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RAC Device Practice Question Set 3- US
Typology: Quizzes
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Question Answer Explanation A startup has created an implantable cardiac device that provides real-time electrochemical monitoring of heart function. The technology is entirely new, and no predicate device exists. The device is classified as Class III due to its high-risk nature. What is the most appropriate premarket submission for this device? A) 510(k) B) PMA C) De Novo D) IDE
Product requiring PMAs are Class III devices are high risk devices that pose a significant risk of illness or injury, or devices found not substantially equivalent to Class I and II predicate through the 510(k) process. The PMA process is more involved and includes the submission of clinical data to support claims made for the device. De Novo cannot be the correct answer as a De Novo classification is used for novel, low- to moderate-risk devices that do not have a legally marketed predicate. A company develops a wearable sensor that monitors hydration levels in real-time and provides alerts to prevent dehydration. The device has no existing predicate, but the company believes it poses low to moderate risk and does not meet the criteria for Class III. Which premarket pathway should they pursue? A) 510(k) B) PMA C) De Novo D) IDE C) De Novo The De Novo pathway is designed for low to moderate- risk devices that do not have a predicate but do not pose high risk. Since the hydration monitoring device is novel but presents minimal safety concerns, the company should submit a De Novo request. If granted, this device would be classified as Class I or II and could serve as a predicate for future 510(k) submissions. A small biotech company has designed a neurostimulation implant that reduces tremors in patients with a rare genetic disorder. The disorder affects fewer than 8,000 individuals in the U.S. each year. The company wants to get the device to market quickly without proving effectiveness through large-scale clinical trials. Which pathway is the best regulatory option? A) PMA B) HDE C) 510(k) D) De Novo
Explanation: The Humanitarian Device Exemption (HDE) applies to devices intended to treat or diagnose rare diseases affecting fewer than 8,000 people in the U.S. per year. Unlike PMA, HDE does not require proof of effectiveness but must still demonstrate safety. Since this device meets these criteria, an HDE submission is appropriate. A manufacturer is developing a next-generation knee implant that features a bioresorbable coating to enhance post-surgical recovery. Because this technology has never been used in orthopedic implants before, the FDA classifies the device as significant risk. What regulatory process must the company follow before conducting a clinical trial in the U.S.? A) 510(k) submission B) Humanitarian Device Exemption (HDE) C) Investigational Device Exemption (IDE) D) Real-Time Supplement C) Investigational Device Exemption (IDE) Explanation: An Investigational Device Exemption (IDE) allows a company to conduct clinical trials on a device that has not yet been FDA-approved. Since the knee implant uses a new material and is classified as significant risk, an IDE is required before clinical trials can begin in the U.S. A company submits a 510(k) notification for a new surgical stapler that is substantially equivalent to a legally marketed predicate. The company wants to know how long it will take to receive clearance before they can market their product. What is the standard review timeline for a 510(k) submission? A) 30 days B) 90 days C) 180 days D) 12 months B) 90 days A medical device company receives PMA approval for a Class III orthopedic implant. A year later, the company wants to add a new manufacturing site for the device. Which type of PMA Supplement is required? A) Panel-Track Supplement B) 30-Day Notice C) 180-Day Supplement D) Real-Time Supplement C) 180-Day Supplement Explanation: A 180-Day Supplement is required when making significant changes to a PMA-approved device, such as adding a new manufacturing site. The FDA reviews the supplement within 180 days to ensure that the changes do not impact the device's safety or effectiveness. A company receives HDE approval for a new pediatric heart valve. They are considering mass production and international sales but are unsure about U.S. sales limits under HDE. What is the maximum number of units that can be sold per year under an HDE? A) 4, B) 8, C) 10, D) Unlimited A) 4,000 RAC Book page 157. A company receives De Novo approval for a novel wound-healing device. They are considering future expansions and partnerships with other companies. Can future manufacturers use this device as a predicate for their 510(k) submissions? A) Yes B) No A) Yes Explanation: Once a De Novo request is granted, the device is classified as either Class I or Class II, meaning future devices can reference it as a predicate in 510(k) submissions.
A manufacturer is developing a drug-eluting stent. Under 21 CFR Part 4, which set of current good manufacturing practices (CGMPs) must they comply with? A. Drug CGMPs only (21 CFR Parts 210 and 211) B. Device Quality System (QS) Regulation only (21 CFR Part 820) C. Both Drug CGMPs (21 CFR Parts 210 and 211) and Device QS Regulation (21 CFR Part 820) D. Biologics CGMPs (21 CFR Parts 600-680) C. Both Drug CGMPs (21 CFR Parts 210 and 211) and Device QS Regulation (21 CFR Part 820) For a combination product that includes a biologic and a device, which of the following CGMP requirements is mandatory under the "streamlined approach". A. Establishing a complaint handling system according to 21 CFR Part 820 B. Conducting stability testing as per 21 CFR Parts 210 and 211 C. Implementing environmental controls per 21 CFR Part 600 D. Performing batch production and control record review under 21 CFR Part 211 A. Establishing a complaint handling system according to 21 CFR Part 820 Explanation: When using the streamlined approach, a manufacturer must comply with specific provisions from the QS Regulation (21 CFR Part 820), including complaint handling. Stability testing is specific to drugs, environmental controls pertain to biologics, and batch record review is under drug CGMPs. Which entity is responsible for assigning the primary mode of action (PMOA) for a combination product? A. Center for Drug Evaluation and Research (CDER) B. Center for Devices and Radiological Health (CDRH) C. Office of Combination Products (OCP) D. Manufacturer's Regulatory Affairs Department C. Office of Combination Products (OCP) If a combination product's PMOA is determined to be a drug, which post-market surveillance requirement must the manufacturer follow? A. Medical Device Reporting (MDR) requirements (21 CFR Part 803) B. Drug Adverse Event Reporting (21 CFR Part 314.80) C. Biologics Adverse Event Reporting (21 CFR Part 600.80) D. Both A and B B. Drug Adverse Event Reporting (21 CFR Part 314.80) Explanation: Section B and Para 1: Postmarketing Safety Reporting for Combination Products Guidance for Industry and FDA Staff A combination product consists of a drug and a device, with the drug as the PMOA. If the manufacturer opts for the "streamlined approach" for CGMP compliance, which of the following is NOT required? A. Establishing a design history file (DHF) as per 21 CFR Part 820 B. Conducting stability testing per 21 CFR Part 211 C. Implementing a CAPA system under 21 CFR Part 820 D. Documenting batch production records per 21 CFR Part 211 A. Establishing a design history file (DHF) as per 21 CFR Part 820 RAC Book page 214. Explanation: Following the "streamlined approach" for a CP with drug as its PMOA, CP has to comply for the cGMP requirements per 21CFR 210 and 211 and 21CFR 820 certain requirements as listed below: 820.20 Management responsibility 820.30 Design controls 820.50 Purchasing controls 820.100 Corrective and preventive action 820.170 Installation 820.200 Servicing DHF per 21CFR 820 is not a requirement. A manufacturer of a combination product using a drug and a device must implement design controls when: A. The drug is the PMOA B. The device component is Class III C. The device component is Class II or III and design controls are applicable D. Design controls are not required for combination products C. The device component is Class II or III and design controls are applicable RAC Book page 214. Explanation: Design controls are required for devices classified as Class II or III. If the combination product includes such a device, design controls must be implemented even if the PMOA is the drug. A software team is developing an update for a Class II medical imaging system. They complete code reviews, unit testing, and integration testing but skip usability testing. What is the most likely regulatory concern? A) Noncompliance with ISO 13485 B) Noncompliance with FDA 21 CFR 820.30(g) C) Failure to meet IEC 60601 requirements D) Failure to comply with HIPAA B) Noncompliance with FDA 21 CFR 820.30(g) Noncompliance with FDA 21 CFR 820.30(g)- Design Validation FDA 21 CFR 820.30(g) requires Design Validation, which includes usability testing to ensure the device meets user needs. Skipping usability testing is a compliance risk. A manufacturer develops a cloud-based remote monitoring system for implantable pacemakers. During an FDA pre-submission meeting, the FDA requests documentation on cybersecurity risk management. Which standard should the company reference? A) IEC 62304 B) ISO 14971 C) NIST 800- D) All of the above D) All of the above Explanation: IEC 62304: Software lifecycle process (essential for medical device software). ISO 14971: Risk management standard, applies to software failures. NIST 800-53: Cybersecurity controls, often referenced in FDA guidance.