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  • 1.  Paper copies of FPL to CBER?

    This message was posted by a user wishing to remain anonymous
    Posted 12-Apr-2018 11:03
    This message was posted by a user wishing to remain anonymous

    We have been submitting labeling in SPL format in our submissions to CBER, but in a recent approval letter we were still asked to provide paper copies of carton and container final printed labeling.  Is this an old template, or do the actually still want these paper copies?  I thought they were trying to do away with paper!
    Please share your experiences, thanks.


  • 2.  RE: Paper copies of FPL to CBER?

    Posted 24-Apr-2018 10:48
    Hi there,

    I found another thread on RegEx that contains similar information that might be helpful to you: Paper/Electronic Submission

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    Heather Arkwright
    Community Manager
    RAPS
    regex@raps.org
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  • 3.  RE: Paper copies of FPL to CBER?

    Posted 24-Apr-2018 11:28
    Dear A:

    At the time of First Use, you are required to submit SPL format per 21 CFR 601.14 and also paper copies* of the revised carton and container final printed labeling per 21 CFR 601.12(f).

    *: three (3) original paper copies

    David

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    Dr. David Lim, Ph.D., RAC, ASQ-CQA
    REGULATORY DOCTOR
    http://www.RegulatoryDoctor.US
    http://www.GlobalComplianceSeminar.com
    Phone (Toll-Free): 1-(800) 321-8567
    E-mail: David@RegulatoryDoctor.US
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  • 4.  RE: Paper copies of FPL to CBER?

    Posted 26-Apr-2018 13:34
    I have recent experience with this, and I do not recommend also submitting the paper copies. I believe this request from FDA is carryover from an old letter template.

    We received a letter from CBER in October 2017, which included a request for submission of final content of labeling in SPL format and also to submit three original paper copies for carton and container final printed labeling. Last month I submitted both an eCTD sequence and paper copies. I received a rejection notification for the paper submission stating that as of May 5, 2017, CBER will no longer accept paper submissions.

    I did attempt to follow up with our FDA PM and DMPQ, but I have not received a response.

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    Jennifer Knicley
    Director Regulatory Affairs
    United States
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