Combo Compliance Manual Includes Streamlined Approach

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Six Hogan Lovells attorneys say the 6/4 FDA update to the Compliance Program Guidance Manual (CPGM) includes a program for inspecting CDER-led and CDRH-led combination products. In an online post, the attorneys write that the updated manual says it “focuses on inspections of combination product manufacturers of CDER or CDRH-led single-entity and co-packaged finished combination products that include both drug and device or biological product and device constituent parts” and is intended to clarify or explain the application of current good manufacturing practice (cGMP) requirements to combination products laid out in a 1/2017 final guidance, including the application of the “streamlined approach” to cGMP compliance outlined in the final guidance.

Because most combination product manufacturers have adopted a streamlined approach to demonstrating cGMP compliance, the attorneys write, the manual focuses on providing instructions to FDA personnel on assessing compliance with the streamlined approach to cGMP compliance. The manual notes that it does not cover inspections for combination products for which CBER is the lead Center, and does not apply to facilities that make either only one type of the constituent part of a combination product or only components of constituent parts.

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