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OTC/Supplement Combo New Safety/Efficacy Data Not Needed - Attorney Hutt

This article was originally published in The Tan Sheet

Executive Summary

OTC/supplement combination products do not require premarket clinical trials to establish safety and efficacy if data exist on the individual ingredients, attorney Peter Barton Hutt of Covington & Burling (Washington, D.C.) asserted at the Consumer Healthcare Products Association Legal & Regulatory Conference in D.C. Nov. 30.

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Dietary supplement/OTC single ingredient combinations should be addressed quickly, the National Nutritional Foods Association says in response to CFSAN's proposed FY 2001 Program Priorities.

Omni Nutraceuticals

Inholtra Joint Pain analgesics with glucosamine and chondroitin are monograph compliant despite FDA concerns about OTC/supplement combination products, Omni says. A launch date has not been set for the line of four analgesics (aspirin, acetaminophen, ibuprofen and naproxen sodium ) and the company is still in talks with FDA regarding labeling. Omni says the products differ from other combinations because they will be labeled only with OTC indications, claims and dosing schedules approved under existing monographs, not structure/function claims. FDA recently sent letters discouraging several companies from marketing products with both OTC and supplement claims, and promised future guidance on the issue (1"The Tan Sheet" June 12, p. 3). Omni will list glucosamine and chondroitin as "inactive ingredients" on labeling but will prominently display them on packaging, relying on consumers' knowledge of the ingredients

OTC/Supplement Combinations "Serious Concern" For FDA

The appropriateness of combination products containing OTC drug and dietary supplement ingredients is under review at FDA. In the interim, the agency is discouraging firms from marketing such items.

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