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Judgment & ambiguity · Calibrating confidence

A design change to a cleared device could be handled as a letter-to-file or could require a new 510(k) — the 'could this significantly affect safety or effectiveness' judgment is genuinely borderline. How sure are you, and how do you make the call defensible?

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On a borderline significance determination, my honest confidence is moderate, not high, and pretending otherwise is the failure mode — so I make the decision defensible rather than certain.

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