CDRH Discontinuance, Interruption Notification Explained
A 5/11 CDRH Webinar reviewed the provisions in a 5/6 immediately-in-effect guidance requiring manufacturers of certain medical devices to notify FDA of an interruption or permanent discontinuation in the manufacturing of the specified medical devices during a public health emergency. CDRH Division of All Hazards Response, Science, and Strategic Partnerships deputy director Katie O’Callaghan explained that the Coronavirus Aid Relief and Economic Security Act added a section to the Federal Food, Drug, and Cosmetic Act requiring manufacturers to notify the agency of a permanent discontinuance or interruption in the manufacturing of certain devices, particularly those that are likely to lead to a meaningful disruption of the supply of that devices in the U.S.
According to O’Callaghan, the section applies to manufacturers of devices that are critical to public health during the public health emergency or for which FDA determines information on potentially meaningful supply disruption is needed during the emergency must notify FDA.
The guidance says the medical device manufacturers can determine whether they are required to report by considering whether the device or accessories are life-supporting, life-sustaining, or intended for use in emergency medical care or during surgery, or are used to diagnose, cure, treat, mitigate, or prevent Covid-19, or would be in higher-than-typical demand during the response to the pandemic compared to a similar period.
The Webinar explained additional nuances in the determination of who is required to report as well as questions about when notifications must be made and what information is to be reported.