Prepare for the Unexpected: Industry not ready to take on FDA’s new Cosmetic Adverse Event Requirements

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FDA has expanded authority and regulatory power specifically for Adverse Events. FDA can now issue a Mandatory Recall if they determine that a cosmetic product is adulterated or that the exposure will cause serious adverse health consequences. They can also suspend a facility if there is reasonable probability of causing a serious adverse health consequence or public health concern. During inspections FDA can request information to help determine if the Adverse Events require a recall or to suspend a facility.  

  1. Understanding new Adverse Event Requirements for Cosmetics  
  2. Requirements for receiving adverse events and upcoming deadline for cosmetic labels 
  3. Process and tips for implementation of an Adverse Event intake system 
  4. Adverse Event Management Software Demonstration 

For Medical Device Establishments, who must register?

Owners or operators of establishments involved in producing and distributing medical devices intended for the U.S. market must register annually with FDA and pay an annual registration fee.

What information is submitted for medical device establishment registration?

In addition to registering with FDA, most owners or operators of medical device establishments must also submit a list of all devices during their annual registration renewal.

  • U.S. Facilities
    • Initial importers must identify the manufacturers of the devices they are importing.
    • A device must be listed if they fall under the any of the following:
      • Contract Manufacturer
      • Contract Sterilizer
      • Manufacturer
      • Relabeler / Repackager
      • Remanufacturer
      • Reprocessor of Single Use Device
      • Specification Developer
      • U. S. manufacturer of export only devices

       

     

  • Non-U.S. Facilities
    • Must list devices, provide a U.S. Agent, and identify importers.

     

Who must provide medical device listings?

In most cases, all medical device establishments required to register with FDA must also submit a complete list of medical devices manufactured for commercial distribution in the U.S. market.

All facilities that fall under any of the following functions:

  1. Contract Manufacturer
  2. Contract Sterilizer
  3. Foreign Exporter
  4. Manufacturer
  5. Relabeler / Repackager
  6. Remanufacturer
  7. Reprocessor of Single Use Device
  8. Specification Developer
  9. U.S. manufacturer of export only devices

What information is submitted for a medical device listing?

Medical device establishments must list any medical device made in the establishment and the activities the device is meant for.

  1. Company function (activity)
  2. Device product code
  3. Proprietary names
  4. Importer information

What is a master file?

A Master File is a secure, confidential submission of proprietary product data to a regulatory agency, such as the U.S. Food and Drug Administration (FDA), Health Canada, or the National Medical Products Association (NMPA) in China.

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