NCHR Comments on De Novo Classification Process

October 14, 2014. As members of the Patient, Consumer, and Public Health Coalition, we have serious reservations about the use of the de novo classification process for implants, life-sustaining, and life-saving devices. We believe that all such high-risk devices should be Class III devices reviewed through the more rigorous PMA process.

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NCHR Comments on Benefit-Risk Factors to Consider When Determining Substantial Equivalence in Premarket Notifications

October 14, 2014. We oppose the draft guidance as written and strongly urge the FDA to rewrite it. The current draft guidance relies on vague wording and subjective judgments, not science or technological assessments. When it is more specific, it promotes the use of surrogate endpoints and the risk tolerance of a small number of patients whose views come to the FDA’s attention.

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NCHR Testimony at FDA Advisory Panel on Device Classification

Oct. 9, 2014. NCHR supports the FDA’s recommendation that More-than-Minimally Manipulated (MMM) Allograft Heart Valves be classified as Class 3 devices and therefore subject to the premarket approval process. All other types of heart valves under the oversight of the Center for Devices and Radiological Health at the FDA are classified as class 3. There is no reason that these heart valves should be an exception.

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Chantix Citizen Petition

October 8, 2014. Five leading nonprofit consumer, research and medical organizations identified below petition the Food and Drug Administration (FDA) pursuant to the Food, Drug, and Cosmetic Act 21 USC 352, 505(o)(4), and 21 CFR 10.30 to take action to improve the safety information included in the label for CHANTIX® (varenicline) tablets , a smoking cessation aid approved under NDA 021-928.

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NCHR Testimony at FDA Advisory Panel on the WATCHMAN™ Left Atrial Appendage Closure Device

October 8, 2014. In summary, patients implanted with the device are at increased risk for ischemic stroke. Methodological problems make it difficult to assess if the device reduces hemorrhagic strokes. The decrease in major bleeding events after 6 months is negated by the increased major bleeding events due to surgery. The device is inferior to warfarin for 2 of the 3 primary endpoints identified by the sponsor and the FDA as signifying success.

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