Dr. Michael Kasser, from Center for Devices and Radiological Health at the FDA, has published an article in the Journal of Biomedical Material Research detailing the history of regulation on ultra high molecular weight polyethylene (UHMWPE) and its use in medical devices. This article is available as a early view download for registered users. Dr. Kasser offers a flow chart for the 510K decision making process to decide if a new productis substantially equivalent to a product already on the market, and therefore, if the 510K route can be used, as opposed to the more costly and time-consuming PMA route.
The paper outlines some of the testing used for establishing equivalency, based on ASTM test methods and tests developed within the orthopedic industry. In particular, custom tests designed to test anti-oxidants used in UHMWPE are required for 510K submissions.
Cambridge Polymer Group has assisted several clients in getting regulatory clearance on their UHMWPE materials, and is very familiar witht the testing requirements.