Stakeholders Suggest Drug-Device Product Guidance Changes

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The Combination Products Coalition says that while it agrees with many of the recommendations in an FDA draft guidance on comparative analyses and related comparative use human factor studies for a drug-device combination product submitted in an ANDA, it believes there should be several revisions. The coalition says it strongly recommends that FDA revise the document to: 

  •          improve alignment between the draft guidance and existing human factors guidance provided by FDA and by recognized U.S. and international standards;
  •          focus comparative analyses on risk, not use error rates;
  •          describe human factor studies as qualitative research (to assess the adequacy of the product user interface) rather than quantitative research (to assess the user’s capabilities);
  •          promote innovation and improvements in product design to enhance safety and effectiveness; and
  •          provide more detailed information on topics not sufficiently addressed in the draft.

AdvaMed’s comment letter raises a concern that the draft guidance proposes an approach that is inconsistent with CDRH 2/3/16 guidance on applying human factors and usability engineering to medical devices and does not appropriately factor in risk-based approaches. “This draft guidance frequently discusses methods that are similar, but meaningfully different,” the letter says. “Modest changes to the language and suggested study designs in this draft guidance could enable the methodology to be aligned with other FDA human factor guidances and recognized standards, while also ensuring the generic product is interchangeable with the reference from a usability perspective and safe for users.”

Specific comments were submitted by the Chartered Institute of Ergonomics and Human Factors and Sanofi.

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