Questions on Emergency-Use Injector Guidance
The Association for Accessible Medicines and Teva have raised identical questions and issues about an FDA draft guidance on technical considerations for demonstrating the reliability of emergency-use injectors submitted under a BLA, NDA, or ANDA. The company and association raise these issues:
- FDA needs to come to a reasonable definition of “emergency-use” because the testing the agency describes in the guidance is rigorous and challenging and likely would not be appropriate for some, if not most, products;
- the possibility that FDA would create a different standard for devices considered under an ANDA than the agency used in reviewing devices when they were originally approved under an NDA;
- the arduous nature of the testing described in the guidance could discourage sponsors from innovating and updating device design attributes; and
- the need for FDA to align the occurrence of a device failure with the possibility that harm will be experienced by the device user or patient as a result of the failure.
The two letters also contained technical line-by-line comments. Pfizer submitted a chart with only technical comments.