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1
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- Donald St.Pierre
- Deputy Director for
- New Device Evaluation
- IVD Roundtable Update, May 2005
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2
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- Now 2+ years old
- Newest and smallest organizational unit
- TPLC does actually work
- Better pre and postmarket coordination/decision-making
- Better Compliance/Enforcement focus
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3
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- November 2002 – 60 FTEs
- Today – 85 FTEs
- Jean Cooper – on detail to FDA Exec Sec
- Carol Benson acting
- Looking Internally to temp. fill Team Leader
- CLIA questions to Carol Benson
- Most new staff starting independent reviews
- FY05 performance very encouraging
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4
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- 26% pleased with process
- 18% no comments
- 14% lack of consistency (cross-division mtg)
- 14% problems with communication (reminders)
- 10% guidance doc. need updating (in-process)
- 8% web-site needs improving
(recent facelift)
- 4% not least burdensome (not bad)
- 4% user fees excessive
- 4% reviews not timely
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5
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- Pre-IDEs
- Assess perception
- Assess market submission quality
- Assess impact on timeliness
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6
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7
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8
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9
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10
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11
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12
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13
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- OIVD has this tamed
- Since OIVD created (13 vs 5 for ODE)
- Broad but not over-reaching view of risk
- Turnaround from 510(k) receipt to denovo order (30 – 200 days, 110 days
on ave.)
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14
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- Final Guidances Published in FY04/05:
- 10 Special Control Guidances
- Replacement Reagent Policy
- Draft Guidances Published in FY04/05:
- Drugs of Abuse Screening tests
- Hepatitis A Virus (companion document to proposed down-classification
of HAV)
- (7 guidances FY02/03 vs. 13 (&
counting) FY04/05)
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15
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- Pharmacogenetics/Genetic Tests (draft)
- NAAT (draft)
- IVD Studies (draft)
- 5 SCGD (HAV (final), HSV (draft), 3 Denovos)
- CLIA Waiver (draft)
- C-reactive protein (draft)
- OTC Ovulation Predication (draft)
- Portable Glucose Monitoring (draft)
- Glucose MDR Guidance (draft)
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16
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17
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- Patient Safety Team
- Adverse Events Database (New)
- Link all incoming signals
- User interactive
- Allows customized data analysis
- (e.g., by event, by manufacturer)
- MDR Reviews
- Overuse of “OTHER” event type
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18
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19
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- Condition of Approval Studies
- Only one to date
- More Likely if:
- Not appropriate to label
accordingly
- Important question still needs answering
- Better pre-/post-marketing balance
- Suggestions to create a better balance?
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20
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- Inspections
- Risk-based inspection planning
- Inspection Cadre (more likely to see OIVD person)
- Staff taking Inspection Training
- Field interactions on the rise (visit DO when we can)
- OIVD – not a work-around to the field
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21
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- Premarket Application Review
- 30-day notices
- Mfg. site changes
- Annual Reports (pending)
- Bioresearch Monitoring (BiMo)
- More focused
- Applications on AIP continue (BAD!)
- Registration & Listing
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22
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23
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- Arabian bazaar of activity
- Pseudo-kits
- Marketing of microarrays and RUOs inappropriately
- FDA slow but steady responses
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24
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- Bottom line
- Lots of behind-the-scenes activities
- Very little completed
- OIVD and industry on the same page
- Working hard to get some interim solution
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25
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- Hot button item
- FDA working closely with CDER
- Recent collaborative concept paper (precedent setting in scope of work
and collaboration)
- Recent collaborative workshop (DIA)
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26
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- Biomarkers is the focus
- Good mechanism to bring IVD’s to the table
- Have FDA’s ear
- Have CDER and PharMA’s ear
- Have OIVD insider
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27
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