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  • 1.  Response to 483

    This message was posted by a user wishing to remain anonymous
    Posted 19-Jun-2018 10:14
    This message was posted by a user wishing to remain anonymous

    Does anyone know what is the best way to send response to FDA 483?
    -Mail
    -Email
    -Fax
    -ESG

    what in case if file exceeds the size to be sent through email? (i.e.) more than 50 mb

    Thank you for your help.

     



  • 2.  RE: Response to 483

    Posted 19-Jun-2018 10:49
    ​I have always seen written responses that were sent via FedEx. You want to have traceability that you responded. It doesn't hurt to also follow up to confirm that FDA received your response.

    Regards

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    Christine Anderson
    Senior Principal Specialist
    Regulatory & Quality Solutions
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  • 3.  RE: Response to 483

    This message was posted by a user wishing to remain anonymous
    Posted 19-Jun-2018 15:00
    This message was posted by a user wishing to remain anonymous

    What in case if response(50+mb) has hyperlinks and bookmarks and it is recommended to send electronically instead of normal mail.

    Does FDA accepts documents through FTP?


  • 4.  RE: Response to 483

    Posted 20-Jun-2018 04:32
    What Christine recommended is the best approach; send in a hard copy with tracking to confirm receipt.

    Regarding electronic submission; as far as I know for FDA Form 483 responses from a completed inspection FDA does not accept electronic submission.  In fact, the response to Form 483 should be done to local FDA district office (D.C. for foreign inspections) and they may not have capability to record information in an electronic system like eCopy for 510(k) submissions.

    In my experience, FDA does not accept documents through FTP or any other file-sharing system because the government system needs to be protected from viruses, intrusions, etc.  I tried to share a large file with an FDA reviewer a while back and I ended having to send in a Supplement with the file on a CD/DVD.

    Now this does not mean you could have a conversation with the local FDA district office to inquire if they will accept an electronic version of the Form 483 response through email or some other medium.  Nowadays, they may do this but it would be dependent upon the district office I think and what capability they have to accept electronic only responses.

    Worse comes to worse if you have an electronic version with hyperlinks and bookmarks, send in a hard copy + CD/DVD with the electronic version.  In the cover letter to the Form 483 response explain that the CD/DVD has an electronic version that is navigable with hyperlinks and bookmarks.

    I would be curious if the wider RAPS group has ever submitted electronic Form 483 responses that have been accepted.

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    Richard Vincins RAC
    Vice President Regulatory Affairs
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  • 5.  RE: Response to 483

    Posted 20-Jun-2018 08:23
    In our 820 inspection last August, the inspector actually requested that we send the response electronically and indicated that email is the preferred method for responses.

    When we emailed our response, we received an automated response indicating that the FDA had received our response for our records. Received our EIR in record time.

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    Joshua Lust
    Global Regulatory Affairs Manager
    Grand Rapids MI
    United States
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  • 6.  RE: Response to 483

    Posted 20-Jun-2018 08:25
    With the recent ORA reorganization, FDA is now saying (in a few recent trade press articles and presentations) you should send 483 responses in both email and paper copy. The email address for devices is

    Division 1: oradevices1firmresponse@fda.hhs.gov
    Division 2: oradevices2firmresponse@fda.hhs.gov
    Division 3: oradevices3firmresponse@fda.hhs.gov

    The paper copy, oddly, should go to the Division Director in your old District office w/ Attn: Compliance on the letter. The electronic copy is now consider the "official" response. In fact FDA says they would prefer you not send paper copies but they realize that isn't going to happen :-)

    I'd suggest you reach out to the Division Program Director and ask how they would prefer to receive a response that is too big for email - after first trying like crazy to actually get the response compressed down to be able to be sent via email. Be prepared to suggest a lot of possibilities, including sending it to them on a CD etc.

    Ginger

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    Ginger Glaser RAC
    Chief Technology Officer
    MN
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  • 7.  RE: Response to 483

    This message was posted by a user wishing to remain anonymous
    Posted 20-Jun-2018 11:22
    This message was posted by a user wishing to remain anonymous

    Thank you for taking the time to share all of that great information. Your inputs and advice have been extremely helpful.


  • 8.  RE: Response to 483

    Posted 25-Jun-2018 05:03
    Yes, thank you for this information especially what you had included Ginger - very interesting.  I had worked with a couple local districts that maybe were still "old school" wanting paper or maybe they were just saying that was the official response and I was hearing them say that as please send in paper copies haha.

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    Richard Vincins RAC
    Vice President Regulatory Affairs
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  • 9.  RE: Response to 483

    Posted 26-Jun-2018 08:16
    Richard,

    I too have always done responses like you describe - with the official copy in paper and tracked receipt. That's actually why I flagged the new FDA info. All apparently driven by the new ORA structure and the desire for them to have an "all electronic" system that automatically (or semi-automatically) incorporates the official responses. I am told those email addresses should route responses directly into the official files eventually - though I suspect right now someone still has to match them up with the company.

    I do generally like electronic overall though.

    We actually added these to our SOPs, just so we remember to use them if the need ever arises! I hope I won't ever again need them :-)

    G-

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    Ginger Glaser RAC
    Chief Technology Officer
    MN
    ------------------------------