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The FDA & Innovative Products

Karen Greene Karen

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

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