S4 · Ready to file

Submission drafting

The record half of a 510(k) or De Novo, assembled in days — every drafted sentence sourced and reviewed by a person.

The stage

Ready to file: the documents exist and the content needs assembling.

The question this week

“Can the submission content be assembled without losing three weeks to tables and checklists?”

Who it is for

  • Companies preparing a 510(k) or De Novo with a small regulatory team
  • Consultants who want the assembly done under their review

The problem

  • The equivalence table, the evidence sections and the acceptance checklist take a senior person weeks.
  • Every figure must trace to a page, and keeping that discipline by hand is slow.
  • Drafting tools produce fluent text with no sources, which a reviewer cannot trust.

You send

  • The full document set: test reports, device description, labeling, software documentation
  • The predicate, if chosen

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

You receive

  • The substantial-equivalence table, the predicate's column quoted from its public summary with pages (or reference devices for a De Novo)
  • Drafted sections in which every sentence cites your document or a predicate page, reviewed sentence by sentence
  • The FDA's acceptance checklist, item by item, mapped to where each is met
  • Change-control plan and human-factors sections from your answers
  • A not-exported appendix listing every statement still owed — nothing unsourced is ever included

Format: PDF and Word, every statement footnoted. Typical turnaround: one to three weeks, depending on the document set.

What it is not

  • A completed eSTAR — the content is organised to its sections and a person enters it
  • A statement about the FDA's decision on the submission

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

What usually comes next

Ongoing: a watch on your code, if you ask for one.

Talk through S4 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.