Bill Anderson <[EMAIL PROTECTED]> wrote in part:

>But wait, there's more! The FDA deals with more than drugs. Any and all
>"Devices" count too. Here's an example. Cloth feminine pads are under
>the regulation of the FDA. If your wife, for example, wants to make them
>fr herself, the FDA has no say. But try to sell them and you get
>regulated. You can sell a kit that people have to actually assemble
>themselves, and be good to go.

No, not even then; see below.

> But assemble it yourself and blammo.
>Extensive testing is now required. Your materials, your supplies, your
>environment, the whole thing.

If the kit you sell is INTENDED for people to assemble into a medical
device, then it too is a medical device, for components of medical devices
(i.e. intended by the purveyor to make up parts of such devices) are
themselves medical devices.

I used to work in medical device R&D, so I know.

In Your Sly Tribe,
Robert in the Bronx
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