Questions on Emergency-Use Injector Guidance

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The Association for Accessible Medicines and Teva have raised identical questions and issues about an FDA draft guidance on technical considerations for demonstrating the reliability of emergency-use injectors submitted under a BLA, NDA, or ANDA.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.

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