TY - JOUR
T1 - Transparency and dermatologic device approval by the US food and drug administration
AU - Ezaldein, Harib H.
AU - Scott, Jeffrey F.
AU - Yin, Emily S.
AU - Ventura, Alessandra
AU - Deruyter, Nicholaas P.
AU - Leffell, David J.
N1 - Publisher Copyright:
© 2018 American Medical Association. All rights reserved.
PY - 2018/3
Y1 - 2018/3
N2 - IMPORTANCE The US Food and Drug Administration approves Class III medical devices via the premarket approval pathway, often requiring clinical data on safety and efficacy. Manufacturers can submit incremental device changes via supplemental applications, which are not subjected to such vetting measures and can cause understudied changes that lead to drift from a device's original design. OBJECTIVES To characterize the postapproval changes to Class III dermatologic devices and to evaluate inconsistencies in the use of the premarket approval pathway. DESIGN, SETTING, AND PARTICIPANTS This studywas a cross-sectional retrospective cohort analysis of a public US Food and Drug Administration database for premarket approval of devices. Included were dermatologic devices approved by the US Food and Drug Administration between January 1, 1980, and November 1, 2016, through the premarket pathway for device approval. MAIN OUTCOMES AND MEASURES Original deviceswere identified, and their supplements were characterized chronologically, by review track, and by modification category. RESULTS The 27 dermatologic devices studied consisted of 14 injectables, 11 photodynamic therapies, a dermal replacement matrix, and a diagnostic imaging instrument. Supplemental applications are increasingly used: the data-requiring panel-track pathway was the least common approach (2.8%[16 of 562 supplements]), while the 30-day track, which does not require clinical data, was most frequently used (42.5%[239 of 562 supplements]). Four devices (14.8%) underwent low-risk recalls (Class II or Class III), and 10 devices (37.0%) were voluntarily withdrawn. CONCLUSIONS AND RELEVANCE As manufacturers make increasing use of supplemental applications, minor device changesmay occur without supporting clinical data, which could pose a safety risk to patients.
AB - IMPORTANCE The US Food and Drug Administration approves Class III medical devices via the premarket approval pathway, often requiring clinical data on safety and efficacy. Manufacturers can submit incremental device changes via supplemental applications, which are not subjected to such vetting measures and can cause understudied changes that lead to drift from a device's original design. OBJECTIVES To characterize the postapproval changes to Class III dermatologic devices and to evaluate inconsistencies in the use of the premarket approval pathway. DESIGN, SETTING, AND PARTICIPANTS This studywas a cross-sectional retrospective cohort analysis of a public US Food and Drug Administration database for premarket approval of devices. Included were dermatologic devices approved by the US Food and Drug Administration between January 1, 1980, and November 1, 2016, through the premarket pathway for device approval. MAIN OUTCOMES AND MEASURES Original deviceswere identified, and their supplements were characterized chronologically, by review track, and by modification category. RESULTS The 27 dermatologic devices studied consisted of 14 injectables, 11 photodynamic therapies, a dermal replacement matrix, and a diagnostic imaging instrument. Supplemental applications are increasingly used: the data-requiring panel-track pathway was the least common approach (2.8%[16 of 562 supplements]), while the 30-day track, which does not require clinical data, was most frequently used (42.5%[239 of 562 supplements]). Four devices (14.8%) underwent low-risk recalls (Class II or Class III), and 10 devices (37.0%) were voluntarily withdrawn. CONCLUSIONS AND RELEVANCE As manufacturers make increasing use of supplemental applications, minor device changesmay occur without supporting clinical data, which could pose a safety risk to patients.
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U2 - 10.1001/jamadermatol.2017.5757
DO - 10.1001/jamadermatol.2017.5757
M3 - Article
C2 - 29365020
AN - SCOPUS:85043978402
SN - 2168-6068
VL - 154
SP - 273
EP - 280
JO - JAMA Dermatology
JF - JAMA Dermatology
IS - 3
ER -