The FDA & Innovative Products
Karen Greene
Another interesting session that I was able to attend at the Biocom Drug/Device Summit was about regulatory issues for new in vitro diagnostics and combination products.
Here is a summary of the session’s highlights:
- Combination products can be drug-device, device-biologic, drug-biologic, drug-device-biologic, but not drug-drug.
- Also defined that if a manufacturer co-packages any of the above in a kit then the package is defined as a combination product.
- The FDA has 3 medical products centers:
- CBER (center for biologics evaluation and research)
- CDER (center for drug evaluation and research)
- CDRH (center for devices and radiological health)
- The Office of Combination Products (OCR) assigns products to a center based on primary mode of action. They have developed an assignment algorithm based on the most important therapeutic action, with reasonable certainty.
- OCP has published a recent guidance document, entitled, “Early development considerations for innovative combination products”.
- FDA is working on rulemaking for GMP’s and post market safety reporting for combination products.
- The critical path for combination products includes the following:
- Expertise and expectations
- Identifying regulatory pathway and requirements
- Analytical techniques
- Biocompatibility vs. toxicology
- Bridging device and drug development cycles



