S3 · Validation done

Validation gap review

Your reports read element by element against what cleared summaries in your code state — before the FDA reads them.

The stage

Validation done: the reports are written and a filing date is set.

The question this week

“Do our reports state what cleared devices in our code stated, and where are the gaps?”

Who it is for

  • Regulatory leads with a filing date and finished test reports
  • Small teams without a second reader
  • Consultants who want an independent check before filing

The problem

  • A missing element is usually found by the FDA, as a request for additional information that costs weeks.
  • Nobody has the time to cross-read every report against the code's precedent.
  • It is unclear which gaps matter most in this particular code.

You send

  • Your validation and performance test reports
  • The device description and product code

Under a signed confidentiality agreement, held on the consultant’s machine only and deleted by a date you agree.

You receive

  • Each of the thirteen elements marked: found (with your document and page), not found, or needs a person to judge
  • The gaps ordered by how often cleared summaries in your code state each element
  • Each gap phrased as a question to answer before filing

Format: PDF and Word, every statement footnoted. Typical turnaround: within a week of receiving the reports.

What it is not

  • A finding that the evidence is insufficient — a gap is a question
  • A statement about the FDA's decision

The FDA decides. Every deliverable says so on its cover.

What usually comes next

S4, to assemble the submission.

S4 · Submission drafting →

Talk through S3 for your device

The first S1 brief for your device is free. A twenty-minute call is enough to start: what the device does, where you are, and the date you are working to.