How to use this
The keys, the words, and what each figure means.
The flow
- 1Paste — your device description or a draft 510(k) — or drop the folder. Or start from a K-number you already hold.
- 2Read the verdict — it says whether you can file, what that means, and the one thing to do first.
- 3Answer one question — if the system could not settle a fact from your text, it asks the single one that changes the most — and tells you what changes.
- 4Check each answer — every card opens with the answer, then its basis, what it read, how often that kind of answer is wrong, and what would move it.
- 5Correct where you disagree — on any row. A correction is marked yours, kept on the record, can be undone, and is offered back to you on later dossiers — never applied on its own, never shared across sponsors.
- 6Review and endorse — a qualified person records the review. Export the Word file, the documents, or the eSTAR data.
Keys
- ⌘K / Ctrl+K or ?
- open the palette — go to any section, export, copy the link
- ⌘ / Ctrl + Enter
- analyze the device text
- /
- open the intake and focus the device text
- a
- focus the first answer
- j / k
- next / previous section
- Esc
- close
The words
FDA’s terms, as the page uses them. Each is also defined where it first appears.
- predicate
- A device FDA has already cleared that yours is compared to. A 510(k) is cleared by showing your device is substantially equivalent to it.
- intended use
- What the device is for, in general — the purpose. FDA compares it with the predicate’s first; if it differs, the 510(k) route is closed.
- indications for use
- The specific conditions, patients and settings the device is meant for. Must stay within the predicate’s intended use.
- substantial equivalence
- The 510(k) test: same intended use as the predicate, and either the same technology or differences that raise no new question of safety or effectiveness.
- Refuse-to-Accept
- FDA’s 15-day completeness screen. A submission missing any checklist element is refused before review starts.
- De Novo
- The route for a device with no predicate: FDA creates a new classification. Slower and costlier than a 510(k).
- Special 510(k)
- A faster 510(k) for a change to a device you already had cleared, when the change can be checked by design controls.
- Abbreviated 510(k)
- A 510(k) that relies on declared conformity to FDA-recognized standards or guidance instead of full test reports.
- product code
- FDA’s three-letter label for a device type. It fixes the regulation, the class and what FDA expects.
- regulation
- The section of 21 CFR that defines the device type and its class — what the product code points to.
- recognized standard
- A consensus standard (ISO, IEC, ASTM…) FDA has formally recognized. Declaring conformity to the recognized edition carries weight; an older edition may not.
- special controls
- Extra requirements FDA attaches to a Class II device type — labeling, testing, performance — that a submission must address.
- Pre-Submission
- A Q-Sub: a written request for FDA’s feedback before filing. Optional; advisable when the route or the testing is uncertain.
- 513(i)(2)
- The section of the FD&C Act that bars a predicate: a device that was removed from the market, or found misbranded or adulterated, cannot be one.
- AI letter
- FDA’s Additional Information request during review. The clock stops until you answer; the questions are confidential to the sponsor.
- NSE
- Not substantially equivalent — FDA’s refusal of a 510(k). The device cannot be marketed on it.
- eSTAR
- FDA’s electronic submission template. Every 510(k) is filed in it; the fields are fixed.
- pre-dates
- Cleared before your submission date — a predicate must have been legally marketed before you file.
- §524B
- The cybersecurity section of the FD&C Act: a device with software that can connect needs a cyber package (SBOM, threat model, patch plan).
- PCCP
- A predetermined change control plan — for AI/ML devices, the future changes FDA clears in advance.
- MAUDE
- FDA’s adverse-event reports database. Counts of reports, not rates of harm.