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Regulatory Compliance Services
We are experts in regulatory requirements and can help companies understand their compliance obligations to the FDA, EPA, or Health Canada.
Companies with products possessing EPA Registration numbers are subject to mandatory reporting requirements for incidents involving these products pursuant to Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) section 6(a)(2). Additionally, EPA registered products with like formulations sold in other countries require that foreign incidents involving these formulations also be reported to the EPA in compliance with FIFRA section 6(a)(2).
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Under the Toxic Substances Control Act (TSCA) Section 8(c), companies are required to record, retain and in some cases report “allegations of significant adverse reactions” to any chemical substance or mixture that they produce, import, process, or distribute and that is not subject to mandatory surveillance compelled by other regulations such as Federal Insecticide Fungicide and Rodenticide Act (FIFRA) 6(a)(2) or the regulations of other agencies such as the FDA.
Furthermore, under TSCA Section 8(e), any person who manufactures, imports, processes or distributes in commerce a chemical substance or mixture and who obtains information which reasonably supports the conclusion that such substance or mixture presents a substantial risk of injury to health or the environment, must inform the EPA of the information unless this risk is already known by the EPA. Such information is commonly referred to as “substantial risk information.”
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Manufacturers of dietary supplements and/or over-the-counter (OTC) medications must comply with the FDA’s Dietary Supplement and Nonprescription Drug Consumer Protection Act (Pub. L. 109-462, 120 Stat. 3469) for adverse events (AEs) regardless of whether a causal relationship has been established between the manufacturer’s product and the adverse event.
SafetyCall Dietary Supplement Adverse Event surveillance services consist of the following operations:
SafetyCall Nonprescription Drug Adverse Event surveillance services consist of the following operations:
Manufacturers of a new drug application (NDA) or an abbreviated new drug application (ANDA) must comply with 21CFR310.80 and 21CFR310.98 for adverse events involving their products.
SafetyCall NDA/ANDA Adverse Event surveillance services consist of the following operations:
At the client’s request, SafetyCall may assist in the preparation of the PADER.
Manufacturers of medical devices must comply with the Medical Device Reporting (MDR) regulations (21 CFR 803) for adverse events involving their products.
SafetyCall MDR surveillance services consist of the following operations:
Classification of ICSRs as ‘Serious’ will be classified as Expedited 30-day alert reports, requiring that an individual FDA Form 3500A be completed by a SafetyCall pharmacist and forwarded to the client for review. Once approved, the ICSR will be submitted electronically to the FDA through the PV Works database.
The Consumer Product Safety Commission (CPSC) Consumer Product Incident Database was established to serve as a government funded forum, where the public can search for consumer allegations of injury or believed risk for injury related to the use of CPSC regulated consumer products or substances. If a consumer reports to the CPSC a product related adverse event that satisfies the minimum required information for publication, the Commission will transmit the report to the manufacturer, or private labeler, within 5 days of receipt by the Commission. Once received, the manufacturer will then have 10 days to provide a written response that will be published along with the consumer report in the database.
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Establishing an on-going system of surveillance for CPSC incidents which includes:
Companies with products possessing EPA Registration numbers are subject to mandatory reporting requirements for incidents involving these products pursuant to the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) section 6(a)(2). Additionally, EPA registered products with like formulations sold in other countries require that foreign incidents involving these formulations also be reported to the EPA in compliance with FIFRA section 6(a)(2).
Key SafetyCall Services:
Under Toxic Substances Control Act (TSCA) Section 8(c), companies are required to record, retain and in some cases report “allegations of significant adverse reactions” to any substance or mixture that they produce, import, process, or distribute and that is not subject to mandatory surveillance compelled by other regulations such as Federal Insecticide Fungicide and Rodenticide Act (FIFRA) 6(a)(2) or the regulations of other agencies such as the FDA.
EPA’s TSCA Section 8(c) rule requires producers, importers, and certain processors of chemical substances and mixtures to keep records concerning significant adverse reaction allegations and report those records to the EPA upon notice in the Federal Register or upon notice by letter from the EPA. The TSCA Section 8(c) rule also provides a mechanism to identify previously unknown chemical hazards in that it may reveal patterns of adverse effects which otherwise may not be noticed or detected. An allegation made by an employee must be kept by the company for 30 years while all other allegations (e.g., those made by plant site neighbors or customers) must be kept by the company for 5 years. Further information is available under 40 CFR Part 717.
All adverse incident reports are reviewed on a periodic basis, to insure complete and accurate documentation consistent with the rules outlined in TSCA section 8(c) – 40 §CFR part 717., SafetyCall applies a severity assessment of Minor, Moderate, Major, or Death on symptomatic cases, and provides a consistency assessment (marked as Consistent, Inconsistent, or Indeterminable) on those cases having a severity of Minor (with patient seen in the ER), Moderate, Major or Death.
SafetyCall will identify and flag potential TSCA 8(c) reportable cases that involve “unexpected (as per the label, MSDS or literature) significant adverse reactions.”
Under TSCA Section 8(e), any person who manufactures, processes or distributes a chemical substance or mixture and who obtains information which reasonably supports the conclusion that such substance or mixture presents a substantial risk of injury to human health or the environment shall immediately inform the EPA of such information unless such person has actual knowledge that the EPA has been adequately informed of such information.
Information does not need to be reported under Section 8(e) if the information:
In addition to the adverse event management for veterinary pharmaceutical products, SafetyCall International can help animal drug manufacturers/marketing authorization holders (MAHs) remain compliant with FDA regulations via our veterinary pharmacovigilance services.
Under section 21 CFR 514.80(b) of the FDA’s regulations, applicants of approved new animal drug applications (NADAs) and approved abbreviated new animal drug applications (ANADAs) are required to report adverse drug events and product/manufacturing defects in a timely manner. This continuous monitoring is the primary means by which FDA’s Center for Veterinary Medicine (CVM) obtains information regarding potential problems with the safety and efficacy of marketed approved animal drugs as well as potential product/manufacturing problems.
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The United States Department of Agriculture, Animal and Plant Health Inspection Service (USDA APHIS) regulates veterinary biologics (vaccines, bacterins, antisera, diagnostic kits, and other products of biological origin) to ensure that the veterinary biologics available for the diagnosis, prevention, and treatment of animal diseases are pure, safe, potent, and effective.
SafetyCall International does not offer any USDA reporting services for animal products. We do, however, manage any adverse events related to vaccines.
In addition to the adverse event management for veterinary biologics, SafetyCall International can help veterinary biologics licensees and permittees remain compliant with CVB regulations via our veterinary pharmacovigilance services
In compliance with the U. S. Department of Agriculture’s (USDA) Virus Serum Toxin Act (VSTA), enforced by the Animal and Plant Health Inspection Service (APHIS) Center for Veterinary Biologics (CVB), all adverse events (AEs; 9 CFR 101.2 “Adverse event”) associated with a veterinary biological product (9 CFR 101.2 “Biological products”) received by a Market Authorization Holder (MAH) must be documented and maintained. This applies to products in both domestic and international markets. Those AE reports meeting the definitions of serious, unexpected, and product related must be reported to CVB within 3 business days from when the MAH makes the determination that the criteria apply, or, at most, within 15 business days of when the AE was first received (9 CFR 116.9(b)(2); VS Memorandum 800.125). Adverse events not meeting the criteria for immediate reporting must be submitted within 90 calendar days of the date first received (9 CFR 116.9(b)(3)). Adverse events include a suspected lack of efficacy and symptomatic human exposures. Additionally, immediate notification to CVB is required if at any time there are indications that raise questions regarding the purity, safety, potency, or efficacy of a product, or if it appears that there may be a problem regarding the preparation, testing, or distribution of a product (9 CFR 116.9(b)(1)).
SafetyCall’s team of experienced veterinary professionals operates our veterinary pharmacovigilance service and can help to ensure CVB compliance by:
Manufacturers of drugs and natural health products in Canada must comply with the Food and Drugs Regulations and the Natural Health Products (NHP) Regulations.
SafetyCall NHP/Drug adverse reaction surveillance services for Canada shall consist of the following operations:
Clients with active ingredients and/or pesticides registered with the Canadian Pest Management Regulatory Agency (PMRA) are subject to mandatory reporting requirements pursuant to the Pest Control Products Incident Reporting Regulations. These regulations require the submission of electronic PMRA Incident Reporting Forms within prescribed timelines based on the severity classification of individual Canadian incidents.
Additionally, all formulations sold by a Canadian company’s affiliated or subsidiary company in the USA that contain active ingredients that are registered with the PMRA, must have certain US incidents associated with these active ingredients also reported to PMRA.
Finally, for each active ingredient associated with 10 or more incidents over a prescribed 12 month period, the registrant must provide an annual summary report identifying the total number of incidents reported and providing a concise critical analysis of the data.
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The Canadian Consumer Product Safety Act (CCPSA) is a recently enacted law that applies to a wide variety of consumer products including children’s toys, household products, sporting goods and specialty chemicals. The Act requires industry to provide information to Health Canada concerning consumer product safety incidents or product defects that result, or could reasonably be expected to result, in death or serious harmful health effects. This “early warning” provision also applies to inadequate labeling or instructions that could lead to the same results, and to recall orders or other corrective measures initiated in other jurisdictions for human health or safety reasons. It is important to note that serious incidents occurring outside of Canada may also fall under this new regulation if the consumer product involved is also sold in Canada.
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Clients with active ingredients and/or pesticides registered with the Canadian Pest Management Regulatory Agency (PMRA) are subject to mandatory reporting requirements pursuant to the Pest Control Products Incident Reporting Regulations. These regulations require the submission of electronic PMRA Incident Reporting Forms within prescribed timelines based on the severity classification of individual Canadian incidents.
Additionally, all formulations sold by a Canadian company’s affiliated or subsidiary company in the USA that contain active ingredients that are registered with the PMRA must have certain US incidents associated with these active ingredients also reported to the PMRA.
Finally, for each active ingredient associated with 10 or more incidents over a prescribed 12 month period, the registrant must provide an annual summary report identifying the total number of incidents reported and providing a concise critical analysis of the data.
Key SafetyCall Services: