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Yeah, I'm on the small molecule side but did a combo device years ago and was shocked at how slack the device rules were compared to the drug side.

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Agreed. Class III hardware is well controlled (i.e., implants), but software (any class) and lower-class hardware is loco. My device was Class II.

This change would have certainly increased overall risk so a new 510(k) would have been required if this device was already commercialized.

And had your management not backed down, and tried to push this through as a Letter to File, you'd have been well-within your rights to blow the whistle to FDA. There's not a FDA employee alive that wouldn't go "hold on there chief" to a device change of this magnitude.

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