The term "
humanitarian exemption" was read in a couple of places, ISSLS journal abstract(s), again recently the 2008 NASS abstracts specifically regarding multi-level ADR , TDR TDA ( two (2) or more levels ). I am a layperson, not a medical professional, regulatory lawyer, blah blah ...
"Humanitarian exemption" may be defined in one of the documents below. More reading required. Excerpts from a an existing humanitarian exemption (Stryker Biotech OP-1) document follows
LINK:
"As defined in the Federal Food, Drug,
and Cosmetic Act (21 CFR 814.124), the definition
of a Humanitarian Use Device (HUD) is a device
that is intended to benefit patients in the
treatment and diagnosis of diseases or conditions
that affect or is manifested in fewer than 4,000
individuals in the United States per year. "
FDA developed and published the Safe Medical Devices Act
on June 26, 1996 to provide an incentive that would
encourage innovative manufacturers, ... DEL.TEXT
development of devices that would benefit only a
small patient population each year. "
Started with FDA, CBER (
Center for Biologics Evaluation and Research) looking for OP-1, rhBMP-7 reference to Intervertebral Disc, DegDiscDisease and
www.clinicaltrials.gov . I worked backwards(?).
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slackwater_sf
mva, 2-level lumbar surgical candidate