Wednesday 18 February 2015

Draft Guidance on Good Manufacturing Practices for Combination Products – FDA Delivers on Promises

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Are you familiar with the draft guidance 
on GMPs for combination products?
by Suzanne M. O'Shea
Counsel, Faegre Baker Daniels LLP


Two years ago, in January 2013, FDA published the final regulations on Good Manufacturing Practices for Combination Products.[1]  These regulations are built on the concept that the constituent parts of a combination product retain their regulatory identity as a drug, device, or biological product, even after they are physically, chemically, or otherwise combined into a single-entity combination product (i.e., prefilled injector or drug eluting stent) or co-packaged together.[2]  Therefore, all the good manufacturing requirements associated with each constituent part must be complied with in the manufacture of single-entity and co-packaged combination products. 
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