‘Exceedingly Burdensome’: PhRMA to FDA on Reporting Guide

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An FDA draft guidance on reporting the amount of listed drugs and biological products under section 510(j)(3) of the Federal Food, Drug, and Cosmetic Act would be “exceedingly burdensome,” Pharmaceutical Research and Manufacturers of America tells the agency in a comment letter.  It notes that drug company data collection practices vary from product to product and company to company, and because of this variability in manufacturers’ data collection practices, “it is anticipated that implementing the 510(j)(3) reporting requirements will be exceedingly burdensome, particularly for complex supply chains. Therefore, to ensure that FDA and manufacturer resources are focused on those issues most critical to public health, PhRMA encourages FDA to take a phased approach to the implementation of these reporting requirements, to describe how the agency intends to use the reported data to mitigate against drug shortages, and to focus the agency’s limited resources on the optimization of existing quality oversight tools and initiatives that will have the greatest impact in enabling FDA and manufacturers to prevent and mitigate drug shortages.”

The letter also makes specific recommendations for changes.

Additional specific comments were provided by the Biotechnology Innovation Organization and Pfizer.

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