Thank you, David. I appreciate your insight and wisdom on this topic.
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Larisa Pavlick
V.P. Global Regulatory and Compliance
UNPA
Salt Lake City UT
United States
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Original Message:
Sent: 30-Mar-2017 08:36
From: David Lim
Subject: Physican's letter and medical foods
Larisa,
For compliance purposes, I would suggest the letter be written pursuant to USC360ee(b)(3) and 21 CFR 101.9(j)(8).
As a medical food, it should be accurately communicated that your medical food is a specifically formulated and processed product; intended for the dietary management of a patient; it provides nutritional support modified for the management of the unique nutrient needs; intended to be used under medical supervision; and intended only for a patient receiving active and ongoing medical supervision..
Further, communication should be based on "medical foods are distinguished from the broader category of foods for special dietary use and from foods that make health claims by the requirement that medical foods be intended to meet distinctive nutritional requirements of a disease or condition, and must be intended to be used under medical supervision. Medical foods are not those simply recommended by a physician as part of an overall diet to manage the symptoms or reduce the risk of a disease or condition."
Thank you.
s/ David
______________________________________________
Dr. David Lim, Ph.D., RAC, ASQ-CQA
REGULATORY DOCTOR
Phone (Toll-Free): 1-(800) 321-8567
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