FDA Clarifies Field Action Reports Guidance
Attorney Jennifer Davidson (Kleinfeld, Kaplan & Becker) says an FDA 7/18 draft question-and-answer guidance on field alert report (FAR) submissions clarifies the circumstances under which a FAR should be submitted. FDA regulations says a FAR should be submitted to the agency within three working days of receipt of any of these types of information: situations in which a drug product may be mistaken for another product; bacterial contamination; any significant chemical, physical, or other change or deteriorations in the distributed drug product; and any failure of a distributed batch of the drug product to meet the specifications established in its application.
The clarification of report submission criteria covers each of the categories and notes that a FAR must be submitted even if the sponsor believes the root cause of the quality defect has been identified and corrected, Davidson says. Also, a recall does not obviate the requirement to submit a FAR.
The guidance says that all drug products marketed under an NDA or ANDA are subject to FAR requirements, including those distributed only outside the U.S.