Pre-EUA submissions or amendments

Ventilator, Ventilator Tubing Connectors, and Ventilator Accessories
Pre-Emergency Use Authorization (EUA)/EUA
Interactive Review Template
This interactive review template (the “template”) was designed to capture the data/information
needed by FDA to support inclusion of an eligible product under the Ventilator, Ventilator
Tubing Connectors, and Ventilator Accessories EUA (the “Ventilator EUA” or “EUA”), as set
forth in the EUA. This template is intended to help companies provide the information to FDA,
but alternative approaches can be used. For more information about EUAs in general, please see
the FDA Guidance document: Emergency Use Authorization of Medical Products and Related
Authorities. For more information on the Ventilator EUA, see the Ventilator section of the
COVID-19 EUA website. Once completed, please send this interactive review memo to CDRHCOVID19-Ventilators@fda.hhs.gov.
GENERAL INFORMATION ABOUT THIS TEMPLATE
•

Text highlighted in yellow [text] should be completed by the medical device product
developer (sponsor) as applicable to its specific device. If any of the sections are not
applicable, please indicate such and provide an explanation (if one is necessary).

•

This is a template for Pre-EUA/EUA submissions and not a guidance document. It includes
the information that should be included in such submissions, as outlined in the Emergency
Use Authorization of Medical Products and Related Authorities Guidance document as well
as the Ventilator EUA. This Template is subject to change including because of revisions to
the Ventilator EUA as we learn more about COVID-19 generally and these devices’ riskbenefit profiles.

•

Any proprietary information provided within the template and during the interactive review
process will remain confidential.

•

Feedback provided by FDA during the interactive review of a pre-EUA/EUA submission is
subject to change as FDA gains experience during an emergency, as FDA learns more about
the disease/condition this device addresses, and as the device’s risk-benefit profile may
evolve to address the unmet public health need.

•

Please remember that if your product is added to this specific EUA, the authorization would
be only for the use specified in the EUA and subject to the conditions in the EUA. This
device must not be introduced into interstate commerce for uses outside the authorized use
without obtaining marketing clearance, approval, an approved IDE, or another EUA by the
FDA.

Page 2
•

If added to this specific EUA, the product would be authorized for use until the declaration of
public health emergency is terminated, the EUA is revoked by the FDA or the product is
removed from the EUA.

•

The EUA is not a pathway to permanent marketing of your device. For information on
premarket submissions, please refer to FDA’s website on “How to Study and Market Your
Device” at https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatoryassistance/how-study-and-market-your-device. For information on FDA’s enforcement
policy for ventilators, see FDA guidance Enforcement Policy for Ventilators and Accessories
and Other Respiratory Devices During the Coronavirus Disease 2019 (COVID-19) Public
Health Emergency. For guidance on modifications that trigger the requirement that a
manufacturer submit a new premarket notification (510(k)) to FDA, refer to FDA guidance
Deciding When to Submit a 510(k) for a Change to an Existing Device.

Page 3
Pre-EUA/EUA INTERACTIVE REVIEW TEMPLATE
for Ventilator, Ventilator Tubing Connectors, and Ventilator Accessories
A.

Basic Information
1. Purpose of Submission
Request for the addition of the [include device name] device to the Ventilator EUA.
2. Applicant
Include the following applicant information:
Contact name/phone/address/email:
Contact information for a U.S. agent:
Manufacturer name/address:
3. Device proprietary or brand name, model number:
4. Indication for use:
5. Regulatory information (Approval/Clearance status in US):
[Please indicate whether the device is legally marketed in the US. If applicable, please
include a description of any modifications made to the legally marketed device.]
6. Marketing authorizations in any other country:
[Please indicate whether the device currently has marketing authorization in another
regulatory jurisdiction, such as the European CE Mark, Australian Register of
Therapeutic Goods (ARTG) Certificate of Inclusion, Health Canada License, or Japan
Pharmaceuticals and Medical Device (PMDA) approval (including certification number,
if available).]
7.

Unmet Need
The Ventilator Emergency Use Authorization (EUA) was issued in response to concerns
relating to insufficient supply and availability of FDA-cleared ventilators for use in
healthcare settings to treat patients during the Coronavirus Disease 2019 (COVID-19)
pandemic.

B.

EUA Section II Information

Page 4

As stated in the EUA, the information below should be provided to ensure the criteria
described in Section II of the EUA have been met.
1. Product Labeling
Please provide a copy of the product labeling, including the instructions for use.
2. Applicable Standards
Please indicate whether the device has been designed, evaluated, and validated in
accordance with the applicable FDA-recognized standards identified in Appendix A of
the EUA.
3. Quality System
Please indicate whether the device is manufactured in compliance with 21 CFR Part 820
or ISO 13485: Medical Devices – Quality Management Systems – Requirements for
Regulatory Purposes, or an equivalent quality system, and the manufacturer or importer
has documentation of such.
4. Other Quality Management Standards
Please indicate whether the device is manufactured in compliance with other
internationally recognized quality management systems.
5. Power Supply
Please indicate whether the device is designed with a power supply that is compatible
with United States voltage, frequency, and plug type standards or is accompanied by an
appropriate power supply adapter for use in the United States.
6. Authorized Labeling
Authorized products must be accompanied by the following information pertaining to the
emergency use (also described in Appendix A of the EUA) which are authorized to be
made available to healthcare providers and patients:
•
•

Fact Sheet for Healthcare Providers: Emergency Use of Ventilators During the
COVID-19 Pandemic
Fact Sheet for Patients: Emergency Use of Ventilators During the COVID-19
Pandemic

The sponsor’s developed instructions for use and the two fact sheets are referred to in the
EUA as “authorized labeling.”

Page 5
Please confirm that the product will be accompanied by the Fact Sheets identified above
and labeling/instructions for use.
C.

EUA Section IV Conditions of Authorization
Please provide a written confirmation that you will be meeting the conditions for sponsors
set forth in Section IV of the Ventilator EUA.

D.

Criteria for Safety, Performance and Labeling (from Appendix A of the EUA)
To be authorized and added to Appendix B of the Ventilator EUA, the product must be
determined to meet the applicable criteria for safety, performance and labeling set forth in
Appendix A of the EUA and outlined below.
1. Declarations of Conformity
Please provide declarations of conformance with the following standards as applicable. In
addition, please provide an explanation of how conformance to the standards identified
adequately ensures the safety and performance of the device:
•
•
•

•
•
•
•
•
•
•

IEC 60601-1: 2012: Medical Electrical Equipment – Part 1: General Requirements
for Basic Safety and Essential Performance
IEC 60601-1-2: 2014: Medical Electrical Equipment Part 1-2: General Requirements
for Basic Safety and Essential Performance – Collateral Standard: Electromagnetic
Disturbances – Requirements and Tests
IEC 60601-1-11: 2015: Medical Electrical Equipment Part 1-11: General
Requirements for Basic Safety and Essential Performance – Collateral Standard:
Requirements for Medical Electrical Equipment and Medical Electrical Systems Used
in the Home Healthcare Environment
Any other applicable collateral/particular standards in the IEC 60601-1: 2012 family
IEC 62304: 2015: Medical Device Software – Software Life Cycle Processes
AAMI TIR69: 2017: Technical Information Report Risk Management of RadioFrequency Wireless Coexistence for Medical Devices and Systems
ANSI/IEEE C63.27: 2017: American National Standard for Evaluation of Wireless
Coexistence
AAMI TIR69: 2017: Technical Information Report Risk Management of RadioFrequency Wireless Coexistence for Medical Devices and Systems
ISO 10993: Fifth Edition 2018-08: Biological Evaluation of Medical Devices - Part 1:
Evaluation and Testing Within a Risk Management Process
ISO 18562-1 First Edition 2017-03: Biocompatibility Evaluation of Breathing Gas
Pathways in Healthcare Applications - Part 1: Evaluation and Testing Within a Risk
Management Process

Page 6
•
•
•
•
•
•
•
•
•
•
•
•

ISO 18562-2 First Edition 2017-03: Biocompatibility Evaluation of Breathing Gas
Pathways in Healthcare Applications - Part 2: Tests for Emissions of Particulate
Matter
ISO 18562-3 First Edition 2017: Biocompatibility Evaluation of Breathing Gas
Pathways in Healthcare Applications - Part 3: Tests for Emissions of Volatile
Organic Compounds
ISO 18562-4 First Edition 2017-03: Biocompatibility Evaluation of Breathing Gas
Pathways in Healthcare Applications - Part 4: Tests for Leachables in Condensate
ISO 10651-5 First Edition 2006-02-01: Lung Ventilators for Medical Use - Particular
Requirements for Basic Safety and Essential Performance - Part 5: Gas-Powered
Emergency Resuscitators
ISO 17510 First Edition 2015-08-01: Medical devices -- Sleep apnoea breathing
therapy -- Masks and application accessories
ISO 80601-2-12 First Edition 2011-04-15: Medical Electrical Equipment - Part 2-12:
Particular Requirements for the Safety of Lung Ventilators - Critical Care Ventilators
[Including: Technical Corrigendum 1 (2011)]
ISO 80601-2-13 First Edition 2011-08-11: Medical Electrical Equipment -- Part 213: Particular Requirements for Basic Safety and Essential Performance of an
Anaesthetic Workstation [Including: Amendment 1 (2015) and Amendment 2 (2018)]
ISO 80601-2-69 First Edition 2014-07-15: Medical Electrical Equipment - Part 2-69:
Particular Requirements for Basic Safety and Essential Performance of Oxygen
Concentrator Equipment
ISO 80601-2-70 First Edition 2015-01-15: Medical Electrical Equipment - Part 2-70:
Particular Requirements for Basic Safety and Essential Performance of Sleep Apnoea
Breathing Therapy Equipment
ISO 80601-2-74 First Edition 2017-05: Medical Electrical Equipment - Part 2-74:
Particular Requirements for Basic Safety and Essential Performance of Respiratory
Humidifying Equipment
ISO 80601-2-79 First Edition 2018-07: Medical electrical equipment - Part 2-79:
Particular Requirements for Basic Safety and Essential Performance of Ventilatory
Support Equipment for Ventilatory Impairment
ISO 80601-2-80 First Edition 2018-07: Medical Electrical Equipment - Part 2-80:
Particular Requirements for Basic Safety and Essential Performance of Ventilatory
Support Equipment for Ventilatory Insufficiency

2. Device Specifications and Instructions for Ventilators and Accessories
Please provide the following specification information for your device, as well as any
other relevant device specification information that may not be covered by the items
below.
For devices for delivering ventilatory support, sponsors should provide specific
information and instructions regarding the device’s:

Page 7
•
•

•
•

Available ventilation modes, patient interfaces, ventilatory parameter ranges (e.g.,
maximum inspiratory pressure, positive end-expiratory pressure, respiration rate,
flow, delivered tidal volume, triggering, etc.)
Battery specifications (if applicable), including runtime, how users are notified of
device battery status (e.g., alarms), and expected use life that is supported by testing.
For devices with external or replaceable internal batteries, the sponsor should provide
information regarding chemistry, including information regarding design, capacity,
and software and/or hardware risk mitigations for overcharging, alarms, and
information regarding conformance to applicable standards (e.g., IEC62311 for
rechargeable batteries or IEC 60086-4 for non-rechargeable batteries for lithium-ion
technology)
Alarm functionality, including a listing of all alarm conditions and the associated
default settings and limits
Sensors and monitored parameters (including device parameters or patient
parameters, as applicable)

For ventilator accessories please provide specific information and instructions (as
applicable), regarding the device’s:
•
•

Connection dimensional characteristics (i.e., per ISO 5356-1) types (e.g. single limb
with active exhalation, dual limb)
Compensating control

3. Reprocessing and Shelf-life Information
Please provide the following information and instructions regarding device reprocessing:
•

Instructions on how to reprocess reusable accessories, including filters and sensors

•

A list of all components—both internal and external to the ventilator—that can
contact patient-expired gases or may become contaminated with patient bodily fluids.
Such components may include, but are not limited to: the expiratory module, flow
sensors, pressure sensors, humidifier, patient circuit, carbon dioxide module sensor.
The list should specify whether the device components are intended for single use or
are reusable. This applies to both patient-contacting components, as well as
components that may otherwise come in contact or be contaminated with patientexpired gases or bodily fluids

•

Information regarding device shelf-life

4. Facility Requirements (as applicable)
As applicable, please provide the following information and instructions regarding the
gas input and gas source of the device manufacturing facility:
•

Gas input connection type (e.g., Diameter Index Safety System (DISS), NIST)

Page 8
•
•
•

Gas type (e.g., air, oxygen), including information regarding input pressures and
flow rates
Gas source (e.g., internal blower, wall-source)
Environmental controls to reduce transmission (e.g., negative pressure)

5. Labeling Requirements for Conditions of Use
Please confirm that the device’s labeling includes the device’s specifications (including
ventilatory parameters), information regarding alarms (e.g., disconnect, EtCO2 alarms,
etc.), device reprocessing instructions, and other instructions described above as
applicable.
6. Continuous Ventilator Splitters (Adapters for Multiplexing)
a. Engineering and Manufacturing Considerations:
Please provide the engineering and manufacturing considerations for a ventilator
circuit adapter for multiplexing certain continuous ventilators intended for use in a
healthcare facility (21 CFR 868.5895 and product code CBK (ventilator, continuous,
facility use)) are set forth below.
These safety and performance considerations highlight the technical application of
creating and testing this type of component and are not intended to be inclusive of all
considerations. Please provide a description or discussion demonstrating an
assessment of these considerations.
1) Material properties and high polymeric crosslinking/conversion
2) Material strength and durability
3) Gas pathway biocompatibility
a. Dry gas validation would include:
i. Testing for volatile organic compounds
ii. Particulate matter sampling
4) Leak tests on finished product
5) Design for use of disconnect alarms that are on multiple circuit paths
6) Compliance with guidelines regarding standard for ventilator circuitry
a. ISO 5356-1 Third edition 2004-05-15 Anaesthetic and respiratory
equipment - Conical connectors: Part 1: Cones and sockets
b. ISO 5366 First edition 2016-10-01 Anaesthetic and respiratory
equipment - Tracheostomy tubes and connectors
c. ISO 18190 First edition 2016-11-01 Anaesthetic and respiratory
equipment - General requirements for airways and related equipment
d. ISO 18562-1 First Edition 2017-03: Biocompatibility Evaluation of
Breathing Gas Pathways in Healthcare Applications - Part 1:
Evaluation and Testing Within a Risk Management Process

Page 9
e. ISO 18562-2 First Edition 2017-03: Biocompatibility Evaluation of
Breathing Gas Pathways in Healthcare Applications - Part 2: Tests for
Emissions of Particulate Matter
f. ISO 18562-3 First Edition 2017: Biocompatibility Evaluation of
Breathing Gas Pathways in Healthcare Applications - Part 3: Tests for
Emissions of Volatile Organic Compounds
7) Appropriate labeling providing instructions for use and cautionary statements
regarding the device use and recommended monitoring activities
b. Labeling Considerations:
Please confirm that the product labeling conveys the following information:
1) A single ventilator fitted with the Vent Splitter can be used for multiple patients
for ventilatory support during the COVID-19 pandemic when individual
ventilators are not available or preemptively to increase the potential of single-use
ventilators permitting mechanical ventilation for multiple patients simultaneously;
2) A description of the recommended use options/configuration (e.g. 2 splitters that
can provide 2 ventilatory circuits (2 patients), 4 splitters that can provide 3
ventilatory circuits (3 patients) or 6 splitters that can provide 4 ventilatory circuits
(4 patients); recommendations regarding the need for extra long tubing if needed
to position patients in a manner that allows access to the patients and the
ventilator; recommendations regarding free gas flow (FGF) requirements for
oxygen when the ventilator used for multiple patients.
3) The pressure control mode is recommended when more than one circuit is added
to the ventilator
4) The single ventilator fitted with the Vent Splitters will provide each patient with
the same level of pressure support, the same rate of respiration, the same
inspiratory/expiratory ratio, the same FiO2, the same level of PEEP, etc.
5) Because the single ventilator provides similar ventilatory support to all patients, it
is important to size match patients
6) Cautionary statement regarding the need for paralysis and sedation, and the need
for additional infusion pumps to administer these agents, to avoid dyssynchronous
breathing and system alarming from bucking and coughing;
7) Cautionary statement regarding the need for additional infusions pumps
8) Because the single ventilator provides similar ventilatory support to all patients, it
is also important to select, to the extent possible, patients with similar underlying
lung physiology, lung compliance, and ventilatory requirements, so that one
system can generally meet each patient’s needs, as they await individualized
ventilators;
9) A description of recommended approach to patient monitoring, e.g. each patient

Page 10
should be assessed frequently clinically, at a minimum of 15-30 minute intervals,
including vital signs, oxygen saturation level, end tidal Co2, examinations of the
chest for bilateral air movement, and, if indicated, assessments of arterial blood
gas findings to assure clinical stability on the shared system; close monitoring of
all patients will be critical since they will likely be paralyzed and sedated.
10) If the shared ventilator alarms for any reason, clinical assessments of each patient
are indicated immediately in order to determine which patient is triggering the
alarm. The ventilator cannot indicate which patient is triggering the
alarm. Providers need to assess all patients, consider suctioning and proper tube
placement, and disconnect any unstable patient, considering mechanical bagging
if necessary;
11) Potential infectious complications from sharing one ventilator have not been
studied, and therefore caution is advised. If patients share the same infection, the
single ventilator for multiple patients is a viable short-term management
option. Each patient’s is individualized with in-line filters designed to filter out
viruses and/or bacteria and to protect the ventilator from contamination.
E.

Benefit/Risk Assessment
This is a key section of the EUA Interactive Review Template that outlines the risk
benefit analysis. The section should be filled out by the sponsor based on the risk-benefit
analysis for the product.

F.

FDA Summary of Documentation and Review [for FDA Internal Use Only]
FDA reviewers will include a brief summary of the documentation provided and their
conclusion of whether the product meets the criteria and conditions identified in Sections
II, IV, and Appendix A of the EUA.

G.

Date
[X]

Interaction Review Log
Please use the table below to document interactive review with FDA, include interactions
initiated by either FDA or the sponsor.
Type of Interaction
(phone/ email/ formal
submission-DCC)
[X]

Brief Description (e.g., questions asked/ feedback from
FDA received / any word documents included)
[X]

Page 11

H.

Next Steps
Once FDA review is completed, if the eligible product has been confirmed to meet the
safety, performance, and labeling criteria in Appendix A of the EUA, then you will
receive an email notification with that information and your product will be added to
Appendix B of the Ventilator EUA. If the product is not eligible for addition to or fails to
meet the safety, performance or labeling criteria in Appendix A of the EUA, then you
will be receive an email notification with that information. Please note that, as set forth
in FDA’s guidance Emergency Use Authorization of Medical Products and Related
Authorities, FDA intends to prioritize its review of EUA requests during a declared
emergency based on various factors, including the extent to which the product would
serve a significant unmet medical need.