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Instructions for Use — Patient Labeling for Human Prescription Drug and Biological Products — Content and Format

FinalCenter for Biologics Evaluation and Research Center for Drug Evaluation and Research Office of the Commissioner,Office of the Chief Medical Officer,Office of Combination Products07/15/2022
Human Factors Engineering

Description

This guidance provides recommendations for developing the content and format of a patient Instructions for Use (IFU) document for human prescription drug and biological products, as well as drug-led or biologic-led combination products submitted under a new drug application (NDA) or a biologics license application (BLA).

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

5
Combination Product

Products combining drug, device, or biological constituents; Generally recommended for Enhanced Documentation; Requires 14971-based framework incorporating ICH Q9; A drug-device combination where the device constituent part detects ingestion.

Biological Product

Regulated under section 351(i) of the PHS Act; Virus, therapeutic serum, toxin, vaccine, or protein applicable to prevention or treatment; Alternative regulation category for products meeting device definition

Chemotherapeutic drug products

Products requiring special disposal procedures

Transdermal systems

Products requiring specific disposal instructions to prevent risk

Drug-led, drug-device combination product

Guidance recommends visuals of the device constituent parts for these products.

Stakeholders

6
Caregivers

Individuals providing information for medical product development; Participants in facilitated discussions and observational studies

Packer

Entity whose name appears on the label

Distributor

Entity responsible for submitting NDINs

Manufacturer

Entity responsible for submitting NDINs

Patient

Way questions are framed is critical to collecting unbiased patient input

Applicant

Entity submitting development data and knowledge; Entity performing the work process for change

Regulatory Context

Regulatory Activities

6
NDA

New Drug Application

Approved

The IFU must state it has been approved by the FDA

BLA

Biologics License Application

ANDA

Abbreviated New Drug Application

PDUFA VI

Sixth authorization of the Prescription Drug User Fee Act

IND

Investigational New Drug submissions

Document Types

2
Instructions for Use

Reagent stability studies should support conditions outlined in the IFU; Labeling for lay users at no higher than a 7th grade reading level.

Prescribing Information

The primary section of drug labeling where SLCs are implemented

Attributes

4
Readability

Content recommendation for patient labeling

Sans-serif font

Recommended typeface styling for readability

Expiration date

should be based on appropriate supportive stability data

Controlled substance schedule

Information to be included in the product title if applicable

Technical Details

Substances

1
Suppositories

Dosage form requiring the action verb 'insert'

Processes

5
Administration Instructions

Specific content section required in the IFU

Disposal Instructions

Specific content section required in the IFU

Reconstitution

Automated mixing of drug prior to injection.

Dilution

Preparation of a drug before administration

Priming

Instructions for priming topical or inhaled products.

Clinical Concepts

1
Adverse reactions

Increased risk when daily wear lenses are worn overnight

Identified Hazards

Hazards

5
Use-related risks

Risks identified through URRA that may warrant an IFU

Needle stick injury

Risk associated with sharps like auto-injectors and pens

Injury

Failure to follow instructions could result in injury.

Secondary exposure

Instructions to prevent or mitigate the risk of secondary exposure to a drug.

Medication errors

Risk of inappropriate administration of extra doses

Standards & References

External Standards

1
Guidelines for Prescription Labeling and Consumer Medication Information for People With Vision Loss

External guidelines referenced for patient labeling design

Specifications

3
Room temperature

Time needed for a refrigerated product to warm to room temperature.

8 points font size

Minimum font size for specific technical sections like manufacturer address

10 points font size

Minimum recommended font size for most IFU sections

Related CFR Sections (10)

Enforcement Impact

Deficiencies cited in Warning Letters referencing the same regulations

Misbranded drug
26
False or misleading claims concerning the compounder
22
Introduction of misbranded drugs into interstate commerce
2
Introduction of misbranded products into interstate commerce
1

Related Warning Letters (10)

Related MFDS Guidelines

Korean regulatory guidelines covering similar topics

See Also (8)