PhRMA Supports Streamlined GMPs for Combo Products

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Pharmaceutical Research and Manufacturers of America (PhRMA) says it supports FDA’s efforts to identify alternative or streamlined mechanisms for complying with GMPs for combination products. In comments to an agency notice on the efforts, PhRMA sought additional clarity on certain elements of the mechanisms outlined in the notice, and “strongly encourage(s) FDA to adopt a more robust risk-based approach to determining exemptions of combination products from the device Quality System regulation (QSR).”

 

Specifically, PhRMA raised concerns with FDA’s proposal to allow sponsors to change a GMP mechanism to one that is different than one previously discussed with the agency. The group says it is “unclear how FDA will consistently apply this approach across the agency when, for example, a given GMP mechanism is described in guidance from multiple Centers or offices or is misaligned with current guidance. PhRMA urges the Office of Combination Products (with the cooperation of the appropriate reviewing bodies) to ensure that sponsors consistently have an opportunity to apply alternative approaches that are risk-based and scientifically justifiable.”


PhRMA says it also strongly supports FDA allowing combo product exemptions “from all or certain provisions of the device QS regulation (part 820) if the device constituent part of the combination product is itself exempt from such requirements and use of the device constituent part falls within the scope of the relevant exemption, including with respect to the device constituent part’s intended use.” The group says it previously conveyed its concerns with the “current combination product regulations with respect to drug products co-packaged in convenience kits with low-risk delivery devices (such as dosing cups, syringes, spoons, etc.), which may subject the drug manufacturer to the full QSR when such devices are included with a drug in a convenience kit.”

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