactured by injection molding. Later, the head of the plunger is attached to the plunger handle.

Assembly and packaging

4. When all of the component pieces are available, final assembly can occur. As the tubes travel down a conveyor, the plunger is inserted and held into place. The ends that cap the tube are affixed. Graduation markings may also be printed on the main tube body at this point in the manufacturing process. The machines that print these markings are specially calibrated to ensure they print measurements on accurately. Depending on the design, the needle can also be attached at this time, along with the safety cap.

5. After all of the components are in place and printing is complete, the hypodermic syringes are put into appropriate packaging. Since sterility of the device is imperative, steps are taken to ensure they are free from disease-causing agents. They are typically packaged individually in airtight plastic. Groups of syringes are packed into boxes, stacked on pallets, and shipped to distributors.

Quality Control

The quality of the components of these devices are checked during each phase of manufacture. Since thousands of parts are made daily, complete inspection is impossible. Consequently, line inspectors randomly check components at fixed time intervals to ensure they meet size, shape, and consistency specifications. These random samples give a good indication of the quality of the hypodermic syringe produced. Visual inspection is the primary test method. However, more rigorous measurements are also performed. Measuring equipment is used to check the length, width, and thickness of the component pieces. Typically, devices such as a vernier caliper, a micrometer, or a microscope are used. Each of these differ in accuracy and application. In addition to specific tests, line inspectors are stationed at various points of the production process and visually inspect the components as they are made. They check for things such as deformed needles or tubes, pieces that fit together incorrectly, or inappropriate packaging.

Hypodermic syringe production is strictly controlled by the United States government, specifically the Food and Drug Administration (FDA). They have compiled a list of specifications to which every manufacturer must comply. They perform inspections of each of these companies to ensure that they are following good manufacturing practices, handling complaints appropriately, and keeping adequate records related to design and production. Additionally, individual manufacturers have their own product requirements.

The Future

Since Alexander Wood introduced the first device, hypodermic syringe technology has greatly improved. Future research will focus on designing better devices that will be safer, more durable, more reliable, and less expensive to produce. Also, improvements in device manufacture will also continue. One example of this is the trend toward utilizing materials such as metals and plastics that have undergone a minimum of processing from their normal state. This should minimize waste, increase production speed, and reduce costs.

Where to Learn More


Chicka, C. and Anthony Chimpa. Diabetic’s Jet Ejectors. Diabetic Gun for Personal Insulin Injection. H.W. Parker, 1989.

Trissel, Lawrence. Pocket Guide to Injectable Drugs: Companion to Handbook of Injectable Drugs. American Society of Health-System Pharmacists, 1994.

— Perry Romanowski

Read more: How syringe is made – material, production process, manufacture, making, history, used, processing, parts, components, procedure, steps, product, History, Design, Raw Materials


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