MEDICAL
DEVICE REGULATORY AFFAIRS
The pathway from
product design to product launch for a new medical device
is often unclear and the number of challenges and questions
often increase as medical devices become more complex.
Generally, medical device regulations are based on risk.
Our regulatory consultants have the expertise to help
your medical device meet the many challenges of the
approval process, for products distribution in China.
Our consultants
are well respected by the SFDA and Ministry of Health
regulatory bodies and have an excellent rapport with
regulatory agency leaders and reviewers earned through
years of professional experience. With Airtrust as your
partner, you will gain a deep understanding of the regulations
and requirements applicable to your medical device,
often beyond what is available in published guidance
documents and other materials.
We will work with
you to design and implement a competitive and cost-effective
regulatory strategy, prepare and submit a "reviewer-friendly"
marketing application, and serve as your liaison from
start to end, helping you to prepare the necessary documentation,
respond to questions and negotiate with regulatory agencies
quickly and effectively.
REGULATORY STRATEGY
DEVELOPMENT
A well-crafted regulatory
strategy considers SFDA medical device regulations,
but also development costs, development cycles, and
profitability concerns. Airtrust will consider the current
regulatory environment, relevant guidelines, and ongoing
SFDA and/or international medical device initiatives
that could influence your regulatory pathway. Our goal
is to facilitate a timely, competitive, and successful
product clearance or approval.
We will consider information
about your medical device, including, the device description
and specifications, its intended clinical applications
and labeling claims, available test data, and any literature
references. We will also review information about possible
predicate devices that may be similar to yours, along
with standard methods, procedures and/or practices,
SFDA guidance documents, and other medical device regulations
and policies that could apply to your product.
Our consultants and project
managers are well respected by the SFDA and other regulatory
agencies. Airtrust staff has excellent rapport with
agency leaders and reviewers, earned through years of
professional experience and almost daily interactions.
With Airtrust as your partner, you will gain a deep
understanding of the relevant medical device regulations
often beyond what is available in published materials,
directives, and FDA guidance documents.
Our goal is to provide
you with a clear understanding of the types of regulatory
and clinical trial requirements you will encounter as
you work towards launching your medical device in CHINA.
We will define a strategy that will move your device
along the appropriate pathway more easily and reduce
the cost and time to bring your innovation from the
bench to the bedside ¨C and meet your ultimate goal of
bringing safe and effective medical technology where
it is needed, to the patient.
SFDA SUBMISSIONS
Depending upon the classification
of your device and your current stage in the medical
device development process, there are a variety of medical
device submissions that may be required by the SFDA.
Airtrust will work with
your team to review, prepare and submit a "reviewer-friendly"
document, designed to effectively address SFDA concerns
and minimize additional questions. Airtrust will assist
to prepare and submitted the following documents:
- The certificate of the legal production qualification
of the Manufacturer
- The qualification certificate of the applicant
- The certificate recognized or approved by the
government of the Country (Region) of Origin to
authorize the products as medical devices to enter
into the market of the country
- The Standards of the Products to be Registered
shall apply the Provisions for the Management of
the Medical Devices Standards
- Operation Manual of the Products
- The Type test Report presented by the medical
devices quality test agency recognized by the State
Drug Administration within the recent one year (Applied
to the Products of Class II and Class III)
- The clinical trial report of medical devices,
the methods on the provisions of the report should
be applied in accordance with the "Provisions
for the 'Subitem of Clinical Reports' for the Registration
of Medical Devices". The clinical trial shall
be implemented in accordance with the "Provisions
for the Clinical Trial Management of Medical Devices"
- The Product Quality Guaranty presented by the
Manufacturer, to promise that the quality of the
products registered and sold in China are unanimously
the same as that of the identical products put into
market in the Country (Region) of Origin
- The certificate of commission for the After-Sale
Service Agency designated in China, the letter of
commitment and business certificate of the commissioned
agency
- The Self-Guarantee Declaration on the authenticity
of the materials submitted
The majority of medical
devices commercialized in the United States require
a 510(k) submission, which is used to demonstrate that
the medical device is at least as safe and effective,
or substantially equivalent, to a predicate device,
meaning a device that is legally marketed.
The SFDA receives nearly
10,000 submissions annually. The Branches and Test institutes
under SFDA within these offices are organized according
to medical scientific disciplines and are staffed by
FDA reviewers. These reviewers, who are biomedical engineers,
physicians, microbiologists, chemists, and other professionals,
will determine whether a new medical device is substantially
equivalent and can be marketed in China.
In general, information
contained in a 510k includes a description of the device,
clinical and preclinical/nonclinical performance data,
device labeling and instructions for use, comparative
products and/or standard methods documentation, and,
if applicable, a description of any software or firmware
used in the medical device will be very helpful in determine
the preparation and application in China. Airtrust will
help you to:
- Perform a 510k like assessment to identify or
confirm the most appropriate predicate device(s)
- Assist to develop and prepare a written argument
for "substantial equivalence" that will
compare your device to a predicate device(s)
- Identify any applicable FDA Guidance Documents
- Communicate directly with SFDA staff and test
institutes to identify any special requirements
that may impact the review of your 510(k) alike
documents, if necessary
- Prepare and submit the document to the SFDA
- Coordinate any communications and negotiations
with the FDA reviewer, and prepare responses to
FDA questions, if necessary
Airtrust
helps clients with combination products, such as drug/device
and biologic/device applications in which the primary
mode of action is either the drug or biologic component,
and correspondingly, the SFDA Department for Drugs or
Department for Biologics will have primary jurisdiction.
Airtrust can help clients identify how their particular
product will likely be regulated by SFDA, and facilitate
the preparation of documentation for agency review.
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