FDA's Update on Medical Device Labeling Changes

Instructor: David Dills
Product ID: 701141

Duration: 60 Min

This Medical device training will provide valuable assistance and guidance to device companies involved in labeling changes. FDA recently released a final rule regarding the parameters in which a device manufacturer can modify label changes to a product. Specifically, manufacturers can add or strengthen the contraindications, warnings, precautions or adverse reactions sections of labeling via a PMA supplement without prior FDA approval only when such modifications are based on newly acquired information and evidence of a causal association between the product and a safety signal is present. The rule also provides clarification as to what the Agency considers to be new information to be incorporated into a label change. Specifically, new information “must reveal risks of a different type or greater severity or frequency than previously included in submissions” and includes meta-analyses, the new regulation states.” FDA requires that drug, biologics, and medical device manufacturers obtain FDA approval of their warning labels before the drugs or devices are marketed and sold. Manufacturers generally must also obtain FDA approval before making changes to labeling information. However, in limited circumstances, companies can revise or supplement their warning labels prior to FDA approval (through changes being effected (CBE) supplements) to ensure consumers are immediately made aware of newly discovered risks.

The labeling regulations, which became effective in late September 2008, clarify that a manufacturer can make unilateral pre-FDA approved labeling changes “only to reflect newly acquired information” when there is “reasonable evidence of a causal association” between the drug or device and the risk. The final rule defines “newly acquired information” as “information not previously submitted to [the] FDA.” This includes “new analyses of previously submitted data,” such as adverse event reports, new clinical study information, and new analyses that “reveal risks of a different type or greater severity or frequency than previously included in submissions to [the] FDA. Under the final rule, however, a CBE supplement is available only if there is "sufficient evidence of a causal association" justifying the addition or strengthening of a contraindication, warning, precaution or adverse reaction. The FDA explains that the language "sufficient evidence of a causal association" refers to the standards for drugs and biologics set forth in §201.57(c)(6) and §201.57(c)(7).

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Areas Covered in the seminar:

Understand the definition of "newly acquired information" than previously included in submissions to FDA.
Learn why the January 2008 proposal suggested the "newly acquired information" referred only to data derived from reports of adverse events.
Proposed rule may play a part in the U.S. Supreme Court consideration of the preemption issue.
Understand the background and history with the labeling changes.
Define how this impacts the manufacturer and modifications to label changes.
Learn why a CBE supplement is available only if there is "sufficient evidence of a causal association".
Final rule clarifies the FDA's pre-existing view of when a CBE supplement is appropriate.
Understand FDA's objective of the final rule and review several industry comments.

Who Will Benefit:

This webinar will provide valuable assistance and guidance to device companies in involved in labeling changes. The employees who will benefit include:

All levels of Management for all departments and those who desire a better understanding or a "refresh" overview.
QA/QC/Compliance/Regulatory Affairs
Marketing & Sales
Engineering/Technical Services/Operations
Consultants
Operations and Manufacturing

Instructor Profile:
David R. Dills, Industry Consultant, departed PAREXEL Consulting in July 2008 due to service line organizational change within SCOPE (Strategic Compliance & Operational Excellence). Prior to joining the consultancy Mr. Dills has provided independent consultative services in various capacities from pre-marketing to post-marketing within the technical, quality, regulatory affairs and compliance arena to pharmaceutical, Class I/II/III medical devices, in vitro diagnostics and biologics/biotech companies with an emphasis on establishing sustainable compliance systems. Mr. Dills also served as Director of Publications, Regulatory & Compliance for the Institute of Validation Technology. Through his work, Mr. Dills has been affiliated within the life sciences industry for more than nineteen years with increasing responsibilities in QA, Quality Engineering, Validation, RA/Compliance, and Corporate/Operations Management and previously employed on behalf of globally recognized device manufacturers and service providers in conjunction with marketing and business development responsibilities.

Key areas of focus include product development and commercialization strategies, regulatory classifications, applications and submissions, regulatory and clinical consulting, rapid regulatory crisis response, involved in consent decree/CIA activities, improve and remediate quality management systems and documentation, inspection readiness preparedness for manufacturers and serves in an Expert Witness capacity for a third party. Mr. Dills has prepared and executed effective paths to obtaining approvals, worked effectively across functions for overall corporate compliance, and aligned GxP compliance in a fashion that supports a company’s business strategies and goals.

Mr. Dills areas of interest and expertise include executing process validation, supplier qualification, training, internal/due diligence audits, policy/procedure development, PM, risk management/assessment, ISO 9001/13485/14971, MDD 93/42/EEC, CE Marking, remediation, GxPs, SW Validation/IT Network, MDR/AE/product complaints, design/change control, CAPA, PMA, IDE, 510(k), NDA and e-CTD/CMCs submissions, interfacing with international regulatory bodies, QSIT and PAI Inspections, sample accountability, and other related functions and tasks.

Mr. Dills currently serves on the Faculty Advisory Board for the Pharmaceutical Training Institute and Editorial Advisory Boards for Software Quality Professional and the Institute of Validation Technology (IVT), publisher of the Journal of GXP Compliance and Journal of Validation Technology. He serves on the Readers’ Board for Medical Device & Diagnostic Industry and Medical Product Manufacturing News and was nominated and accepted for inclusion into the 2005-2006 Strathmore’s Who’s Who of Professionals. Mr. Dills has authored and published validation, regulatory and compliance-related articles, commentaries and technical guides, and is an accomplished global industry presenter.

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