Hello Rashmi,
Either the "Rx Only" symbol or the full narrative form you've given must appear on the "label" pursuant to FDA's 21 CFR Part 801.109. FDA defines "label" as the display of written, printed, or graphic matter upon the immediate container. Therefore it is insufficient to have the prescription use statement only on the IFU.
Hope this helps,------------------------------
Kevin Randall, ASQ CQA, RAC (U.S., Canada, Europe)
Principal Consultant
ComplianceAcuity, Inc.
Golden CO
United States
www.complianceacuity.com------------------------------
Original Message:
Sent: 05-Jun-2017 19:42
From: Rashmi Pillay
Subject: Device label and Precription only device statement
Hi ,
Needed advice on the device label and requirement of Rx only statement for the device label (for ophthalmic ultrasound & lasers). Our IFU does include the statement 'Caution: Federal law restricts this device to sale by or on the order of a qualified ophthalmic physician.' Does it need to be included on the device label as well?
Thanks & Regards,
Rashmi Pillay
Regulatory Affairs Associate
Ellex Medical Pty Ltd
3, Second Avenue, Mawson Lakes
Adelaide, SA 5095, Australia
T + 61 8 7074 8105
F +61 8 8104 5231
rpillay@ellex.com