Agency's Classification of ECT Devices Debated

By Mechcatie, Elizabeth | Clinical Psychiatry News, February 2011 | Go to article overview

Agency's Classification of ECT Devices Debated


Mechcatie, Elizabeth, Clinical Psychiatry News


GAITHERSBURG, MD. -- A Food and Drug Administration advisory panel split on whether to recommend that electroconvulsive therapy devices be switched to a less stringent regulatory category when used to treat severe major depressive disorder. But the majority of the panel said that for other indications, ECT machines should be maintained at the level now used to regulate devices deemed as highest risk.

At the end of the 2-day meeting last month, about half of the FDA's Neurological Devices Advisory Panel recommended that electroconvulsive therapy (ECT) devices be switched from a class III category to class II when used to treat severe depression. Class III devices, which have the most stringent regulatory controls, are used for medical devices such as replacement heart valves and silicone gel-filled breast implants. Class II devices, which are classified as "intermediate risk," include x-ray systems, gas analyzers, and surgical drapes. Currently, ECT devices are cleared for use by the FDA for treating severe depression (unipolar and bipolar), schizophrenia, bipolar manic (and mixed) states, schizoaffective disorder, schizophreniform disorder, and catatonia.

Under the Medical Devices Amendments of 1976, class III devices require manufacturers to submit a premarket approval application (PMA), which includes clinical trial data, to provide adequate evidence that the device is safe and effective for its intended use. But because ECT devices were on the market before 1976, they have been exempted from the approval process. Instead, ECT manufacturers have been required to show that the devices are substantially equivalent to a legally marketed device before they are cleared for marketing.

The FDA is in the process of developing regulations that will either reclassify ECT and other devices marketed before the amendments went into effect or keep them in the class III category Keeping them in the class III category would require that the manufacturers submit PMAs for them to remain on the market. Reclassification into the intermediate risk (class II) category for devices would avoid requiring manufacturers to apply for approval but could require "special controls" to mitigate the associated risks of the device to "provide reasonable assurance" of their safety and effectiveness. Such controls could include postmarket surveillance, patient registries, and/or development and dissemination of guidelines, according to the FDA, which held the meeting to get feedback on how ECT devices should be classified for severe depression and the other indications cleared by the agency for treatment with ECT.

The panel supported labeling that would require physicians to monitor a patient's cognitive status as part of the efforts to mitigate risk prior to undergoing ECT and throughout the course of treatment.

Class III or Class II?

Among the reasons cited by panelists supporting the class III category for severe depression were associated memory loss and the lack of long-term data. These panelists included the consumer and patient representatives on the panel, who were concerned about the lack of knowledge about long-term adverse effects associated with ECT Dr. David Good, professor and chair of neurology Pennsylvania State College, Hershey, said that despite responses in the public docket describing ECT as lifesaving, he leaned toward supporting class III status because of the absence of long-term data and evidence showing that ECT is associated with memory loss.

Those supporting a switch to the class II category agreed there was adequate evidence that ECT was effective and advocated the use of special controls to help mitigate the associated risks of ECT. …

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