FDA UpdateReEngineering:
Two new teams are being formed: the Bioresearch monitoring team
and Postmarket team. The Bioresearch monitoring team will consider how to improve the
inspection process, manage and make decisions, and interface with the Bioresearch
monitoring program. The Postmarket team will select appropriate scientific and regulatory
strategies for public health decisions and will take an active approach to postmarket
issues.
Reclassification & 510K Pilot:
The FDA is downclassifying 38 devices and will publish the
reclassifications in the Federal Register. The knee reclassification document is moving
through the FDA process. The shoulder reclassification petition, which includes the
cemented shoulder, must be reviewed by the regulatory staff. The elbow reclassification is
part of the mass down classification effort.
The 510k pilot program is apparently successful. FDA is receiving a
lot of Special 510k’s, but not too many Abbreviated 510k’s. By declaring
conformity to standards, the FDA thought it would reduce their workload. FDA received 30
abbreviated 510k’s in one year. The FDA had one PDP (Product Development Protocol) go
to completion.
Special 510k’s require a 30 day internal review. Abbreviated or
traditional 510 k’s are a 90-day review process. If a manufacturer declares
conformity to standards of 50%, the FDA will focus its review on the other 50%. In the
U.S., ASTM, ANSI, AATB produce consensus standards.
Mutual Recognition Agreements
Orthopaedic implants were excluded from possible third party
reviews by the FDA Modernization Act. FDA’s definition of a permanent implant is
anything that is implanted longer than 30 days. Third party reviews are not allowed on
these devices therefore, IM rods and external fixators are excluded.
NIAMS Update
A slide presentation illustrated the increased level of
Bioengineering research support from NIH for FY 1997. Harold Varmus, MD, PhD, National
Institutes of Health Director, is currently focusing on the "burden of disease"
to society. Dr. Katz, Director of NIAMS, appears to be committed to musculoskeletal
concerns. There are four types of grants: Bioengineering Research Partnerships
(BRP’s), Tissue Engineering RFA, R03 Small Grants (RFA), and Bioengineering Research
Grants (BRG’s) which are through an R01 mechanism. NIAMS has internally identified
three disadvantaged communities: bioengineering, clinical research, and social and
psychological research. They are particularly interested in the field of bioengineering
and want to be responsive to that community. NIAMS may partner with medical societies to
develop musculoskeletal registries.
Task Force Liability Issues Update
Website:
The mission statement was approved. Forum members had a
discussion about changing the term "orthopaedic scientists" to
"physicians". The term orthopaedic scientist will remain on the FDA recognition
statement and will not be changed.
The Device Forum website has been set-up. The domain
http://www.orthpaedicdeviceforum.org has been registered. It was decided to have a
three-month trial run beginning March 1, 1999, where Forum members will have access to the
site before it is available to the general public. The Orthopaedic Device Forum
Proclamation, which includes the mission statement, operational principles, and the FDA
recognition award statement, will be included on the Forum page. Individuals will not be
identified in the body of the report but will be identified as being present on the first
page of the summation report. The Orthopaedic Device Forum website will link to the ASTM,
ORS, FDA, AOA, NIH, AAOS and Arthritis Foundation websites after the trial period.
Future meeting dates will be posted, however the location will not
be listed. Jeanie Kennedy will be listed as the contact person with AAOS phone number and
email address provided. Future agendas will be posted two weeks prior to the meeting on
the website. Sunday speakers will not be identified.
Disclosure:
A new AAOS policy has been drafted and will be placed on the
website. Members will have the agendas approximately two weeks before the meeting and will
be given ample opportunity to review agenda items for potential conflict. Academy members
will disclose once a year, and at the beginning of each meeting, as appropriate.
Polyethylene Guidance Update
An update on the polyethylene guidance document was
presented. Manufacturers are working on new forms of polyethylene and that fact was taken
into consideration in the drafting of the document. There are a plethora of new processes
for polyethylene in last few years. Different processes can change the mechanical
characteristics of UHMWPE. A manufacturer would need to file a new claim (510k) if there
are 4-5 modifications in substance, changes in spectrum range or performance, or are
outside of ranges of approved substances.
FDA felt that the UHMWPE guidance document was helpful and gave them
ranges to follow. Manufacturers are also using the guideline, but are mindful that
laboratory data cannot be used to develop clinical conclusions. There is still much to
learn about polyethylene even though manufacturers have been working with it for decades.
Standards Update
ASTM/ISO:
The International President’s breakfast will be held during
the Academy’s annual meeting in February 1999. Members attending the breakfast will
receive a handout that solicits help in identifying orthopaedic surgeons from the
international membership who will work to develop ISO standards for orthopaedic surgical
implants.
The Chairman of ASTM F-04 division’s term ends in 1999.
Openings for chairs of F-04 subcommittees still exist. The next meeting of ASTM will take
place on May 19-21, 1999 in Seattle, Washington. The following meeting will be in Kansas
City, Missouri in November 1999. The Committee on Biological Implants and Biomedical
Engineering are proposing a joint meeting to be held in May in conjunction with the ASTM
meeting. FDA and ASTM will educate members of both committees about processes involved in
writing standards and the potentials of collaboration among various groups. The Forum
Chairman will present a proposal for the joint committee meeting at the AAOS January
Council on Research.
Biological Standards:
ASTM serves as liaison but also serves to provide coordination
to other standards. The Society of Tissue Engineering, Tissue Culture Society,
Pharmacopia, and others want to coordinate the writing of standards regarding cell,
tissue, and biologics with ASTM.
Biologics Update
A handout was presented from an ORS workshop agenda on FDA:
Policies and Protocols for Device Approval. Topics covered were an overview of the FDA
regulatory aspect relative to biologics, safety and efficacy of biologics, how a company
would address the needs of the surgeon and FDA, and the role of the ORS.
Biological Guidances Update
The Forum was updated on the soon to be released book,
"Animal Models in Orthopaedic Research" edited by Yuehuei H. An and Richard J.
Friedman. The editors consulted many experts and the work is very comprehensive. An and
Friedman’s books begins with safety and efficacy of animal models and encompasses
bone conditions, articular cartilage and joint conditions, joint replacement, ligaments
and tendons, spinal conditions, and microsurgical technique.
Articular cartilage and fracture repair guidance documents are
currently being drafted. The resulting guideline can be used in the development of ASTM
standards. After discussion, it was suggested that the scientific community might be able
to help the FDA develop guidance documents. It was noted that some products have been on
the market for years without standards.
Cartilage Resurfacing Update
Progress continues on the cartilage resurfacing guidance. A
draft will be available at the April meeting. It was mentioned that the only way to
understand the process of writing a guidance document is to actually write the document.
It’s imperative to have something in writing in order to be able to critique it.
Conference calls were suggested to coordinate ongoing efforts on guidance documents.
Guidance Documents
FDA mentioned that the spinal guidance document was ready to
go out for comment.
MDR Task Force Update
Forum members were briefed on suggestions from a FDA
representative. FDA suggests that the Forum define and justify exemptions on internal
fixation, THR, and TKR. Members of the Forum will solicit suggestions from both the Hip
and Knee Societies.
Educational Initiatives Update
The Forum was updated on the symposium "Regulatory Aspects
in Orthopaedics" which will be held Thursday, February 4, 1999 at the AAOS annual
meeting. Speakers will be allotted approximately 13 minutes each and a question and answer
period will follow. This symposium will address the evolution of the regulatory process,
moving new products and technologies through the regulatory process with the FDAMA of
1997, the role of device standards in the orthopaedic product approval process, custom,
special products and off label device usage, and surveillance: insuring the safety of
orthopaedic devices, and the role of the Orthopaedic Device Forum.
An application will be submitted through the Bioengineering
committee for a symposium on polyethylene for the 2000 AAOS annual meeting.
Labeling Update
The possibility of developing a new approach to orthopaedic
device labeling was discussed. The fact that some physicians do not read inserts is of
some concern. Manufacturers try to minimize continual label changes and seek to condense
labels. Further, class III labels are significantly different than class II. Orthopaedic
device labels need to be translated into many different languages as well.
There exists a wide variance of labeling in class II and special
recommendations would need to be noted on the labeling. It was decided to form a labeling
work group, which will consist of three Forum members to further study the issue of
uniformity in labeling.
Metal on Metal Update
A brief update was presented on the proposed
downclassification of metal-metal devices. IDE studies are ongoing and one has already
been completed.
Future Agenda Items: