CDER Naloxone Model Drug Facts Label
In a move to increase access to naloxone, perhaps even through regulatory approval of over-the-counter sales, CDER staff developed a model drug facts label for such sales to determine whether consumers understood the key statements for safe and effective use. Writing in a New England Journal of Medicine special article, the staff reports that consumers sufficiently understood six of the eight instruction components in the label and came close on the other two. “Overall, FDA found that the model label was adequate for use in the development of a naloxone product intended for over-the-counter sales,” the article says.
The agency says its decision to develop a model drug facts label and to conduct a study to assess consumer comprehension represents a considerable departure from the typical drug development process in which the sponsor conducts all testing and comes to FDA for approval.
“This label performed well in facilitating understanding of the important steps needed in evaluating a person who appears to have overdosed and in administering naloxone,” the article concludes. “The success of this label-comprehension study has enabled much of the work needed to secure the over-the-counter availability of naloxone and will be key to leveraging over-the-counter product development as a possible means to increasing access to a life-saving drug. We encourage industry sponsors to use this model label to accelerate development initiatives that will ultimately allow for wider access to naloxone.”