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. 2023 Jan 10;329(2):136–143. doi: 10.1001/jama.2022.23279

Table 2. Characteristics of Predicate Devices Used to Support Clearance of Recalled 510(k) Devices.

No. (%)
Total No. of predicates cited by index devices 243
No. of predicates per device, median (IQR) 1 (1-2)
Time between predicate and index device clearance, median (IQR), y 4.0 (2.0-7.9)
No. of index devices with information about predicatesa 127
Using recalled predicates 92 (72.4)
Using a predicate with ≥1 Class I–designated recall 56 (44.1)
Total No. of unique predicatesb 229
Use of clinical data in predicate device’s 510(k) application
Included clinical data 10 (4.4)
No clinical testing 137 (59.8)
Insufficient information in decision letterc 35 (15.3)
Information about device evidence unavailabled 47 (20.5)
No. of recalls per predicate, median (IQR) 1 (0-2)
Predicate devices with history of recall 123 (53.7)
Recalled predicate devices with at ≥1 Class I–designated recall 64 (28.0)
a

Of the 156 index devices, 127 had information available about their predicates.

b

Of the 243 predicates identified for the 127 index devices, 14 were duplicates (cited by multiple index devices); 229 reflects the number of unique predicates.

c

Decision memo was available in the Devices@FDA database for the index device but did not state explicitly whether premarket clinical testing was conducted.

d

No decision memo was posted for the index device in the Devices@FDA database, and as such, it was not possible to determine what, if any, premarket clinical testing was conducted.