Withdraw Insulin Reimportation Proposal Request: PhRMA
Pharmaceutical Research and Manufacturers of America (PhRMA) is calling on FDA to withdraw its 9/24/20 Request for Proposals (RFP) Regarding Insulin Reimportation Programs. A 12/17/20 petition also calls on the agency to:
- refrain from reimportation of insulin under section 801(d)(2) of the Federal Food, Drug, and Cosmetic Act unless insulin is in shortage as a result of a medical emergency;
- establish a process by which the drug manufacturer has notice and an opportunity to participate in the decision-making process for an application for reimportation of its drug product under section 801(d)(2); and
- provide the public with notice whenever an application for drug reimportation under section 801(d)(2) has been approved.
The petition says FDA’s Request for Proposals “ignores significant risks to patient safety posed by imported insulin and failed to consider the factors FDA itself has identified as relevant to determining whether a drug is ‘required for emergency medical care.’” The petition also says FDA is relying on an improper reading of section 801(d)(2) and the RFP is “plagued by additional legal flaws.”