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Actually, your regulatory affairs guy is absolutely right. FDA has a
clear definition of a "finished device," and it does include
software-only products.
You might want to read up on this sometime; the regulations are pretty
easy to follow (which is a lot more than I can say for their European
equivalents).
-----Original Message-----
From: Chris Morton
Sent: Monday, January 09, 2012 12:04 PM
To: techwr-l -at- lists -dot- techwr-l -dot- com
Subject: FDA (b)anality
My company has a software solution that is subject to FDA
approval/scrutiny. That entity insists that we use the following
cautionary statement in our user manual:
CAUTION: Federal law restricts this device to the sale by, or on the
order of, a physician.
Because the software is not a device, I modified the statement to read:
CAUTION: Federal law restricts this product to the sale by, or on the
order of, a physician.
Now our regulatory affairs guy has a pickle up his _____ and is hassling
me over the change. I believe that no one can, or will, bother us about
this minor modification.
What are your thoughts about this?
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