Comments on Liquid Drug Flow Restrictor Guidance

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The Consumer Healthcare Products Association (CHPA) says an FDA draft guidance on flow restrictors for oral liquid drug products “reflects recommendations by the agency for which CHPA members are supportive for the most part.” The association’s comment letter includes input on the Directions for Use section of the guidance and general recommendations.

In its response, Johnson & Johnson says it has partnered with CHPA through its review and commenting process and supports the comments that association submitted. However, the company also provides its comments about the scope of the guidance, alignment with other regulations, toxicology assessment, use of graphical images on labeling insert, and data for labeling comprehension. It also included specific line-by-line comments.

The Combination Products Coalition asks that FDA further clarify the designation of restricted delivery systems, including whether they are considered to be medical devices. It also wants the draft guidance to include considerations and recommendations for using restricted delivery systems, but not give requirements for their use since guidances do not establish legally enforceable responsibilities.

Novartis provided line-by-line specific comments.

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