Regulation for combination product

Regulation for combination product

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  PREPARED BY AKASH M.PHARMA 1STSEM. (PHARMACEUTICS)
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   Two ormore separate products packed together in a single package or as a unit comprised of drug and device products, device and biological products or biological and drug products.  i.e. Drug or biologics with applicator/delivery devices.  Monoclonal antibody combined with a chemotherapeutic drug.
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   Prefilled syringes Patches for transdermal drug delivery  Wound dressings whose primary purpose is to deliver a drug  Red blood cell processing solutions  Contrast media
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   Drug impregnateddevices  Injectable collagen  Wound dressing (act as a barrier)  Blood bags containing anticoagulant  Drug coated devices such as catheters, shunt sensors or pacemaker leads
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  According Therapeutic GoodsAct 1989, it is defined as any instrument apparatus, appliance, material or other article (whether used alone or in combination and including the software necessary for its proper application) intended to be used for human being for:  Diagnosis, prevention, monitoring, treatment or alleviation of diseases. Investigation, replacement or modification of the anatomy or of a physiological process.
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  Intended use anddevice characteristics Classification Regulatory requirements Regulatory submission process
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  Legislation Effective dateComment Federal Food And Drug Act 1906 Did not include medical devices Food, Drug And Cosmetics Act 1938 Extended control to cosmetics and medical devices New Drug Amendments 1962 The Kefauver-Harris Amendments requiring efficacy prior to marketing, post-marketing surveillance, and adverse event reporting Medical Device amendment 1976 Devices divided into 3 categories with defined approvals processes Safe medical devices act 1990 Additional reporting and tracking rules with emphasis on class III devices
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  The Food &Drug Administration Modernization Act 1997 Allowed accelerated reviews, regulation of advertisements, and reauthorized for additional 5 years, with certain technical improvement Medical Device User Fee & Modernization Act 2002 Multiple reforms to medical device regulations, authorization of user fees, and establishment of the office of combination products (OCP) The Food & Drug Administration Amendment Act 2007 Reauthorization of medical device user fees, new pediatrics devices provisions, and clinical trial registry for 510(K) and PMA eligible products The Food & Drug Administration Safety & Innovative Act 2012 Reauthorization of the medical device user fee act (MDUFA III) for another 5 years and implementation of about 3 dozen medical device provision
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  Classification Comments Class ILow risk of harm to user, registration only unless 510(K) clearance required, compliance with general controls Class II Moderate risk of harm to user,510(K) clearance unless waived, compliance with general controls and special controls Class III High risk of harm to user, often requires premarket approval (PMA), compliance with general controls and PMA Combination Product Depending on the primary mode-of-action (PMOA), may be reviewed by multiple interagency divisions
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   In India,the medical devices are regulated by the Drug Controller General of India (DCGI) within the Central Drugs Standard Control Organization (CDSCO) under the Drug & Cosmetics Act 1940 and Drugs & Cosmetics rules of 1945.  CDSCO include bone cements, heart valves, blood component bag, condoms, cardiac stents, disposable hypodermic needles and orthopedic implants.
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   Medical classificationby the EU, Canadian Drugs and Health Products (DHP), Japanese Pharmaceuticals and Medical Devices Agency (PMDA), Russian Roszdravnadzor (RZN) and Australian Therapeutic Goods Act (TGA) are subdivided into four categories as class I through IV and Class I, IIa, IIb and III for EU, RZN and TGA.  The four levels of classification is based on low, Low-moderate, moderate-high and high risk to patients.
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   Depending onthe device, several regulatory pathways are available to the applicants including 510(K) premarket notification, reclassification, product development protocol (PDP), de novo review, and premarket approval (PMA) application.  A 510(K) filing, the device is “cleared” if it is substantially equivalent (SE) to an already marketed device referred as a “predicate device”  Reclassification process could include a petition to the USFDA to classify the device at a lower than originally requested, in order to receive permission for marketing.
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   PDP’s aimis to design preclinical and clinical studies by working closely with the USFDA in advance of any testing.  The de novo review or so-called automatic reclassification is for those class I and II devices that have no predicate device after receiving a not substantially equivalent (NSE) response.  PMA for higher-risk sustaining devices, often class III that requires a major commitment by the sponsor to conduct preclinical and clinical studies.