FDA EDDO Control Strategy Guidance Analyzed
A Journal of Regulatory Affairs article written by staff from FDA and several drug companies analyzes an agency 2024 draft guidance on essential drug delivery outputs (EDDO) for devices intended to deliver drug and biological products, focusing on risk-based control strategies, effective submission strategies, and when to engage with FDA. The article highlights regulatory expectations for EDDO upstream controls, discusses implementation challenges, and provides insights on practical approaches for robust submissions, including integrating prior knowledge, risk assessments, submission strategies, and global trends.
“The draft guidance provides a structured submission approach grounded in design control and International Council for Harmonization (ICH) principles,” it concludes, “guiding industry in developing and presenting robust control strategies to ultimately ensure patient safety…. Effective communication of holistic control strategies, including rationale and location within regulatory submissions, remains essential for health authority engagement. FDA encourages data-driven discussions and supports alignment on control strategies at key milestones, such as pre-BLA/NDA meetings, particularly for novel device designs or complex EDDOs. As the industry continues to adapt EDDO control strategy concepts, FDA is committed to clarifying expectations and ensuring alignment with ICH guidelines. Many of the considerations discussed are broadly applicable not only to EDDO but also to other device functional attributes, as the underlying principles remain consistent.”