Postmarketing Surveillance of Medical Devices — Filling in the Gaps

Abstract
Failures of implantable medical devices, although rare, can carry a substantial risk of serious injury. From 2000 through 2011, more than 150 new high-risk medical devices were approved by the Food and Drug Administration (FDA) through the premarket approval (known as PMA) process, and an additional 600 devices were cleared through the less demanding 510(k) process, in four medical specialty areas (cardiovascular care, neurology, obstetrics and gynecology, and orthopedics; see graph ). The problem that Hauser describes (pages 873–875) — the erosion of the insulation in St. Jude Medical's Riata leads for implantable cardioverter–defibrillators — highlights the fact that medical devices are complex assemblies of multiple components, and the failure of any single component can lead to unexpected and serious safety problems. Because it is impossible to design an implantable medical device with zero risk of failure, effective systems for monitoring safety after a device is on the market are essential for protecting the public health. Moreover, since incremental changes are made in medical devices throughout their life cycles, it is impractical to prospectively study each change comprehensively before marketing. Balancing the need for robust postmarketing safety monitoring with the need to avoid the stifling of innovation is a prime responsibility of the Center for Devices and Radiological Health (CDRH) at the FDA.