Guidance on Advisory Committee Member ‘Appearance’ Issues
FDA has released a draft guidance on “Procedures for Evaluating Appearance Issues and Granting Authorizations for Participation in FDA Advisory Committees” that addresses the process for evaluating whether an advisory committee member has potentially disqualifying non-financial interests or relationships. It also describes FDA’s process for determining whether to authorize a member with an appearance issue to participate in an advisory committee meeting. In addition, FDA is seeking comments on whether the agency should ask members with appearance issues who are authorized to participate in an advisory committee meeting to voluntarily publicly disclose their authorization.
Under the current process, Form FDA 3410, Confidential Financial Disclosure Report, is to be completed by potential committee members. While it primarily focuses on current financial interests, it also asks for information about past financial interests that directly relate to the products or issues to be considered at the meeting, and any other interests or relationships that might give rise to an appearance issue.