Medical device biocompatibility · ISO 10993 · 510(k)
Independent, board-certified toxicology strategy for 510(k) and IND device programs. Find what's missing in your biological evaluation in four to six weeks — before a reviewer does, or before you pay for testing you didn't need.
Is this you right now?
If you're at one of these points on a device program, a few weeks of focused strategy now is worth months on the back end.
FDA flagged biocompatibility or toxicology in your 510(k) and the clock is running on your response. You need a defensible answer, not a scramble.
You want to know your ISO 10993 biological evaluation will hold up before it's in front of a reviewer — and where a gap could trigger an Additional Information request.
Early enough that the right call now avoids building a regulatory problem into the device — and avoids a testing bill you can't unspend later.
The engagement
One board-certified toxicologist, four to six weeks, from risk framing to a decision-ready package. No handoffs, no over-testing — just the evidence that moves your submission forward.
4–6 week sprint
Map the pathway, contact category, and the questions a reviewer will actually ask. Surface the gaps now.
Decide what to test, what to characterize, and what existing data and predicates already cover.
Roadmap, risk register, and a toxicological risk assessment narrative you can put straight into the pre-submission.
Most programs start with a scoped review call before committing — so you know exactly what the Sprint will cover.
Why not just send it to a lab
The person who frames the risk writes the conclusion. No relay between a sales rep, a project manager, and a reviewer you never speak to.
Under the current ISO 10993-17 and -18 approach, chemical characterization and a sound toxicological risk assessment can replace animal studies a testing house would simply run and bill.
Actionable direction in four to six weeks — before your team commits months of spend to the wrong evidence plan.
Case study
The 510(k) was stalled by an unresolved biocompatibility question, with a broad — and costly — re-testing plan on the table.
Rebuilt a targeted safety-testing plan and defined a practical regulatory roadmap focused only on evidence relevant to clearance.
Avoided unnecessary testing and re-manufacturing, and positioned the program for clearance — [52 weeks saved / $0.5M avoided].
Common questions
The questions founders and device teams ask most before committing to a testing plan.
It depends on the nature and duration of your device's contact with the body, not on a fixed checklist. FDA's modified matrix maps each contact category and contact duration to the biocompatibility endpoints to consider, and many of those endpoints can be addressed with existing data, chemical characterization, or a documented rationale rather than new testing.
In many cases, yes. Under ISO 10993-18 chemical characterization combined with an ISO 10993-17 toxicological risk assessment, extractables and leachables data can address endpoints such as genotoxicity, carcinogenicity and systemic toxicity without running the corresponding animal studies — consistent with the 3Rs and FDA's current biocompatibility guidance.
A focused strategy and gap analysis can be completed in weeks, but physical testing varies widely — short assays take weeks while implantation or chronic studies can take several months. Defining the right evidence plan up front is what avoids committing to long-lead studies you may not need.
It is FDA's adaptation of the ISO 10993-1 endpoint table, presented in the 2023 guidance. It uses the same contact-type and contact-duration framework as ISO 10993-1 but adds endpoints FDA recommends for consideration, and it functions as a framework for selecting endpoints rather than a mandatory testing checklist.
Not always, but a change to formulation, resin supplier, processing, or sterilization can alter biocompatibility and should be evaluated. Documented equivalence and comparative chemical characterization can often justify leveraging prior data instead of repeating the full test battery.
A Biological Evaluation Plan is a risk-based document that maps your device's contact type and duration to the relevant biocompatibility endpoints and identifies what existing data already covers versus the gaps that remain. It is the foundation of an ISO 10993-1 evaluation and drives whether testing, characterization, or rationale is needed for each endpoint.
Start with a scoped review of where your device stands. If the Sprint is the right fit, you'll know exactly what it covers before you commit.
