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Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelph ia, PA 19102 A Health Care Provider Perspective CDRH 510(k) Implementation: Discussion of an On-line Repository of Medical Device Labeling, and of Making Device Photographs Available in a Public Database without Disclosing Proprietary Information Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelph ia, PA 19102 Aaron Moskowitz Executive Director Biomedical Research and Education Foundation

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Page 1: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

A Health Care Provider Perspective

CDRH 510(k) Implementation: Discussion of an On-line Repository of Medical Device Labeling, and of Making Device Photographs Available in a Public Database without Disclosing

Proprietary Information

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Aaron MoskowitzExecutive Director

Biomedical Research and Education Foundation

Page 2: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Biomedical Research and Education Foundation

• 501c3 Non-profit Independently Funded

• Philadelphia, PA• Founded in 2003• Research, publication, conferences• Listed PSO• www.medicaldeviceregistry.org

Page 3: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Scope

• Typical Problems of Physicians for patients who already have a device

• Current Information Sources• www.medicaldeviceregistry.org• Suggested Improvements

Page 4: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Problems

• Number One Problem We Hear: What device does my patient have?– Imaging procedures– Prescribing drugs– News about recalls– Where to direct a patient for more

information

Page 5: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Information Gathering Difficulty

• Finding information about about specific Devices – Determining imaging compatibility– Determining drug interaction– Trouble Shooting problems

Page 6: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Why Images Are ImportantRadiographic and Photographs

• Identify non-implants from a catalogue

• Identifying devices from medical images

• Identifying normal and abnormal changes in anatomy from images

Page 7: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Current Information Sources

• Current information sources• Ask an expert• Literature “if you don’t want a primary care

physician to see it, publish it”• Web at large: google• Direct information sources• Then there is:• Personal Healthcare Record• Available resources to a practitioner

Page 8: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Information Gathering

• Pick a Device– Implant– Home Use Device

• Determine The Name• Search Expected Sources

– Manufacturer Site– FDA Sources– General Internet

Page 9: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Example: CD HorizonSpinal Fixation Device

FDA Medsun

FDA MAUDE

FDA Approval 510k

2 results

70 Approval Numbers from 12/05/1996 by Sofamor Danek USA, Inc to 1/26/2011 by Medtronic Sofamor Danek, Inc.

29 REPORTS

Page 10: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

“CD Horizon” By Medtronic

Manufacturer Website

Patient Websites

www.LessInvasiveSpine.comContains information on Multiple Devices and procedures

No PicturesNo Implantation warnings found on 510k letterDifficult Navigation

Page 11: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Example: ACCU-CHEK Aviva Blood Glucose Meter

FDA Medsun

FDA MAUDE

FDA Approval 510k

5 results, 2 likely relevant

52 devices ACCU-CHEK Aviva Blood Glucose Meter

>500 REPORTS

Manufacturer Website

FAQsImagesTroubleshooting

Internet Retailers FAQsImagesTroubleshooting

Page 12: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Review of FDA access

• Currently the access databases are not connected.

• Absent fields make linking difficult• Device Name, Manufacturer are

insufficient to verify a device• There are no images or manuals

Page 13: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Solutions

• Unique Identifier for Devices used across databases

• Single site, Collating all information.

• Requires:Images of DevicesRadiographic Images AnatomyContraindicationsResource Lists

Page 14: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

www.medicaldeviceregistry.org

• Free Service• Account not required• Designed for consumers• Register devices• Links to FDA’s information• Links to other available sites (ie:

manufacturers, news)

Page 15: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Alerts onwww.medicaldeviceregistry.org

Page 16: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

www.MedicalDeviceRegistry.org

Page 17: Biomedical Research & Education Foundation 1500 Market Street 12 th Floor – East Tower Philadelphia, PA 19102 A Health Care Provider Perspective CDRH 510(k)

Biomedical Research & Education Foundation1500 Market Street 12th Floor – East TowerPhiladelphia, PA 19102

Final Suggestions

• Unique identifiers• Images

– Images of devices– Images Anatomy

• Labeling and user manuals• Contraindications for imaging• Legacy devices, Version tracking• List online resources