Two alternatives to the PMA exist for class III devices: the “Product Development
Protocol” (PDP) and the “Humanitarian Device Exemption” (HDE). The PDP process is
based upon early consultation between the sponsor and the FDA, leading to a device
development and testing plan that is acceptable to both parties. Once the PDP has been
accepted, periodic reports are submitted to the FDA followed by a “Notice of
Completion.” If the FDA finds that all requirements have been met, the PDP will be
declared complete, and the device may go to market.
An HDE application for a Humanitarian Use Device is essentially the same as a PMA in
both form and content but is exempt from the effectiveness requirement of a PMA. Though
the HDE does not require scientifically valid data demonstrating effectiveness the application
must contain sufficient information for the FDA to determine that the device does not
pose an unreasonable or significant risk of illness or injury to patients. It must also demonstrate
that the probable benefit to health outweighs the risk of injury or illness from its use.