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Continuous Regulatory Intelligence • Substantial Equivalence Automation

Move from Reactive Dossier Authoring to Living Regulatory Intelligence

Regulatory affairs shouldn't be the final bottleneck in commercialization. PMX OS continuously tracks design deltas, maps predicate technological characteristics, and executes deterministic 510(k) and EU MDR change decision trees in real time.

The Regulatory Dilemma

The Static Document Trap

Regulatory Affairs teams are tasked with maintaining compliance against rapidly changing global laws (EU MDR, FDA Cybersecurity Refuse-to-Accept, Health Canada SaMD guidance) while working with fragmented engineering files.

Traditional RA operations assemble 1,500-page submission binders manually. When an engineer alters an adhesive resin or firmware telemetry loop, RA rarely finds out until formal design freeze—triggering an exhausting manual gap analysis and delaying product releases by quarters.

The Core Need:

A system that evaluates engineering changes as they occur, providing algorithmic certainty on whether an update requires an FDA 510(k), an EU MDR Significant Change notification, or an auditable Letter to File.

Algorithmic Change Determination

1
Intended Use & Indications

Does the engineering change modify clinical patient population or primary anatomical indications?

2
Technological Characteristics

Does the modification introduce a new operating principle, power source, or software architecture?

3
Performance & Safety Boundary

Do verification tests confirm that modified components remain strictly within baseline safety tolerances?

Guidance Basis: FDA CDRH 2017-02 Automated Graph Evaluation
Predicate Intelligence

Substantial Equivalence Engineered as a Graph

PMX OS decomposes primary and reference predicate devices into structured technological parameters, giving RA teams instant comparison clarity.

Technological Parameter Primary Predicate (K182901) Subject Device: CardioSense Pro v3.8.2 Algorithmic Equivalence Status
Clinical Intended Use Continuous outpatient ECG & telemetry monitoring Continuous outpatient ECG & physiological telemetry Identical
Electrode Interface 3-lead hydrogel adhesive patch 3-lead dry conductive silicone composite Equivalent (ISO 10993 Passed)
Surface Thermal Limit IEC 60601-1-11 ≤ 41.0°C IEC 60601-1-11 ≤ 41.0°C (Transducer S-22) Equivalent (REQ-0184)
Arrhythmia Analysis Static heuristic rhythm detector 1D CNN (PCCP Protocol 3 Bound) PCCP Governed (K221840)
Case In Point

CardioSense Pro: The Letter-to-File Determination for CHG-1024

How the PMX Regulatory Engine resolved transducer replacement without an unnecessary 90-day FDA review.

The Proposed Design Change

Substituting Thermistor S-18 with S-22

When engineering submitted CHG-1024, the regulatory specialist was asked whether substituting transducer S-18 altered device clearance under K221840.

In a manual review, RA would have to comb through the original 510(k) summary, compare data sheets, and schedule meetings with biomedical engineers. With PMX OS, the decision tree runs instantaneously.

Automated Regulatory Justification

Defensible Audit Package Generated

• FDA Decision Tree Question B1: Does the change affect indications? → NO
• FDA Decision Tree Question B2: Does it alter operating principle? → NO
• FDA Decision Tree Question B5: Could it adversely affect clinical performance? → Yes, if thermal limits fail
• Verification Link: Test protocol V-0183 confirms dissipation ≤ 40.2°C (< 41.0°C threshold)
• Result: Documented Letter-to-File approved. Zero filing delay.
Multi-Country Harmony

Single Change, Global Regulatory View

Review filing consequences simultaneously across all target markets from a single unified cockpit.

US FDA CDRH

Letter to File vs. Special 510(k) vs. Traditional 510(k) decision logic with automated reference to Section 510(k) summary tables and risk management files.

EU MDR (Article 120 / 61)

Significant vs. Non-Significant change evaluation per MDCG 2020-3, ensuring CE mark certificate validity and automatic GSPR checklist synchronization.

PMDA & Health Canada

Annual notification mapping and minor modification filing exports, eliminating translation disconnects between domestic and international affiliates.

Transform Regulatory Operations

Equip Your RA Team with Predictive Intelligence

Stop spending weeks writing static comparison matrices. Schedule a personalized walkthrough of the PMX Regulatory Engine.