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Postmarketing Safety Reporting for Combination Products: Guidance for Industry and FDA Staff

FinalOffice of the Commissioner,Office of Clinical Policy and Programs,Office of Combination Products Center for Drug Evaluation and Research Center for Devices and Radiological Health Center for Biologics Evaluation and Research07/22/2019

Description

This guidance addresses how to comply with the final rule on postmarketing safety reporting (PMSR) requirements for combination products that FDA issued on December 20, 2016 (81 FR 92603, hereafter the "combination product PMSR final rule," "final rule," or "rule").  The rule describes how to comply with PMSR requirements for combination products that have received FDA marketing authorization.  Although the PMSR regulations for drugs, devices, and biological products share many similarities, each set of regulations establishes distinct reporting requirements, including reporting triggers and timeframes.  The final rule addresses the application of these regulatory requirements to combination products to ensure consistent and complete reporting while avoiding duplication.

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.

Drug-eluting stent

Device application combination product example

Single-entity combination product

Components combined or mixed and produced as a single entity like a prefilled syringe.

Co-packaged combination product

Separate products packaged together in a single package.

Cross-labeled combination product

Separately packaged products intended for use only with each other.

Stakeholders

5
Combination Product Applicant

Entity subject to the PMSR final rule for a combination product.; Entity holding the only application or all applications for a combination product; Entity responsible for safety reporting for the combination product as a whole.; Entity responsible for submitting safety reports; Entity responsible for submitting PMSR reports for combination products; Must retain PMSR records for the longest time period required under all applicable requirements.; Entity responsible for submitting combined FAR/BP

Distributor

Entity responsible for submitting NDINs

Importer

Must comply with registration if meeting facility/responsible person definitions

Manufacturer

Entity responsible for submitting NDINs

Constituent Part Applicant

Entity subject to the PMSR final rule for a constituent part of a combination product.; Entity holding an application for a constituent part marketed by different applicants; Entity responsible for a specific part of a combination product.; Entities required to share information regarding deaths or serious injuries; Subject to separate recordkeeping and information sharing requirements.; Entity subject to the combination product PMSR final rule

Regulatory Context

Attributes

4
active moiety

Used to determine reporting requirements for foreign products

expected life of the device

Time a device is expected to remain functional after being placed into use.

3 working days

The mandatory timeframe for submitting a FAR after receiving reportable information.

45 calendar days

Timeline for submitting BPDRs from the day of acquiring information

Identified Hazards

Hazards

2
bacteriological contamination

A condition triggering a Field Alert Report

contaminants

Drug coating contaminants traced to production equipment

Related CFR Sections (19)

Related Warning Letters (10)

  • Compounding Pharmacy/Adulterated Drug Products

    Wells Pharma of Houston, LLC

    2025-11-25
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Royal Philips

    2025-10-28
  • Medical Device Reporting/Misbranded

    Insung Medical Co. Ltd.

    2025-09-30
  • False & Misleading Claims/Misbranded

    Novo Nordisk Inc.

    2025-09-16
  • False & Misleading Claims/Misbranded

    Eli Lilly and Company

    2025-09-16
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Visgeneer, Inc

    2025-08-05
  • Medical Device Reporting/Misbranded

    Insightra Medical Inc.

    2025-07-08
  • CGMP/QSR/Medical Devices/Adulterated

    Aju Pharm Co., Ltd.

    2025-06-24
  • False & Misleading Claims/Misbranded

    Sprout Pharmaceuticals, Inc.

    2025-06-10
  • CGMP/QSR/Medical Devices/Adulterated

    DFI Co., Ltd.

    2025-06-03

See Also (8)

Postmarketing Safety Reporting for Combination Products: Guidance for Industry and FDA Staff | Guideline Explorer | BioRegHub