FDA's recommendation that industry package liquid OTCs with uniquely appropriate dosing devices "may in fact lead to an increase in dosing errors" as consumers mix devices from different products, private labeler Perrigo says. The firm's associate director of regulatory affairs, Devon Morgan, writes in a Feb. 3 1letter that FDA should study consumer usage and understanding, and then provide "data-driven direction to industry." Perrigo also disagrees with other elements of FDA's November 2009 draft guidance on dosing devices for liquid OTCs, including the recommendation that "delivery devices should not be significantly larger" than a liquid drug's largest labeled dose; the firm cites a device's need to facilitate technical functionality and consumer handling. Allegan, Mich.-based Perrigo distributes 63 liquid OTC products and says it is implementing the voluntary industry dosage device provisions adopted by the Consumer Healthcare Products Association (2"The Tan Sheet" Feb. 8, 2010, In Brief)

The Institute for Safe Medication Practices calls for FDA to make a draft guidance on dosage delivery devices for liquid OTCs more restrictive to prevent consumer misdosing via standardized devices

The Consumer Healthcare Products Association recommends a standardized labeling format for OTC pediatric oral liquids to help prevent accidental overdoses and misdosing