Method·November 1, 2026 · 4 min read

The standard's recognized. One clause isn't.

FDA's Recognition List 066 folded the newest edition of its most-cited biocompatibility standard into the recognized consensus standards database in August 2026 — then named two clauses it would not recognize, one of them in full, because FDA's own risk-management standard already claims that ground.

By Connor Griggs — Regulatory & Quality Strategist

FDA recognizing the current edition of its most-cited biocompatibility standard reads, at a glance, like a clean adoption — the agency catching up to where the standards body already is. The record it actually published says something narrower: recognized, except for two named clauses, one of them in full.

What recognition number 2-313 actually covers

Recognition List Number: 066, the Federal Register notice FDA published August 24, 2026, assigned ISO 10993-1:2025 — the sixth edition of Biological evaluation of medical devices Part 1: Evaluation and testing within a risk management process — its own entry in FDA’s Recognized Consensus Standards Database: recognition number 2-313, succeeding the fifth edition’s 2-258. Nothing about that notice recognizes the new edition as a single document. The database entry it created lists exclusions by clause number, and a Declaration of Conformity citing the standard inherits the exclusions along with it.

The clause FDA already owns

Clause 6.9, “Biological risk estimation,” is excluded in full. FDA’s stated reason is specific: the clause’s own risk-scoring method conflicts with ISO 14971:2019, the device risk-management standard FDA separately recognizes and that this product’s own posts have already covered as the governing risk-management text. Where two recognized standards disagree about the same job, FDA did not split the difference — it subtracted the newer clause and left the standard it already relies on untouched. A narrower exclusion sits beside it: the phrase “consumer products” in Clause 6.5.11.3 doesn’t carry FDA’s recognition either, word-level, inside a clause that is otherwise recognized.

FDA recognizes a standard by clause, not by title page. A Declaration of Conformity that cites the document and skips the database entry is citing more than FDA actually recognized.

The old edition still works

This is a transition, not a cutover. FDA will keep accepting a Declaration of Conformity built on the 2018 fifth edition — recognition 2-258 — through July 1, 2029. A submission in front of a sponsor today has a real choice of edition, not a forced migration, for close to three more years.

The practice

Recognition doesn’t retire FDA’s own guidance layered on top of either edition. Use of International Standard ISO 10993-1, FDA’s current guidance on applying the standard, still asks for material-mediated pyrogenicity testing on devices with prolonged or permanent mucosal or breached-surface contact — an endpoint the standard’s own test-selection tables don’t carry, in either edition. Checking the recognition database’s own exclusions before a submission cites a standard is a mechanical step; whether a specific device’s biocompatibility file still needs something the standard doesn’t ask for is a judgment for the toxicologist or regulatory professional on that file, never a determination this post makes for them.

FDA Radar doesn’t monitor the Recognized Consensus Standards database today — see what we monitor and what we deliberately don’t. Until a reliable feed exists for it, reading the live database entry, clause by clause, stays a manual step ahead of every submission that cites one.

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The malfunction report that never reaches FDA
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A provider letter doesn't need a recall
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A qualified tool has a context, not a blanket
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The eMDR account isn't automatic
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The manufacturer who owns no factory
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GLP covers the safety study, not the device
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Part 11 governs the copy, not the duty.
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A K-number isn't always a 510(k)
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Approved once. Reported every year.
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The goal date passes. FDA owes a letter.
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The money a 510(k) never has to mention
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A discussion paper isn't guidance
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A stereotaxic system isn't a RASD
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The A-list is a forecast, not a deadline.
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Ultra has a gram range. Fragrance doesn't.
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Patient preference just reached the 510(k)
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The health hazard evaluation isn't the record
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The sponsor proposes risk. The IRB decides.
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A Special 510(k) needs a predicate you own
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The flag marks the reviewer, not the result
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Call it fifteen. File it in thirty.
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The recognition number isn't the list number
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The letter to file isn't in the guidance
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The PMA preempts. The 510(k) doesn't.
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Cleared doesn't code. Coded doesn't cover.
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Exempt from 510(k). Restricted anyway.
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Exempt from registration. Not from 510(k).
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Right to try reaches drugs, not devices
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The 510(k) clears the range, not the fit
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The hospital's duty runs to the maker, not FDA.
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The predicate study isn't the waiver study.
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No clinical hold for an IDE. Only disapproval.
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A CFG can cover a device that never came here.
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The symbol skips text. The glossary can't.
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The label clears 812.5. The flyer doesn't.
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A 510(k) can change hands. No rule says how.
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A missed renewal is two violations, not one
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Drugs expire by rule. Devices by choice.
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Denied the petition. Not the outcome.
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Starting a committee is public. Renewing isn't.
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A recall closes. A radiation refund doesn't.
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The trial is public. The IDE isn't.
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A PMA withdrawal pays back. A 510(k) doesn't.
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Interoperable is a design term, not a class.
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The category is new. The 510(k) record isn't.
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The device is cleared. Not the room.
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Classified in 2011. Excluded in 2016.
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The law reached devices. The guidance hasn't.
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The label says RUO. FDA reads intent.
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Humanitarian. Not always nonprofit.
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The certification has a one-year tail
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The code changed. The failure didn't.
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Skip has a ceiling. Search after doesn't.
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Reviewed together. Decided separately.
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Class III. Not called for PMA.
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The standard for the wire, not the device
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A reference device isn't a predicate
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A predicate checklist nobody has to follow
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The pathway that skips the predicate
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A network FDA funds, not FDA runs
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Panel-recommended. Not yet classified.
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The pilot that needed a statute
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A committee no clearance ever names
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Never cleared here. Exported anyway.
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Built for drugs. Silent on devices.
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A significant decision carries its own clock
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The guidance that went back to draft
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Breakthrough crosses centers. TAP does not.
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Two lists decide who reviews your 510(k)
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The reprocessor holds the 510(k)
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The Rx symbol never reaches the record
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The disqualification list names no device
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The summary FDA writes, not the sponsor
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A missed MDR is misbranding, not a defect
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Two names on one registration, two jobs
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A K-number is public. The other isn't.
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Exempt covers the type, not the use
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Recognized. Not published.
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The supplement got eSTAR. The PMA did not.
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Congress ordered a guidance, not a rule
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AI-enabled is a list. Not a field.
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The companion diagnostic list changed its name
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The master file neither of you can read
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The condition inside the approval order
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The repair FDA calls manufacturing
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Vacated in March. Filed in September.
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Classified. Not waived.
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Emergency use isn't defined in Part 812
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The two-year inspection clock is gone
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The PMA clock starts at the last module
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The Q-Sub that doesn't buy you more time
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Lapsed and revoked end an EUA differently
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A recall strategy has a grade. openFDA doesn't.
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A granted De Novo becomes a predicate.
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Least burdensome changes the ask, not the bar.
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The lab is accredited. Not the device.
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Breakthrough is law. STeP is a guidance.
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MDSAP replaces routine. Not for-cause.
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No field on a 510(k) says what it treats
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Discretion is a policy. Exclusion is a statute.
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Designated by one office. Approved by another.
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MedSun sits beside MAUDE, not inside it
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The five-unit device never gets a K-number
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Meeting the criteria isn't a tracking order
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The PMA clock doesn't stop at approval
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The K-number doesn't track today's device
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A MAUDE report proves it was filed
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Not every MDR starts with the manufacturer
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Completed. Not terminated.
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The device-ban list has three entries
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The UDI exception has its own deadline
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MDUFA VI is being negotiated in public
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The inspection manual changed, not the rule
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The count Congress had to legislate
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The small-business rate isn't retroactive
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A detention order has no docket to read
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PMA approvals moved off the Federal Register
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A citizen petition names names
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A market withdrawal isn't a recall
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Not every device letter comes from CDRH
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Closed on one device. Open on the rest.
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No IDE is confirmed until the PMA is
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The remedial-action call sets the clock
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Jurisdiction is a letter, not a field
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An address is not a footprint
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The final rule that isn't final yet
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The special controls aren't in the record
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Exempt from GMP. Not from complaints.
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The notify list isn't the shortage list
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A constraint can't be skipped. A script can.
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No cron sends this. A person does.
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Corrected, not rewritten
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Quiet is a finding, not a default
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The summary is public. The statement isn't.
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A competitor's 513(g) leaves no trace
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An empty response field proves nothing
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A petition is public. Its outcome isn't.
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The panel is a category, not a meeting
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An accessory carries its own classification
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A TPLC report is a category, not a device
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A 522 order is a question, not a verdict
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A PCCP change leaves no new record
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Not every signal becomes a recall
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eSTAR did not remove the acceptance check
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An early alert has no recall number yet
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A consent decree isn't a database row
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The record has no cybersecurity field
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Classification Change is not one event
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Publication date is not effective date
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One event. Many recall numbers.
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Quantity is a sentence, not a number
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How a firm told you is a field too
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A RIN outlives the document number
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The docket ID is not the comments
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The 510(k) record doesn't name the predicate
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The 510(k) FDA didn't review first
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The letter FDA doesn't have to post
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Cleared doesn't say which track it took
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The clock stops. The calendar doesn't.
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Why a guessed match never reaches you
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The standards list never names a device
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The guidance isn't in the Federal Register.
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Filtered. Not discarded.
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There are two recall databases, not one
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Breakthrough status is confidential by law
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One MAUDE report is not one malfunction
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A supplement number is not a track
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Cleared is not approved
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Nationwide doesn't mean your building
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Not every correction reaches FDA
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Registered. Not reviewed.
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Contact ODE is not a pathway
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Almost no recall is FDA-mandated
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FDA's device names read like a card catalog
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openFDA is free. It is not unlimited.
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GUDID stores the model. Not the box.
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Detention doesn't need a warning letter
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A Class I device, a Class I recall
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21 CFR 820 didn't move. Its contents did.
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The product code that doesn't exist yet
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The classification posts. The 483 behind it doesn't.
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A recall has three dates, and the pipeline had to pick one
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The count is real. The rate is not.
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The firm on the record is not the firm on the box
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Low confidence is an instruction, not a hedge
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The same company, spelled three ways
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A device that was never a medical device
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FDA's warning letters, addressed by column number
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Your regulation has a decimal. FDA's watch doesn't.
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Three letters is too short to search for
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Most warning letters never close
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The guidance that skipped the draft
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Ongoing, as of when?
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The least interesting fact in a 510(k)
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No recall arrives with a product code attached
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The deadline that doesn't email you
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The warning letter has two dates
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How to monitor FDA without drowning
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Your predicate was recalled. Now what?
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Why no item reaches you without a human