Regulatory Open Forum

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  • 1.  Physican’s letter and medical foods

    Posted 24-Mar-2017 14:04
    Hello,
    Can anyone tell me the necessary inclusions in a "physician's letter" related to a medical food?  Can you please direct me to the appropriate reference?  I have reviewed the FDA compliance program and FDA website related to medical foods with no luck.  the compliance program states this "physicians letter" is to be collected by the FDA investigator during the inspection and it will be forwarded to CFSAN.  I am having trouble determining what should be included in this letter.  Thank you for your help.

    Best,


    Larisa Pavlick
    V.P. Global Regulatory and Compliance

    United Natural Products Alliance

    1075 E Hollywood Ave, Salt Lake City, UT 84105  lunpa.com 
    Office phone 801.474.2572 

    Direct: 801.738.2975  

    fax 801.474.2571  info@unpa.com



  • 2.  RE: Physican’s letter and medical foods

    Posted 30-Mar-2017 08:38
    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

    NOTICE: This communication (including any attachments) may contain privileged or confidential information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this communication and/or shred the materials and any attachments and are hereby notified that any disclosure, copying or distribution of this communication, or the taking of any action based on it, is strictly prohibited.







  • 3.  RE: Physican's letter and medical foods

    Posted 31-Mar-2017 17:46
    Thank you, David.  I appreciate your insight and wisdom on this topic.

    ------------------------------
    Larisa Pavlick
    V.P. Global Regulatory and Compliance
    UNPA
    Salt Lake City UT
    United States
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