Non-Recognized Standards: Medical Devices

an indication, but cannot guarantee, the ignition behavior of the assembled integrated devices of a complete wheelchair. The standard states: Where practical, it is advisable that manufacturers use materials with superior resistance to ignition. The manufacturer is required to make the case as to why ISO 7176-16 Wheelchairs-Part 16: Resistance to ignition of postural support devices, could not be employed rather than this part of ISO 16840. Currently FDA recognizes wheelchair standards such as: ISO 7176-16, RESNA WC-1 and WC-2. These standards are used to satisfy premarket performance requirements for all types of wheelchairs. These standards have been accepted to demonstrate substantial equivalence (SE),safety and effectiveness of wheelchairs. The current FDA recognized wheelchair standards series is well understood and for this reason, lend themselves to a Declaration of Conformity (DoC).

In addition, we note that the scope of ISO 16840-10 First edition 2014-12-15 conflicts with ISO TR 13570-1 First edition 2005-04-15 Wheelchairs- Part 1: Guidelines for the application of the ISO 7176 series on wheelchairs , Clause 6.2.3.3 Interpretation of results - Flammability. The clause states in part: Cushions and supports added after purchase may not have been subjected to the flammability test. If you are a smoker or you spend time with people who smoke, then you should choose a wheelchair that passes this test. Because ISO 16840‐10 does not include flammability testing of all the integrated wheelchair "soft" surfaces or upholstered parts, as does the currently recognized ISO 7176-16 and RESNA WC-1:16, value is not added to the review towards a determination of substantial equivalence (SE).

requirements, emissions requirements, and test results/reporting that together confer less expectation of predictability than the FDA-recognized IEC 60601-1-2 standard or provides only part of a complete immunity test for medical device products. It does not adequately test all the attributes that FDA would consider necessary to evaluate the performance for medical devices and medical products that contain sensitive circuitry and electronics, for example. For these reasons, FDA considers the IEC 61326-2-6 methodology not robust enough for FDA to rely upon a declaration of conformity (DoC) that would establish or predict the performance of medical devices when subjected to electrostatic discharge, electromagnetic fields, power frequency magnetic field, and (electrical fast transients) burst.

FDA has recommendations for manufacturers in their Guidance titled:"Information to Support a Claim of Electromagnetic Compatibility (EMC) of Electrically-Powered Medical Devices", published on July 11, 2016. Section II. EMC Information provides what information a claim of EMC for a device should demonstrate to facilitate premarket submissions and reviews. IEC 61326-2-6 may still be fit for its purpose to support the performance of a device subject to a premarket submission to FDA, with proper justification, and this would be dependent upon a risk assessment for the type of medical device under consideration. This use would fall under Section IV.B.,"General Use of Consensus Standards" as explained in our guidance. Please refer to Appropriate Use of Voluntary Consensus Standards in Premarket Submissions for Medical Devices, issued 2018.

not possible because the test methods and requirements in this standard are in conflict with other recognized standards:
1) ASTM F67 Standard Specification for Unalloyed Titanium, for Surgical Implant Applications (UNS R50250, UNS R50400, UNS R50550, UNS R50700)
2) ISO 5832-2 Fourth edition 2018-03 Implants for surgery - Metallic materials - Part 2: Unalloyed titanium
JIS 4650 includes 19 normative references that are required to meet the JIS 4650, all of which are JIS documents and not generally available to those outside of Japan. This may present additional challenges to those who decide to use JIS 4650 outside of Japan and to make a direct comparison with other internationally harmonized standards.

requirements, emissions requirements, and test results/reporting that together confer less expectation of predictability than the FDA-recognized ES60601-1 and IEC 60601-1-2 standards or provides only part of a complete immunity test for medical device products. It does not adequately test all the attributes that FDA would consider necessary to evaluate the performance for medical devices and medical products that contain sensitive circuitry and electronics, for example. For these reasons, FDA considers IEC 61326-1 methodology not robust enough for FDA to rely upon a declaration of conformity (DoC) that would establish or predict the performance of medical devices when subjected to electrostatic discharge, electromagnetic fields, power frequency magnetic field, and (electrical fast transients) burst.

FDA has recommendations for manufacturers in their Guidance titled:"Information to Support a Claim of Electromagnetic Compatibility (EMC) of Electrically-Powered Medical Devices" published on July 11, 2016.Section II. EMC Information provides what information a claim of EMC for a device should demonstrate to facilitate premarket submissions and reviews. IEC 61326-1 may still be fit for its purpose to support the performance of a device subject to a premarket submission to FDA, with proper justification, and this would be dependent upon a risk assessment for the type of medical device under consideration. This use would fall under Section IV.B.,"General Use of Consensus Standards" as explained in our guidance. Please refer to Appropriate Use of Voluntary Consensus Standards in Premarket Submissions for Medical Devices, issued 2018.

Resource Book 2018: Guidelines for Selecting and Using ISTA Test Procedures and Projects; the rationale provided; and, current recognized packaging standards, namely, the ISTA 3 Series. The scope of the ISTA 2A standard and the ISTA Resource Book 2018 state, Test Procedure 2A is a partial simulation test for individual packaged-products. The test procedure is one of three tests offered by ISTA in Series 2: Partial Simulation Performance Tests. The method for 2A includes at least one element of 3 Series type General Simulation performance tests, such as atmospheric conditioning or mode-shaped random vibration, in addition to basic elements of a 1 Series type Non-Simulation Integrity test.

Based upon the scope and ISTA guideline for testing, Test Procedure 2A is characterized as a screening test that confers less expectation of predictability than the FDA-recognized ISTA 3 Series or provides only part of a complete simulation test for packaged products. It does not test all the attributes that CDRH would consider necessary to evaluate the performance for medical devices and medical products that would be packaged as sterile, devices that contain sensitive electronics, devices that contain liquids, or contain components known to be vulnerable to transportation and distribution stresses for example. For these reasons, FDA considers the Series 2A method not robust enough for FDA to rely upon a declaration of conformity (DoC) that would establish or predict the performance of medical devices when subjected to simulated distribution and transportation stressors.