FDA 510(k) Transfer Draft Guidance.

FDA issued a draft guidance Transfer of a Premarket Notification (510(k)) Clearance Questions and Answers” dated Dec. 22, 2014. This guidance explicitly states that when a device is sold or transferred to another party FDA does not expect submission of a new 510(k). Now that 510(k) numbers are included in Device listings and required to be updated information FDA will now use this information to indicate the current holder of the device 510(k) and can be updated by manufacturers as needed and if needed outside the annual filing no additional fee is required.

It also states: “Because contract manufacturers and sterilizers, foreign exporters, and foreign private label distributors are not responsible for the commercial distribution of devices, they would not be 510(k) holders, and should list the product under their customer?s 510(k) number once it has been listed by the 510(k) holder.”

If more than one entity claims the same 510(k) within the same annual update period the most recent update is used by the database. FDA will contact the parties to determine the rightful owner.

SoftwareCPR Training Courses:

Being Agile & Yet Compliant (Public)

Our SoftwareCPR unique approach to incorporating agile and lean engineering to your medical device software process training course is now open for registration!

  • Agile principles that align well with medical
  • Backlog management
  • Agile risk management
  • Incremental and iterative software development lifecycle management
  •  Frequent release management
  • And more!

3 days virtual (Zoom) with group exercises, quizzes, examples, Q&A.

Lead Instructor: Mike Russell

Next public offering: Dec 3, 4, & 5, 2024 – 12:00 pm to 5:00 pm CET

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IEC 62304 and other emerging standards for Medical Device and HealthIT Software

Our flagship course for preparing regulatory, quality, engineering, operations, and others for the activities and documentation expected for IEC 62304 conformance and for FDA expectations. The goal is to educate on the intent and purpose so that the participants are able to make informed decisions in the future.  Focus is not simply what the standard says, but what is meant and discuss examples and approaches one might implement to comply.  Special deep discount pricing available to FDA attendees and other regulators.

3-days onsite with group exercises, quizzes, examples, Q&A.

Instructor: Brian Pate

Next public offering:  TBD

Call or email now to schedule a private, in-house class. The fall schedule is filling up!

Email training@softwarecpr.com to request a special pre-registration discount.  Limited number of pre-registration coupons.

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Medical Device Cybersecurity (Public or Private)

This course takes a deep dive into the US FDA expectations for cybersecurity activities in the product development process with central focus on the cybersecurity risk analysis process. Overall approach will be tied to relevant standards and FDA guidance documentation. The course will follow the ISO 14971:2019 framework for overall structure but utilize IEC 62304, IEC 81001-5-1, and AAMI TIR57 for specific details regarding cybersecurity planning, risk characterization, threat modeling, and control strategies.

2-days onsite with group exercises, quizzes, examples, Q&A.

Instructor: Dr Peter Rech, 2nd instructor (optional)

Next public offering:  TBD

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