About the Author
Proxima CRO Team
Isabella Schmitt, MBA, RAC
Director of Regulatory Affairs
Ms. Schmitt has also served in additional regulatory affairs and clinical research roles in which she contributed to multiple regulatory submissions and clinical affairs projects across a wide range of indications.

When a change to the software only restores the device to the specifications of the most recently cleared device, then submission of a new 510(k) is likely not required. Generally, it is unlikely that modifications to software solely to restore the device to the most recently cleared device’s specifications could significantly impact safety, effectiveness, or intended use of the device; however, manufacturers should evaluate the impact of the software changes. Manufacturers should conduct an analysis that involves determining the overall impact of the change to the device in terms of risk assessment and performance. This analysis is important for evaluating any modification that adds new features that appeared in the specification of the most recently cleared device but were not yet implemented.

Missing, incomplete, ambiguous, or conflicting software requirements may lead to a software modification that involves updating specifications, resulting in additional software code changes. In these situations, the answer to this question is likely that a new 510(k) is unnecessary.

Generally, manufacturers are not required to submit a new 510(k) for changes to a specification document to clarify to an existing software requirement or to capture a missing software requirement, provided that this does not necessitate any changes to software code or product performance specifications. However, manufacturers should still assess the impact of the changes on other software documentation when applying appropriate design controls.

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