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Consolidated Review of Submissions for Lasers and Accessories #G90-1 (Blue Book Memo) October 1990

Issued by:
Guidance Issuing Office
Office of Medical Products and Tobacco, Center for Devices and Radiological Health

This guidance was written prior to the February 27, 1997 implementation of FDA’s Good Guidance Practices, GGP’s. It does not create or confer rights for or on any person and does not operate to bind FDA or the public. An alternative approach may be used if such approach satisfies the requirements of the applicable statute, regulations, or both. This guidance will be updated in the next revision to include the standard elements of GGP’s.

General Program Memorandum #G90-1


Date:  Oct. 19, 1990                   

From:  Director, Office of Device Evaluation (HFZ-400)

Subject:  Consolidated Review of Submissions for Lasers and         

To:  ODE Review Staff

Purpose.  The purpose of this guidance is to promote uniformity and 
efficiency in the review of submissions for lasers and their 
accessories.  510(k) submissions for these devices may have been 
reviewed in different divisions depending upon the intended use of a 
specific device.  This guidance assures the consolidation of 
responsibility for review of 510(k) submissions and their supporting 

IDEs for these devices within one division, while at the same time 
maintaining inter-divisional consultations, as necessary, to assure the 
high level of expert review that has been applied in the past.  This 
memorandum clarifies the roles and responsibilities of the primary 
reviewing division and the consulting divisions and sets forth the 
procedures they will use for this review process.
Identification of Divisions and Devices.  The following 
divisions and devices are the subject of this memorandum:

      -  Consolidated Devices:          LASERS AND ACCESSORIES

      -  Primary Division:              DIVISION OF SURGICAL AND
                                        REHABILITATION DEVICES

      -  Consulting Divisions:          ALL ODE DIVISIONS, EXCEPT THE
                                        DIVISION OF CLINICAL LABORATORY

510(K)s and Supporting IDEs.

      -  The Primary Division will be responsible for the review of 
      510(k)s and supporting IDEs for the Consolidated Devices.

      -  The Consulting Division will provide to the Primary Division 
      the name of its contact person who will serve as the liaison

      with the Primary Division concerning 510(k)s and IDEs for the 
      Consolidated Devices.

      -  The Consulting Divisions will provide to the Primary Division 
      a list of intended uses, i.e., indication statements, for all 
      Consolidated Devices and their accessories that are subject to 
      this memorandum and that have been found to be 
      substanially equivalent via 510(k) decisions including a brief 
      statement regarding currently required data to support these 
      decisions.  In addition, the Consulting Divisions will also 
      provide, when applicable, a list of Consolidated Devices that 
      have approved PMAs and relevant PMA information that will
      assist in making 510(k) decisions.

      -  The Consulting Divisions will provide to the Primary Division
      a list of current IDEs that are approved for the purpose of 
      gathering clinical data in support of a 510(k) for the 
      Consolidated Devices.  These ongoing IDEs will be transferred to 
      the Primary Division.  Future submissions concerning these 
      IDEs, e.g., amendments, will be reviewed by the Primary 
      Division.  The Primary Division, in turn, will obtain feedback 
      from the Consulting Divisions, if necessary.

      -  During the review of 510(k)s for the Consolidated Devices, 
      the Primary Division will seek input from the Consulting 
      Divisions whenever necessary, such as when a 510(k) contains 
      an indication statement that raises the posibility that a new 
      use may be intended.  After a new indicatioin statement has 
      been approved via the 510 process a few times, the Primary 
      Division will seek consultation only when deemed appropriate.

      -  When input is sought from a Consulting Division, all 
      necessary feedback will be provided to the Primary Division 
      within 30 days.  With respect to "not substantially equivalent" 
      decisions, the Primary Division will obtain the review and 
      concurrence of the Consulting Divsions, which will be reflected 
      in the yellow sign-off sheets.

PMAs and Supporting IDEs.  

      -  As in the past, a PMA and its supporting IDE for a 
      Consolidated Device will be reviewed by the division 
      responsible for the medical specialty for whose use the device 
      is intended.  This may be the Primary Division or a Consulting 
      Division, depending upon the specific device and its intended 
      use.  If the reviewing division for the PMA/IDE is a Consulting 
      Division, the Primary Division, when requested, will provide 
      the technical review of these submissions for the reviewing 

New IDEs.  

      -  The POS/DMC will send all new IDEs for Consolidated Devices 
      to both the Primary Division and the Consulting Divisions.  
      Within two days of receipt ot the IDE, the Primary Division and 
      the Consulting Divisions will meet to decide whether the device 
      is likely to proceed to markdet via a 510(k) or PMA.  The 
      Primary Division will be responsible only for 510(k) track IDEs.  
      The PMA track IDE will be reviewed by the division that will 
      review the PMA, as discussed above.

Other General Procedures.  
      -  The Primary Division will send copies of all 510(k) and IDE 
      decision letters to the appropriate Consulting Division at the 
      time each is issued.

      -  The Primary Division will conduct monthly or bimonthly 
      meetings with the Consulting Divisions to provide an update on 
      the status of reviews and actions taken since the previous 

      -  Issues between the Primary Division and the Consulting 
      Divisions that are not resolved at the review level will be 
      documented and presented in a timely manner to the affected 
      division directors for resolution.  If any issue cannot be 
      resolved by the division directors, they will refer the matter 
      to the Office of the Director, Office of Device Evaluation.

Effective Date.  This guidance memorandum is effective immediately.



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