The lab is accredited. Not the device.
ASCA lets a submission use an FDA-accredited testing lab and a shorter Summary Test Report instead of a full one. That is a paperwork change to how a submission gets reviewed, never a lower bar for what a device has to meet.
By Connor Griggs — Regulatory & Quality Strategist
A test report proves a device meets a standard. Whether FDA re-reads that report line by line or takes a laboratory’s word for it turns on something that has nothing to do with the device at all: which lab ran the test, and whether that lab has been accredited under FDA’s Accreditation Scheme for Conformity Assessment (ASCA).
What gets accredited, and by whom
ASCA accredits testing laboratories, not devices and not sponsors. An accreditation body FDA recognizes evaluates a lab against ISO/IEC 17025 competence requirements for a specific standard and test method — biocompatibility testing to the ISO 10993-1 series, say, or basic safety and essential performance testing to the IEC 60601-1 and IEC 61010 families. Congress created the legal basis for this in 2017, adding a pilot accreditation program to Section 514(d) of the FD&C Act — 21 U.S.C. 360d(d). FDA ran the pilot from 2020, and the 2022 MDUFA V reauthorization amended the same subsection to drop the pilot’s sunset: ASCA has been a permanent, ongoing program since September 19, 2023.
What changes in a submission
Nothing about the standard changes. What changes is the paperwork behind it. A submission that normally carries a declaration of conformity plus a complete test report can, when the testing ran at an ASCA-accredited lab, carry the declaration plus an ASCA Summary Test Report instead — a shorter, standardized document the lab produces rather than its own full report. FDA’s stated practice is not to come back with additional-information requests about that lab’s methodology once the summary report is in hand, because accreditation already vouched for the methodology up front. That removes one specific category of review friction. It does not shorten the rest of the review, and it does not decide the outcome.
Accreditation vouches for the lab’s competence. It does not vouch for the device.
What it doesn’t cover
The program only reaches the standards FDA has specifically built ASCA guidance around, and that list started narrow — biocompatibility and basic safety and essential performance first — and has grown since, one standards-specific guidance at a time. A standard outside that list gets no ASCA benefit no matter how reputable the lab is, and a device that fails to meet a standard fails it whether an accredited lab or an unaccredited one ran the test. Participation is voluntary on both sides — for a testing lab seeking accreditation and for a manufacturer choosing where to send a device — and FDA charges no additional fee to use it.
The practice
The decision worth making early is which lab runs which test, not which submission strategy to file. Before committing a device’s biocompatibility or electrical-safety testing to a lab, check FDA’s current list of ASCA-accredited labs and standards-specific guidances against what that lab is actually accredited for — accreditation is granted standard by standard and lab by lab, not as a blanket credential. openFDA’s 510(k) record, and FDA Radar’s own copy of it, keep the K-number, applicant, device name, product code, decision code and description, advisory committee, and third-party-review flag for every clearance. None of those fields say whether the underlying testing went through an ASCA-accredited lab at all — that fact lives in the submission file, never in the public dataset. This is regulatory intelligence and method, never regulatory advice about which lab or pathway fits a specific device; that determination belongs to the regulatory professional holding the file.
Primary sources
- 21 U.S.C. § 360d(d) — Accreditation scheme for conformity assessment
- FDA — Accreditation Scheme for Conformity Assessment (ASCA)
- FDA — Manufacturers: How to Participate in ASCA
- Federal Register — The Accreditation Scheme for Conformity Assessment Program; Draft Guidances for Industry, Accreditation Bodies, Testing Laboratories, and FDA Staff; Availability
- FDA Radar — what we monitor and how often
Regulatory intelligence, not regulatory advice. This post describes method and published FDA records as of its date; decisions about a specific device belong with your regulatory professional.