Comments on Voluntary Recall Guidance

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The Healthcare Distribution Alliance says it commends FDA for issuing a draft guidance on initiating voluntary recalls and the clarity and assistance it offers to recalling firms and their trading partners. It also says the draft is not aligned with Drug Supply Chain Security Act requirements and explains its detailed concerns.

The Center for Science in the Public Interest says the draft could be improved by clearly outlining the steps required for communications between a recalling firm and a retail consignee. The focus of its comments is on foods.

AdvaMed comments that the draft “provides a good overview of what a firm should consider when developing its recall processes and procedures.” The medical device trade group says FDA should determine that the definition used in the draft guidance applies for the purposes of Part 806 requirements for medical device recalls.

The International Society for Pharmaceutical Engineering says the guidance should be revised to   provide context that a firm may need to interact with the agency to prepare its recall strategy before making external communications, such as public warnings. And it says the guidance should also be revised to address the possibility that a firm may need to interact with the FDA Office of Compliance or Division of Drug Shortage while it is developing its recall strategy for correction or removal of a life-saving or life-supporting medical product.

Finally, Apotex provided line-by-line technical comments.

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