Guide on Combo Product Risk Analyses
FDA has released a draft guidance entitled “Purpose and Content of Use-Related Risk Analyses for Drugs, Biological Products, and Combination Products.” The document provides information on the purpose and content of a use-related risk analysis (URRA) and how this, along with other information, can be used to determine human factors (HF) data needs during product development and to support a marketing application. It applies to drug- and biologic-led combination products that include a device constituent part.
The guidance notes that as part of FDA’s evaluation of an application, it evaluates HF study results submitted by sponsors. “This includes data to support the product user interface when submission of such data is warranted,” FDA says. “The URRA is a risk analysis tool used to identify use-related hazards associated with product use and the measures implemented to reduce those risks. The URRA supports the entire HF engineering process and should be considered as part of an overall risk management framework.”
Additionally, the document says a URRA is important to help identify use-related hazards associated with a combination product’s user interface design, as well as to characterize risks to mitigate them through risk controls or eliminate them altogether through improved product user interface design. The URRA is also a key component in developing an HF validation study protocol and “informing the acceptability of residual risks,” it says. It may also aid in demonstrating compliance with applicable combination product requirements.
The draft guidance recommends that sponsors should initiate the URRA early during product development and use and update the tool in all phases of the product lifecycle (e.g., as the product design changes or as new risks are identified during development or post marketing).
FDA notes that a URRA should include the following:
- A comprehensive list of all tasks required for using a product
- The potential use errors and harms that may occur with those tasks
- A determination of whether each task is a critical task
- Risk controls employed in the user interface design to mitigate the use errors
- Evaluation methods that have been used (or will be used) to evaluate risk controls’ effectiveness