Premarketing

A particular mode of neurotoxicity was discovered for tricresyl phosphate that correlated with the presence of the o-cresyl isomer (or certain other specific aLkylphenyl isomers) in the triaryl phosphates. Many details of the chemistry and biochemistry of the toxic process have been elucidated (139,140,143—146). The use of low ortho-content cresols has become the accepted practice in industrial production of tricresyl phosphate. Standard in vivo tests, usually conducted with chickens sensitive to this mode of toxicity, have been developed for premarket testing of new or modified triaryl phosphates. As of 1992, the EPA called for extensive new toxicity and environmental data on this group of products (147). The Vederal e ster AoQ xm. ci. calling for this... 

Many countries have adopted chemical substance iaventories ia order to monitor use and evaluate exposure potential and consequences. In the case of essential oils used in many fragrance appHcations, these oils must be on many of these Hsts. New essential oils used in fragrances are subject to premanufactuting or premarketing notification (PMN). PMN requirements vary by country and predicted volume of production. They require assessment of environmental and human health-related properties, and reporting results to designated governmental authorities. 

In 1962, amendments to the U.S. Federal Food, Dmg and Cosmetic Act (Kefauver-Harris amendments) promulgated regulations concerning the requirements for premarketing approval by the FDA. This legislation estabUshed requirements of proof of both safety and therapeutic efficacy and strict control of human clinical testing, for example, which have extended the time and cost to market a new dmg. Thus, whereas approximately 40 new dmgs were marketed annually from 1948 to 1962, this number had fallen to 12 by 1966. 

Two statutory provisions of Tide 21 govern the introduction of new medical devices into the marketplace. Section 515 estabHshes a premarket approval appHcation (PMA) containing data and information demonstrating the safety and effectiveness of a device. Section 510(k) estabHshes a premarket notification process. Under this process, a manufacturer is required to file with the EDA, 90 days before a new device is to be marketed, a premarket notification demonstrating that the device in question is substantially equivalent to a device that was on the market before enactment of the 1976 Amendment and therefore marketable without formal EDA approval. 

Unless otherwise exempt, a firm must submit a premarket notification, also called a 510(k), to the PDA 90 days before it intends to market a device for the first time (17). The 510(k) submission must contain sufficient information to show that the device in question is substantially equivalent to a legally marketed device for a particular intended use. This notification is also required for a product when there is a change or modification to a product that may significantly affect the safety or effectiveness of the device, or when there is a significant change or modification to the intended use of the device. 

Class III Premarket Approval. Similar to a new dmg approval, a premarket approval grants the appHcant a Hcense to market a specific weU-characterized device. These devices are subject to the requirements of Section 515 of the Eood, Dmg, and Cosmetic Act. A post-amendment device is a device put ia commercial distribution after May 28, 1976. If it is not substantially equivalent to a preamendment device it is automatically ia Class 111, and a premarket approval appHcation (PMA) is required. The appHcation must iaclude reports of preclinical and clinical studies done ia support of claims of safety and efficacy as well as any labeling claims made for the device. Once the PMA is submitted, the PDA determines whether the appHcation iacludes the required information. If the PMA is suitable for scientific review, the PDA has 180 days from the filing date to approve or deny the appHcation. Polybutester, polydioxanone, polyglyconate, and ePTPE sutures are all regulated as Class 111 devices. 

A primary responsibility of the Food and Drug Administration (FDA) is the enforcement of the Federal Food, Dmg, and Cosmetic Act of 1938 and its various amendments, eg. May, 1976, in which dental materials, instmments, and equipment are included. Premarketing clearance requirements apply for estabhshing the safety and effectiveness of new products. There is a close Haison between the FDA and the ADA standards and certification programs. 

Regulation. Dental implants are regulated by the Food and Dmg Administration. AH dental implants faH iato the FDA class III which covers devices that are life sustaioiag, life supportiag, or are implanted iato the body and have the potential to cause unreasonable risk, illness, or iajury. Devices ia class III are requited to have appHcatioas for premarket approval (315). There are 15 to 20 companies that have FDA marketing clearance for specific dental implants, based on substantial equivalency to implants marketed prior to 1976, and approximately one third of these companies are foreign. Marketing clearance is not the same as premarket approval. 

Investigational New Drug Applications (INDs), NDAs, Premarket Approval Applications (PMAs), Premarket Notifications (5 lO(k)s), Investigational Device Exemptions (IDEs), Biological Master Files (BMFs) and DMFs that are referenced in the current application. 

Where necessary the manufacturer must carry out, or arrange for, safety testing. Many countries operate mandatory premanufacturing and premarketing notification schemes of which safety testing is the cornerstone. Within the European Community under Directive 67/548/EEC and its sixth amendment 79/831/EEC, Competent Authorities must be... 

To properly assess drug safety, we must be able to systematically tap the information captured in the massive amounts of medical data collected in both premarketing and postmarketing settings. In addition, as stated above, we must also be able to reproduce findings in different repositories of medical data in an auditable way. However, two major issues in studying drug safety confront us. 

Missing Information. Both premarketing and postmarketing collections of data are perpetually plagued by missing information. In premarketing and postmarketing clinical trials, patients can be lost to follow-up because of ... 

Reconfiguration of Data. Drug safety data from different sources are often pooled or combined in databases. Reasons for combining data vary. In the case of premarketing studies, data from different sites are routinely combined because one site may not be able to recruit enough patients for a study. Data from different studies are often combined to increase sample size and therefore statistical power for detecting an uncommon adverse event. 

Guidance for Industry Premarket Notification (510(k)) Guidance Document for Contact Lens Care Products. Center for Devices and Radiologic Health, FDA, Rockville, MD, 1997. 

The Safe Medical Devices Act of 1990, a major revision to the 1976 amendments, among other revised requirements provided two major mechanisms for bringing an IVD medical device to market premarket notification and premarket approval. The act is administered by the FDA s Center for Devices and Radiological Health, of which the Division of Clinical Laboratory Devices (DCLD) is a part. The premarket notification process is used for devices that can be classified... 

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