BROKERS ASSOCIATION SEMINAR SPECIAL PRODUCT REQUIREMENTS January 22, 2009 Chicago District/FDA
Ryan Gibson, Investigator Human Drugs Animal Drugs Medical Devices Medical Devices That Emit Radiation Non-Medical Devices That Emit Radiation Devices: Sunglasses/Reading Glasses Regulations Biological Products Biological Numbers
Human Drugs DLS – Drug Listing Number from the Foreign Manufacturer NDA – New Drug Application from the U.S. Firm IND –Investigation New Drug ANDA – Abbreviated New Drug Application http://www.fda.gov/
ANIMAL DRUGS NAD – New Animal Drug Application Number – Number issued by FDA/CVM to a U.S. Firm/Sponsor ANA – Abbreviated New Animal Drug DLS – Drug Listing Number from the Foreign Manufacturer INA – Investigational New Animal Drug http://www.fda.gov/
MEDICAL DEVICES DEV – Registration number for Importer LST – Medical Device Listing Number PMN – Premarket Notification (510(k)#) PMA – Premarket Approval (“P”#) IDE - Investigational Device Exemption http://www.fda.gov/
Medical Devices That Emit Radiation DEV – Registration Number For Importer LST – Medical Device Listing Number PMN – 510 (k) Number ACC – Accession number 2877 Form – 4 parts to the form A, B, C, D
Non-Medical Devices That Emit Radiation ACC – Accession number from manufacturer 2877 Form – RAA, RAB , RAC, RAD MDL – Model Number
Devices Sunglasses or Reading Glasses DEV – Registration number for Importer LST – Medical Device Listing Number IRC – Impact Resistance Lens Certificate
Regulations (CFR) Use this code plus the qualifier to inform FDA that a product is exempted. Most of FDA’s regulations are in Title 21.
Biological Products BFL – Biological Establishment License Number BPL-Biologic Product Number Biological License Number can be provided using either AofC
Biologic Numbers Biologic 510(k) BK960002 Biologic PMA BP000028 Use Device AofC PMN Biologic PMA BP000028 Use Device AofC PMA NDA BN 040083 Use Drug AofC NDA
Susan Ciani, Investigator Cosmetics LACF/AF: Low Acid Canned Foods and Acidified Foods IFE: Import For Export
Cosmetics If it is a drug, it requires foreign DLS. Concerns about Permitted colors BSE Microbiological content
LOW ACID/ACIDIFIED FOODS FCE – Food Canning Establishment Number Container Dimensions for jars, cans and pouches. SID – Schedule Identifier Number
LOW ACID/ACIDIFIED FOODS PRODUCT CODING CONSIDERATIONS Subclass is important to identifying products subject to LACF Regulations Products that are not hermetically sealed are exempt from LACF Regulations Subclass E (Metal), C (Glass), V (Vacuum or Modified Atmosphere Packgaing)
LOW ACID/ACIDIFIED FOODS PRODUCT CODING CONSIDERATIONS PIC is important to determining which products are subject to LACF Regulations PIC E Commercially Sterile: Product is packed in hermetically sealed container and heat treated to achieve commercial sterility PIC I Acidified: Low Acid Foods that are hermetically sealed to which acid is added
LOW ACID/ACIDIFIED FOODS PRODUCT CODING CONSIDERATIONS Examples Canned Tuna/Commercially Sterile 16AEE45/ Fish/ Metal / Commercially Sterile / Tuna (Albacore, Yellowfin, Bluefin, Skipjack, Etc.) Canned Artichokes/Acidified 24TEI01 Leaf / Stem Veg/ Metal / Acidified / Artichoke (Leaf & Stem Vegetable)
Import for Export Product will be imported into the U.S. but will be exported. Does not require a qualifier. Allows for importation of violative articles.