P223: New Visualization Models of Designation Pathway and Group Categorization of Device-Drug /Biologic Combination Products in US

Poster Presenter

Nobuo Uemura

Adjunct Researcher
Institute For Medical Regulatory Science, WASEDA University
Japan

Objectives

To improve the predictability and acceptability of the designation of new device-drug and device-biologic combination products in US for developers, and sponsors, we proposed new visualization models of the designation pathway and group categorization focusing on the device component function.

Method

We searched the website of the FDA on 15 November, 2020 to identify the regulatory scheme of the FDA’s 129 capsular decision cases of device-drug and device-biologics combination products and other publicly available cases the FDA designated to the drug/biologic or device regulatory scheme.

Results

New definition of the primary intended use (PIU): the most important single intended use (IU) of the final combination product by developer and sponsor. By introducing a new definition for primary intended use (PIU) by developers and sponsors extracted from the classification factors of primary mode of action (PMOA), we developed new visualization models of the designation pathway and two-dimensional group categorization. And applying these models to the cases the FDA designated, we proposed a new group categorization of combination products while focusing on the device component function.

Conclusion

The new visualization models with PIU and PMOA and the new group categorization focusing on the device component function proposed in this study may increase predictability and acceptability of the classification of newly developed combination products into the regulatory scheme of drug, biological product, and device, for innovators, developers, and sponsors.