Method·August 23, 2026 · 3 min read

The summary is public. The statement isn't.

A 510(k) applicant satisfies the same disclosure rule two different ways — a summary FDA posts for anyone to read, or a statement promising the same safety-and-effectiveness data to whoever asks within 30 days. The clearance record doesn't say which one a given filing chose.

By Connor Griggs — Regulatory & Quality Strategist

Every cleared 510(k) satisfies the same disclosure requirement one of two ways, and the choice belongs to the applicant, not FDA. 21 CFR 807.92 describes a 510(k) summary: enough detail about the device and the basis for substantial equivalence that FDA can post it publicly on its own initiative. 21 CFR 807.93 describes the alternative — a 510(k) statement, a short certification that the applicant will hand the same underlying data to anyone who asks. Two documents doing the same regulatory job, with opposite defaults on who ever sees the substance behind a clearance.

What a statement actually promises

21 CFR 807.93 is specific about what the certifier is on the hook for: all of the safety and effectiveness information in the original submission, made available within 30 days of a request — a duplicate of the filing itself, adverse findings included, with only patient identifiers and confidential commercial information withheld. Nothing in the regulation requires FDA to hold or forward that data. The obligation sits with the company that cleared the device, and it activates only if a specific person asks for it.

What FDA Radar’s own clearance record carries

openFDA’s 510(k) endpoint returns a field for exactly this choice — statement_or_summary — on every record, and FDA Radar’s ingestion reads it off the raw payload for every clearance it fetches. It does not currently carry that value into the facts a reader sees: not the K-number’s title, not its source text, not the structured fields a future watchlist would query. The distinction this post describes comes from FDA’s own field reference and the regulation behind it — not from anything FDA Radar surfaces about a specific clearance today.

A summary is a document you can read. A statement is a promise you have to collect on — and nothing in the public record says which one you’re looking at.

The practice

Before treating a competitor’s or a predicate’s K-number as fully documented because a 510(k) summary turned up in a search, confirm it actually is one. A statement-route clearance carries no public summary at all — only the certification, and the fact of clearance itself. If the safety-and-effectiveness basis matters to a predicate decision, 807.93 gives a path to it: a written request to the applicant, with a thirty-day clock the regulation puts on them, not on FDA. What that basis should mean for a specific predicate or submission is a judgment for a regulatory professional working the file — this is regulatory intelligence about which of two documents a clearance produced, per FDA Radar’s editorial standards, never advice about when to invoke the request yourself.

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.

Method
The lab is accredited. Not the device.
Practice
Breakthrough is law. STeP is a guidance.
Practice
MDSAP replaces routine. Not for-cause.
Method
No field on a 510(k) says what it treats
Method
Discretion is a policy. Exclusion is a statute.
Practice
Designated by one office. Approved by another.
Method
MedSun sits beside MAUDE, not inside it
Practice
The five-unit device never gets a K-number
Practice
Meeting the criteria isn't a tracking order
Method
The PMA clock doesn't stop at approval
Practice
The K-number doesn't track today's device
Method
A MAUDE report proves it was filed
Practice
Not every MDR starts with the manufacturer
Method
Completed. Not terminated.
Practice
The device-ban list has three entries
Method
The UDI exception has its own deadline
Method
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
Practice
The small-business rate isn't retroactive
Method
A detention order has no docket to read
Practice
PMA approvals moved off the Federal Register
Method
A citizen petition names names
Practice
A market withdrawal isn't a recall
Method
Not every device letter comes from CDRH
Practice
Closed on one device. Open on the rest.
Method
No IDE is confirmed until the PMA is
Practice
The remedial-action call sets the clock
Method
Jurisdiction is a letter, not a field
Practice
An address is not a footprint
Method
The final rule that isn't final yet
Practice
The special controls aren't in the record
Method
Exempt from GMP. Not from complaints.
Practice
The notify list isn't the shortage list
Method
A constraint can't be skipped. A script can.
Practice
No cron sends this. A person does.
Method
Corrected, not rewritten
Practice
Quiet is a finding, not a default
Practice
A competitor's 513(g) leaves no trace
Practice
An empty response field proves nothing
Method
A petition is public. Its outcome isn't.
Practice
The panel is a category, not a meeting
Method
An accessory carries its own classification
Method
A TPLC report is a category, not a device
Practice
A 522 order is a question, not a verdict
Method
A PCCP change leaves no new record
Practice
Not every signal becomes a recall
Method
eSTAR did not remove the acceptance check
Practice
An early alert has no recall number yet
Practice
A consent decree isn't a database row
Method
The record has no cybersecurity field
Practice
Classification Change is not one event
Method
Publication date is not effective date
Method
One event. Many recall numbers.
Practice
Quantity is a sentence, not a number
Practice
How a firm told you is a field too
Method
A RIN outlives the document number
Method
The docket ID is not the comments
Practice
The 510(k) record doesn't name the predicate
Practice
The 510(k) FDA didn't review first
Method
The letter FDA doesn't have to post
Practice
Cleared doesn't say which track it took
Method
The clock stops. The calendar doesn't.
Method
Why a guessed match never reaches you
Practice
The standards list never names a device
Method
The guidance isn't in the Federal Register.
Practice
Filtered. Not discarded.
Method
There are two recall databases, not one
Practice
Breakthrough status is confidential by law
Practice
One MAUDE report is not one malfunction
Method
A supplement number is not a track
Method
Cleared is not approved
Practice
Nationwide doesn't mean your building
Practice
Not every correction reaches FDA
Method
Registered. Not reviewed.
Method
Contact ODE is not a pathway
Practice
Almost no recall is FDA-mandated
Method
FDA's device names read like a card catalog
Practice
openFDA is free. It is not unlimited.
Method
GUDID stores the model. Not the box.
Practice
Detention doesn't need a warning letter
Method
A Class I device, a Class I recall
Practice
21 CFR 820 didn't move. Its contents did.
Method
The product code that doesn't exist yet
Practice
The classification posts. The 483 behind it doesn't.
Method
A recall has three dates, and the pipeline had to pick one
Practice
The count is real. The rate is not.
Method
The firm on the record is not the firm on the box
Practice
Low confidence is an instruction, not a hedge
Method
The same company, spelled three ways
Practice
A device that was never a medical device
Method
FDA's warning letters, addressed by column number
Practice
Your regulation has a decimal. FDA's watch doesn't.
Method
Three letters is too short to search for
Practice
Most warning letters never close
Method
The guidance that skipped the draft
Practice
Ongoing, as of when?
Method
The least interesting fact in a 510(k)
Practice
No recall arrives with a product code attached
Practice
The deadline that doesn't email you
Method
The warning letter has two dates
Method
How to monitor FDA without drowning
Practice
Your predicate was recalled. Now what?
Method
Why no item reaches you without a human