Class I Recalls of Cardiovascular Devices

Quick Takes

  • Between 2013 and 2022, the U.S. FDA issued 137 Class I recalls affecting 157 unique cardiovascular devices, of which 112 (71%) were moderate-risk 510(k) devices and 45 (29%) were high-risk premarket approval devices.
  • Cardiovascular devices with Class I recalls were infrequently subjected to premarket or postmarket testing and affected thousands of patients annually.

Study Questions:

What are Class I Food and Drug Administration (FDA) recalls of cardiovascular devices and what is the clinical evidence supporting authorization?

Methods:

The authors used the FDA Medical Device Recalls database to identify Class I recalls of cardiovascular devices from 2013 through 2022.

Results:

There were 137 Class I recall events affecting 157 unique cardiovascular devices, of which 112 (71%) were moderate-risk 510(k) devices and 45 (29%) were high-risk premarket approval devices. Recalls affected a median of 7,649 units and were most commonly attributed to device design. Forty-two (27%) devices had multiple Class I recalls. Thirty (19%) devices underwent premarket clinical testing. Most studies used surrogate and composite measures as primary endpoints. Twenty-two (50%) premarket approval devices had required post-approval studies. No 510(k) devices were subject to postmarket surveillance.

Conclusions:

The authors conclude that cardiovascular devices with Class I recalls were infrequently subjected to premarket or postmarket testing and that recalls affected thousands of patients annually.

Perspective:

Most cardiovascular devices are designated by the U.S. FDA as Class II or Class III devices, to reflect moderate or high risk, respectively. For example, diagnostic catheters and balloon pumps are designated as Class II devices, and they are approved to enter the market via the 510(k) pathway, which requires that new devices share indications and have technological characteristics similar to those of devices that are already legally authorized for marketing. In contrast, Class III devices, such as implantable cardioverter-defibrillators and stents, are approved under the premarket approval pathway, which requires premarket clinical evidence of safety and effectiveness to obtain FDA approval, a higher burden of evidence. In the current study, the authors examined records for cardiovascular devices which after approval were designated to have Class I recalls.

Class I recalls are the FDA’s most severe designation, indicating a reasonable probability of “serious adverse health consequences or death.” The authors of the current study show that >70% of the devices which became Class I recalls had been authorized under the 510(k) pathway, the one requiring less rigorous evidence before approval. Most studies used surrogate and composite measures as primary endpoints. These findings show limited clinical evidence was used to approve the devices later found to have serious safety concerns. The authors also offer many policy prescriptions on how to improve patient safety.

Clinical Topics: Arrhythmias and Clinical EP, Implantable Devices, Invasive Cardiovascular Angiography and Intervention

Keywords: Device Approval, Medical Device Recalls


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