Thank you for breaking this down. I assume the Auricle team would at least carry some of these processes forward while the FDA does their thing? I understand they probably wouldn't make a large order or train distributors without approval, but at least know where that order would be sent? My fear is the FDA pulls some kind of stunt where they want another trial of data before approving. Would help if we knew it's at least in front of them.
Outside that I'm just trying to figure out if this darn thing will do anything for me.
You're welcome.
Depending on how the prototypes were developed, some of these may already be in place.
I have no knowledge of the data generated by UoM/Auricle during their trials and development, but I'd be quite surprised if the FDA asked for anything close to another study. I know many here were disappointed with the number of participants in the second study, but statistically speaking - the number of participants was more than satisfactory.
Whilst I can't offer any insight into how long this will take to hit market, I can hopefully offer some reassurance to those anxiously awaiting release. This device is not Class III, it does not contain any chemicals, it doesn't have a chemically processed production method, it doesn't contain any bio-active materials, it has no synthetic/animal derived raw materials, it's not implantable, it's not a life-prolonging device and so the approvals process should really be quite simplistic, relatively.
Any of the above would mean the submission process is a completely different beast. For example, the FDA may ask for residual chemical analysis, design of experiments to reduce residual load, biocompatibility studies, stringent raw material control, unwanted chemical interaction tests etc which generally always result in additional studies/investigations. As this isn't the case here, I don't really think Auricle will have any
major problems with approval. Just the usual
"please explain X,Y,Z in greater detail and provide evidence."
Take FMEA (failure mode and effect analysis) as our example here. This is one of several risk management techniques required by regulatory bodies. This looks as the question of
"what if A,BC goes wrong?" You assign various risk factors depending on the failure mode you're assessing. I frequently take part in FMEAs whereby the possible outcome is fatal i.e. brain death, inhibited platelet aggregation leading to possible excessive bleeding, tissue rejection and necrosis - well beyond anything that's possible with this device. These must have risk strategies to identify the problems and solutions to fix it, as well as looking at possible occurrence rates. If your solutions to these problems are unsatisfactory, regulatory bodies will let you know or may even reject your submission. Going back to this device, the worst possible failure mode I can think of (again, I'm not an expert in this field) is the device going out of timing and thus the patient not getting the proper active treatment. Solution? Potential internal calibration prior to allowing the treatment to start as a go/no-go test. If the internal calibration/verification fails, the device will refuse to operate. The only risk to the patient here is that they may need to go a week or two without the treatment whilst their device is repaired. Annoying? Yes. Threat to life? No.
Speaking as a tinnitus sufferer, it doesn't fill me with any joy that we'll still be waiting a while for this to hit the market. As a scientist that deals with global regulatory bodies, it fills me with confidence there will be no catastrophic hurdles to overcome with approval.
I tend to waffle in these responses and probably bore a lot of people, but I think it'd be a disservice to my fellow sufferers that maybe are interested in it if I didn't try and impart some of my knowledge with the regulatory process.