Home-Use Device Labeling Rule ‘Redundant’: Stakeholders
AdvaMed and Abbott Laboratories say an FDA proposed rule on electronic submission of labeling for certain home-use medical devices is redundant and should not be pursued. The AdvaMed comment letter says the rule is not needed because device labeling information is widely available to users, and many manufacturers of home-use devices provide labeling information for products through their Web sites.
Also, AdvaMed says, a labeling database proposed in the rule may confuse device users, such a proposed database should not be linked to other FDA systems, there should be exceptions and sunset periods, and additional clarity is needed when multiple parties are involved.
Abbott comments that it would be preferable for FDA to remove barriers to manufacturers of home-use devices in providing electronic versions as the sole means to convey device labeling, as is permitted for prescription medical devices used in healthcare settings.
Procter & Gamble says that the proposed requirement for electronic submission of the device label and package insert for all Class 2 medical devices labeled for use outside a professional healthcare facility “could create a regulatory burden greater than the proposed public health benefit for some categories of Class 2 devices.” The company recommends an exemption for products that have a low potential for misuse, either due to the nature of the device or due to the frequency of purchase of products that provide for a resupply of labeling. “Usage of these products is known to the population who purchases the product and usage information, warnings, and contact information for the manufacturer are included in each product package which is purchased at regular intervals,” it says. “In addition, information is available on the product Web site, therefore, additional submissions to FDA would be redundant. Further, as these are single-use products, no maintenance instruction is required.”
Finally, Mylan says that overall it welcomes the proposed rule and requests clarification regarding the intent of the agency’s “review” of the label and package insert of home-use devices.