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Purpose and Content of Use-Related Risk Analyses for Drugs, Biological Products, and Combination Products

DraftCenter for Biologics Evaluation and Research Center for Devices and Radiological Health Center for Drug Evaluation and Research Office of the Commissioner,Office of Clinical Policy and Programs,Office of Combination Products07/08/2024

Description

The Food and Drug Administration (FDA or Agency) is announcing the availability of a draft guidance for industry and FDA staff entitled “Purpose and Content of Use-Related Risk Analyses for Drugs, Biological Products, and Combination Products.”  This document provides guidance to industry and FDA staff on the purpose and content of a use-related risk analysis (URRA) and how a URRA, along with other information, can be used to determine human factors (HF) data needs during product development and to support a marketing application.

Scope & Applicability

Product Classes

1
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.

Stakeholders

4
Sponsor

Entity responsible for submitting applications under section 524B

Health Care Professional

Intended users such as nurses in a nonemergency setting

Lay User

Intended user population for emergency use auto-injectors

Applicant

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

Regulatory Context

Attributes

2
Critical Task

User tasks which, if performed incorrectly, could cause harm.

Cap removal force

Cross-ridge cap designed with 1-2 N pulling force

Identified Hazards

Hazards

3
Harms

Identify the potential harms in URRA

Hepatotoxicity

Potential harm from overdose due to dosing schedule deviation

Use Error

Potential errors that may occur during product use tasks.

Related CFR Sections (3)

Related Warning Letters (10)

  • CGMP/QSR/Medical Devices/Adulterated

    Envoy Medical Inc.

    2025-12-09
  • CGMP/QSR/Medical Devices/Adulterated

    Hong Qiangxing Shenzhen Electronics Limited

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

    Contec Medical Systems Co., Ltd.

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Royal Philips

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Qianjiang Kingphar Medical Material Co Ltd.

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated

    LEVO AG

    2025-10-21
  • CGMP/QSR/Medical Devices/Adulterated

    Technological Medical Advancements LLC

    2025-10-07
  • Medical Device/Adulterated/Misbranded/Lacks PMA and/or 510(k)

    The Richline Group, Inc.

    2025-09-23
  • Investigational Device Exemptions (IDE)/Premarket Approval Application (PMA) Adulterated Device

    SeniorLife Technologies, Inc.

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

    Miach Orthopaedics

    2025-08-26

See Also (8)