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Navigating GRAS Panels: A Guide to Best Practices

When it comes to introducing new substances into the world of food and dietary supplements, ensuring safety is paramount. The GRAS (Generally Recognized as Safe) designation plays a critical role in this process. The U.S. Food and Drug Administration (FDA) provides guidance on how to convene a GRAS panel effectively and responsibly, ensuring that the substances used are indeed safe for human and animal consumption. In this summary blog, we’ll explore the key takeaways from the FDA’s guidance on “Best Practices for Convening a GRAS Panel.

Understanding the GRAS Provision

GRAS, or “Generally Recognized as Safe,” is a designation that signifies that a substance is deemed safe for its intended use in food. However, obtaining this status is no small feat. The FDA offers valuable insights into this process, specifically when a GRAS panel’s input may be needed.

When Is a GRAS Panel Necessary?

In many cases, a proponent, the entity seeking GRAS status for a substance, may not require a GRAS panel to determine the safety of a new ingredient. The proponent can evaluate existing data and information independently. However, there are instances where the proponent might opt to consult a GRAS panel. This decision depends on the complexity of the substance or the potential need for expert opinions.

The Role of a GRAS Panel

A GRAS panel serves as a valuable resource, offering an expert assessment of the safety and suitability of a substance for its intended use. Importantly, the panel’s conclusion does not inherently establish general recognition of the substance’s safety. Instead, it serves as evidence that there is general acceptance within relevant scientific communities based on generally available information.

Choosing the Right GRAS Panel

The FDA emphasizes the importance of assembling a qualified and balanced panel. Members should possess subject matter expertise relevant to the scientific considerations associated with the intended conditions of use of the food substance. Only when a panel adequately represents a larger scientific community can its conclusions be considered “generally accepted.”

The Need for Expertise

A “GRAS panel” opinion carries weight only if its members have the expertise appropriate to address the safety questions specific to the substance in question. A panel consisting of scientists without the requisite expertise cannot establish “generally accepted” conclusions.

When a GRAS Panel May Not Be Necessary

In most cases, a robust GRAS conclusion can be reached without the input of a GRAS panel. Therefore, proponents should carefully assess whether the resources and efforts required to convene such a panel are warranted for their specific case.

FDA’s Guidance Recommendations

The FDA’s guidance offers recommendations for those considering GRAS panels:

  1. Identifying Panel Members: Ensure that GRAS panel members have appropriate expertise in the relevant field.
  2. Mitigating Bias: Take steps to reduce any potential bias or conflicts of interest among panel members to maintain the credibility of the panel’s output.
  3. Limiting Data and Information: Only provide GRAS panels with public information, avoiding trade secret data.

Conclusion

In summary, the FDA’s guidance on convening GRAS panels provides essential insights into the complex process of establishing the safety of food substances. The right choice between seeking a GRAS panel’s input or relying on independent evaluation depends on the circumstances. Ensuring that the panel is composed of qualified experts and that potential biases are minimized is crucial. Ultimately, the GRAS process plays a pivotal role in protecting the safety of consumers and maintaining the quality of the food supply.

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Understanding FDA FURLS, FDA Approved, and FDA Registered Medical Devices

 

Navigating the Regulatory Landscape: Understanding FDA FURLS, FDA Approved, and FDA Registered Medical Devices

The process of bringing medical devices to market in the United States involves stringent regulations imposed by the Food and Drug Administration (FDA). Understanding the distinction between FDA FURLS (FDA Unified Registration and Listing System), FDA Approved, and FDA Registered is crucial for manufacturers and distributors seeking to comply with these regulations.

This article explores the differences between these designations and provides insights into how to obtain the necessary licenses for medical devices. Keep reading to learn more and stay compliant.

Device Registration and Listing Requirements

Since October 1, 2012, specific medical device listing requirements have been in effect. It is imperative for all stakeholders to adhere to these regulations:

  • All proprietary names under which a device is marketed must be reported during initial listing and in the annual update of registration and listing information.
  • Combination products, which include devices and biological products or drugs, must be clearly identified, specifying the type of combination product, such as convenience kit or prefilled drug delivery device, through the FDA Unified Registration and Listing System (FURLS).
  • Regardless of commercial distribution, all contract manufacturers and sterilizers of finished devices are obligated to register and list their products.
  • Initial importers must identify the manufacturers of the devices they import.
  • Foreign establishments exporting devices to the United States must identify all known U.S. importers of their devices.
  • Devices must be listed by the manufacturer, specification developer, single-use device reprocessor, remanufacturer, or re-packer/re-labeler before a foreign exporter, contract manufacturer, or contract sterilizer can list them.
  • Establishments handling complaints, previously registered as manufacturers or specification developers, should update their establishment type to “Complaint File Establishment.”

FDA Approved: Ensuring Safety and Efficacy

FDA approval refers to the process by which a new medical device undergoes rigorous evaluation to ensure its safety and efficacy before it can be marketed in the United States. The approval process involves the submission of a premarket approval (PMA) application or a 510(k) premarket notification, depending on the device’s classification.

PMA applications are required for Class III devices, which are high-risk devices such as implantable pacemakers and certain diagnostic imaging devices. 510(k) premarket notifications are for devices that are equivalent to a legally marketed device (predicate device) and are typically lower risk.

FDA Registered: Establishment Compliance

FDA registration is a mandatory requirement for all medical device establishments. It involves providing detailed information about the facility, its operations, and the devices it manufactures, processes, packs, or holds. FDA-registered establishments are subject to inspections to ensure compliance with FDA regulations, including good manufacturing practices (GMP).

Registration is a prerequisite for selling medical devices in the U.S. market, and failure to register can lead to serious consequences, including legal actions and fines.

How to Obtain Licenses? Step-by-Step Guide

  1. Identify the correct classification of your medical device according to the FDA’s classification system (Class I, II, or III).
  2. Prepare the required documentation, such as a 510(k) premarket notification or a PMA application. Work closely with regulatory experts and consultants to ensure the accuracy and completeness of the submission.
  3. Submit the application to the FDA along with the required fees. The FDA will review the submission and provide feedback or request additional information if necessary.
  4. Ensure that your establishment is registered in the FDA FURLS database. Update registration information annually to maintain compliance.
  5. Quality System Requirements: Implement a quality management system compliant with FDA regulations, including GMP. Prepare for FDA inspections to demonstrate compliance with quality system requirements.
  6. Establish a post-market surveillance system to monitor the performance and safety of your device after it enters the market. Report adverse events and product issues promptly to the FDA.

Conclusion

Navigating the intricate regulatory landscape of medical device approval and registration demands a deep understanding of FDA FURLS, FDA Approved, and FDA Registered designations. By aligning with expert consultants and regulatory professionals, manufacturers and distributors can successfully obtain the necessary licenses, providing safe and effective medical devices to enhance healthcare outcomes for patients across the United States.

Our experts at Quality Smart Solutions are here to help and offer medical device-related regulatory advice and support on successfully securing your medical device license.  We can help you by responding to potential information requests, keeping your license updated, and reviewing your device labels (510k Medical Device Registration, Facility Registration & FURLS, IVD Device Registration, and SaMD Classification. Fill out the form below to book a free consultation with our experts or contact us for more information.

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What Are Critical Control Points (CCPs) in HACCP?

Introduction 

Ensuring food safety is crucial for businesses in the food industry. That’s where Hazard Analysis and Critical Control Points (HACCP) comes in, a structured approach that helps prevent contamination and maintain high safety standards. At the center of this system are Critical Control Points (CCPs), key stages in food production where risks must be controlled to avoid hazardous outcomes. 

But why do CCPs matter, and how can you implement them effectively? This guide will walk you through everything you need to know, from defining CCPs to meeting regulatory requirements. Keep reading to learn how to protect consumers, maintain compliance, and strengthen your food safety practices. 

Defining Critical Control Points (CCPs) 

A Critical Control Point (CCP) in HACCP is a specific step in the food production process where control must be applied to mitigate biological, chemical, or physical hazards. Without effective CCP management, the risk of contamination increases, potentially leading to foodborne illnesses or non-compliance penalties. 

Importance of CCPs in HACCP 

Properly managing CCPs not only ensures product integrity but also helps businesses avoid risks associated with contamination. Here’s why CCPs are so important: 

  • Risk reduction: Identifying and managing CCPs minimizes the likelihood of hazardous contamination, reducing the risk of foodborne illnesses. 
  • Quality assurance: CCPs help maintain consistency in food quality by enforcing strict control measures throughout the production process. 
  • Regulatory compliance: Many regulatory bodies mandate HACCP-based food safety systems. Implementing CCPs ensures compliance with international food safety regulations, preventing legal and financial issues. 

Regulatory Standards Governing CCPs 

Food safety regulations vary across countries, but most follow similar principles based on HACCP guidelines. These regulations help ensure that food businesses implement proper controls to minimize risks and protect consumers. Below are key regulatory bodies and frameworks that govern CCPs worldwide: 

United States: FDA Food Safety Modernization Act (FSMA) 

In the U.S., The Food Safety Modernization Act (FSMA) enforces preventive food safety measures, including HACCP principles and CCP identification. 

Canada: Safe Food for Canadians Regulations (SFCR) 

Canada enforces HACCP principles through the Safe Food for Canadians Regulations (SFCR), which guarantees that food businesses maintain high safety standards. 

European Union: European Food Safety Authority (EFSA) 

The EFSA establishes guidelines for CCPs across the European Union, securing stringent food safety compliance. 

Global Standards: Codex Alimentarius Commission 

This international organization sets food safety benchmarks that many countries adopt, making HACCP and CCPs a globally recognized standard. 

How to Implement CCPs in HACCP 

Successfully implementing critical control points (CCPs) in HACCP requires a structured approach. Each step is designed to identify potential risks, establish control measures, and ensure ongoing compliance. Below is a streamlined process to help businesses effectively implement CCPs: 

  1. Conduct a hazard analysis: Identify biological, chemical, and physical hazards that may compromise food safety. 
  2. Determine critical control points: Pinpoint stages in the production process where risks must be controlled to prevent contamination. 
  3. Establish critical limits: Define measurable thresholds for factors like temperature, time, and microbial counts to maintain safety. 
  4. Implement monitoring procedures: Regularly track CCPs through inspections, testing, and data collection to ensure compliance. 
  5. Develop corrective actions: Create protocols to address deviations from critical limits and quickly restore safety measures. 
  6. Conduct verification and record-keeping: Maintain detailed records of monitoring, corrective actions, and verification activities to demonstrate compliance.  

At Quality Smart Solutions (QSS), we can guidance you on HACCP compliance and CCP implementation. Our services include formula review, product labeling, and nutrition facts (Canada & USA); supplemented foods registration (TMALs) & compliance; safe foods for Canadian regulations (HACCP, PCP, import licensing, GRAS notifications); facility registration, FSVP agent, and U.S. Agent services.  

Contact us today to ensure your food safety compliance. 

Read more 

Want to dive deeper into HACCP, CCP, and food safety? Here are some helpful resources to expand your knowledge: 

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