Comments on FDA Guidance Best Practices

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The Parenteral Drug Association (PDA) says an FDA “Draft Report and Plan on Best Practices for Guidance” does not provide an overview and metrics on the initiatives in an agency 2011 good guidance practices report. PDA says it suggests that FDA include a section in the draft report with the missing information or publish the data on the agency Web site.

The AdvaMed comment letter raises these issues:

  • expanded use of guidances without advance opportunity for comment could undermine good policymaking;
  • FDA should take steps to facilitate the public’s understanding of the evolution of specific guidances;
  • FDA should enhance transparency surrounding guidance development;
  • support for non-binding use of templates, when appropriate, and other non-traditional ways to disseminate information; and
  • FDA should address and clarify instances in which guidance contains binding aspects.

In its letter, the Association for Accessible Medicines (AAM) says it strongly supports FDA efforts to issue timely and informative guidance that assists the regulated industry in complying with regulatory requirements. While the draft report says the number of guidances issued by the agency has increased significantly in the past 20 years, the AAM urges a focus on guidance quality rather than quantity and says FDA should ensure that published guidance continue to reflect its current thinking. “The focus on publishing new material often means draft guidances remain in draft status for extended periods,” it says. “This creates uncertainty about whether the draft guidance continues to reflect the agency’s current policy, even apart from the fact that draft guidance is not supposed to be implemented before it is final.”

Finally, Pharmaceutical Research and Manufacturers of America says it commends FDA for its “longstanding commitment to and leadership in providing guidance to interested stakeholders, and to promoting transparency, predictability, and efficiency through good guidance practices.” It identifies several areas where it believes the agency could improve its practices related to developing and issuing guidances.

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