Devices

We are writing to express our strong concerns about the draft guidance for the “Balancing Premarket and Postmarket Data Collection for Devices Subject to Premarket Approval.” The standards for PMA are currently much lower than for prescription drugs, despite the fact that the 1% of devices approved through the PMA process are life-saving and life-sustaining products, which many prescription drugs are not.  The draft guidance has the potential to lower those standards even more, by increasingly relying on postmarket safety and effectiveness data rather than pre-market data, thus putting patients at greater risk.

We do not support the draft guidance for the “Expedited Access for Premarket Approval Medical Devices Intended for Unmet Medical Need for Life Threatening or Irreversibly Debilitating Diseases or Conditions.” The standards for PMA are already substantially lower than for prescription drugs. Most PMA devices are approved through supplements that do not require clinical trials. Original PMA clinical trials are often small and short-term with limited use of control groups.  And yet, the draft guidance lowers the bar for certain PMA medical devices even further.

This proposed indication for the HPV test would represent an unprecedented and significant shift in clinical practice that would affect millions of women for the majority of their adult lives.  With the health of so many at stake, we strongly urge the FDA to reject the application for this expanded indication, until evidence clearly indicates that this will not reduce the effectiveness of screening for cervical cancer.

We strongly support the FDA’s proposed order for Nonroller-Type Cardiopulmonary Bypass Blood Pumps for Temporary Ventricular Support devices to remain in Class III with Premarket Approval applications (PMA) required. The evidence of safety and effectiveness for these indications has not been established, and the benefit/risk profile for these devices is “unknown.”

We strongly support the FDA’s proposed order for Intra-Aortic Balloon and Control Systems (IABP) devices used to treat septic shock or pulsatile flow generation (Other Specific Intended Uses) to remain in Class IIIwith Premarket Approval applications (PMA) required. The evidence of safety and effectiveness forthese indications has not been established.  As the FDA noted in its assessment of the device, there is no “theoretical or demonstrated benefit to using the intra-aortic balloon and control systems for this clinical syndrome.”

We oppose the FDA proposed order that will reclassify stair-climbing wheelchairs (a preamendment Class III device, indicating high risk) into Class II (moderate risk).  This change in classification would result in greater risk for some of our nation’s most vulnerable consumers.

We are writing to express our concerns about the proposed down-classification from Class III to Class II of External Counter-Pulsating (ECP) devices for treatment of chronic stable angina that is refractory to optimal anti-anginal medical therapy and without options for revascularization. We strongly support the proposed PMA for other indications for the same ECP devices.  Our coalition includes consumer groups, patient groups, public health experts, medical professionals, and scientists who are dedicated to ensuring that all medical products sold in the U.S. are safe and effective. 

We urge you to finally follow the recommendations made by FDA classification panels in 1977 and upclassify sunlamp products. All sunlamps should be reclassified as Class III devices because of their known risks, especially the increased likelihood of developing the most serious type of skin cancer. By law, high-risk devices that can cause substantial harm or even death are Class III. Clearly, sunlamps satisfy those criteria.

We are writing to you in the hopes that you will recognize that the OMB has a crucial public health role to play in expediting long-delayed release of this rule and ensuring that the final rule achieves its stated public health goals. Because the rule has been more than five years in the making, and in its proposed version remained under OMB scrutiny for 12 months, we wanted to express our concern that OMB release the final rule as soon as possible.

We strongly support the FDA proposed order that will require the premarket approval application (PMA) for Automated External Defibrillators systems (AEDs). A study of high-risk recalls of medical devices from 2005-2009, Medical Device Recalls and the FDA Approval Process, published in the Archives of Internal Medicine in 2011, noted that cardiovascular devices comprised the largest category of high-risk recalls. More than 350,000 Americans may need an AED this year, which is why we do not support the FDA exercising enforcement discretion for 15 months.