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Drugs used in medicine generally are divided into classes or groups on the basis of their uses, their chemical structures, or their mechanisms of action. These different classification systems can be confusing, since each drug may be included in multiple classes. The distinctions, however, are useful particularly for physicians and researchers.

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For questions regarding this document, contact the Office of Combination Products, at or combination fda. It does not establish any rights for any person and is not binding on FDA or the public. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations.

Antimicrobial drugs

To discuss an alternative approach, contact the FDA office responsible for this guidance listed above. FDA regularly receives questions from medical product sponsors concerning the classification of their products.

In addition, providing as much clarity and predictability as possible with respect to product classifications should enable informed planning for product development. While issues have arisen relating to whether a product should be classified as a drug, device, biological product, or combination product, most of these issues have related to whether a product should be classified How are medicines classified either a drug or a device.

The Agency recommends that sponsors contact the Office of Combination Products OCP to confirm the classification of any products they may wish to market if the appropriate classification is unclear or in dispute. FDA's guidance documents, including this guidance, do not establish legally enforceable responsibilities. Instead, guidances describe the Agency's current thinking on a topic and should be viewed only as recommendations, unless specific How are medicines classified or statutory requirements are cited. Any RFD determined to be incomplete will be returned to the sponsor with a request for the missing information.

The sponsor recommends a classification in the RFD, and should explain the basis for the recommendation. While the sponsor should justify why it believes the product meets the recommended classification, we generally consider both the information provided in the RFD and other information available to the Agency at that time in making our deation.

Generally, OCP will respond to the sponsor in writing within sixty days of the RFD filing, identifying the classification of the product as a drug, device, biological product, or combination product. RFD determinations pertain only to the product as described in the deation letter, including its proposed use s or indication s for use.

Therapeutic classification of drugs

The Agency may modify How are medicines classified determination made under section regarding the classification of a product or the component of FDA that will regulate the product either with the written consent of the sponsor or for public health reasons based on scientific evidence. A new determination may be appropriate if there is a change in, for example, a proposed indication for use or in a component of the product, or if the sponsor or Agency becomes aware of additional information that reveals that the means by which the product achieves its primary intended purposes differ from what was originally described in the RFD.

For example, if a sponsor wished to change the indication for a product and that new indication would be achieved through a different mechanism than the original indication, a different classification for the new indication might be appropriate.

Please contact OCP if you have questions regarding whether to submit an RFD, what information to provide, or issues to address in an RFD to ensure its completeness and clarity. Medical product classification determinations often focus substantially on whether a product that meets the definition of drug also meets the statutory definition of device.

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This section presents the drug and device definitions and discusses how the Agency addresses certain issues that arise when determining whether a product should be classified as a drug or device. A articles recognized in the official United States Pharmacopoeia, official Homoeopathic Pharmacopoeia of the United States, or official National Formulary, or any supplement to any of them; and B articles intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease in man or other animals; and C articles other than food intended to affect the structure or any function of the body of man or other animals; and D articles intended for use as a component of any articles specified in clause ABor C.

The sponsor presumably has the most complete information relevant to how its How are medicines classified product achieves its primary intended purpose s. For example, for a sponsor seeking to classify its proposed product as a device, those data should demonstrate that its product meets the definition of a device. At the classification stage, sponsors would not be expected to have gathered sufficient data to demonstrate that their proposed product meets the applicable marketing authorization standard e.

FDA will use How are medicines classified best scientific judgment to evaluate all available information relevant to the classification determination, including information submitted by the sponsor or available in the literature. This could be the case, for example, for gels or powders put on the skin as a barrier, gases used as space fillers, or liquids used to clean either surgical instruments or contact lenses. For example, if the primary intended purpose of a hip t replacement implant is to restore movement, and the implant also elicits a foreign body response through chemical action, that response would not be considered a primary intended purpose of the implant.

Similarly, if the primary intended purpose of an absorbable suture is to re tissue, and the suture is also deed to be resorbed by the body through a combination of chemical action and metabolic activities, such resorption would not be considered a primary intended purpose of the product. The examples presented in section III. If the chemical action is occurring inside the body or on the surface of the body, it is within or on the body.

How are medicines classified example, the chemical action of an antimicrobial agent used to clean a surgical instrument before that instrument is used is not occurring within or on the body.

However, the Agency has on occasion considered some situations in which it may be less clear whether chemical action is occurring within or on the body. For example, we have determined that chemical action occurring solely within an extracorporeal device, specifically a kidney hemodialysis machine, is not occurring within or on the body. Similarly, we have determined that the chemical action of a transport solution to preserve a donor organ for transplantation while in an organ transport container is not occurring within or on the body.

The following examples further illustrate the application of some of the key provisions of the device definition discussed above. Table 1 contains some examples of medical products that achieve their primary intended purposes through chemical action within or on the body. Table 2 contains some examples of medical products that do not achieve their primary intended purposes through chemical action within or on the body.

As explained in section III. In addition, products that meet the drug definition, or How are medicines classified the drug and device definitions, may also meet the definition of biological product under section i of the PHS Act 42 USC i. Products that meet the drug definition and that also meet the definition of biological product are classified as biological products, and are generally subject to licensure under the PHS Act.

If you have questions regarding whether a product meets the definition of biological product or how this might affect its classification, please contact OCP. Tel Fax combination fda.

Yes, if the product does not achieve its primary intended purposes through chemical action within or on the body and otherwise meets the definition of a device. However, products that meet the device definition may be regulated as drugs or biological products in some cases.

See question 2. Generally, the product would be classified as a device, unless it falls within a special category for example, How are medicines classified used in the preparation of compounded positron emission tomography drugs are classified as drugs, see 21 USC ii. Two products with exactly the same composition can be classified differently based on their primary intended purposes. However, the same product can be classified as a drug if it is intended, for instance, to alter pH, control odor, or prevent infection, and does so through chemical action as discussed in III.

What should you do if, after reviewing this guidance, you are unsure of how your product is classified?

GOV for feedback. This guidance addresses the definitions for the terms drug, device, and biological product in section III. For further information regarding the definition for the term combination product and the regulation of combination products, please visit the web for the Office of Combination Products. This guidance focuses on classification of products for human use.

Distinct considerations may apply in determining how to classify a product intended for use in animals. See 21 CFR 3. The sponsor may request reconsideration of the decision if its classification recommendation is not adopted by the Agency. A pre-RFD process is available if a sponsor wishes to obtain a preliminary, non-binding classification determination or to engage in preliminary classification discussions with the Agency before filing a formal RFD.

The RFD and pre-RFD processes are also available to sponsors to clarify the Center asment for medical products, though this issue is beyond the scope of this guidance.

If a product type has been classified by regulation, FDA would generally classify the product including as a constituent part of a combination product in accordance with the regulation, if the product or constituent part falls within the scope of that regulation. If the Agency concludes that it may be appropriate to propose changing a classification established by regulation, FDA would initiate notice and comment rulemaking to do so.

Accordingly, we do not offer guidance on its construction here. For purposes of this interpretation, an interaction at the molecular level occurs through either chemical reaction i. The mere exchange of non-chemical energy e. You can submit online or written comments on any guidance at any time see 21 CFR All written comments should be identified with this How are medicines classified docket : FDAD Product Description Aspirin Aspirin is used for pain relief. Acetylsalicyclic acid aspirin contains an acetyl group that has the ability to covalently bind to a serine residue of a cyclooxygenase enzyme COX-1 or COX Beta How are medicines classified Beta blockers are used to reduce blood pressure.

Beta blockers, like propranolol, bind beta receptors b1 and b2 and exhibit pharmacological action by inhibiting the activation of the aling cascade. This blockage causes cardiac cells to reduce the strength of cardiac contractions and heart rate. Magnesium Sulfate Magnesium sulfate is used as replacement therapy for magnesium deficiency.

Making sense of medication classification

It acts as a catalyst in enzymatic reactions a molecular-level interaction. While the chemical or atomic structure of magnesium sulfate is not altered, its participation in enzymatic reactions is considered a pharmacological action because it impacts various cellular and molecular processes. Polymyxin B Sulfate Polymyxin B sulfate is an antibiotic that is used to treat bacterial infection.

It is composed of a cationic protein surfactant that has fatty acid functional groups. Polymyxin B sulfate acts through intermolecular forces, by binding to components of the bacterial membrane i.

This binding is a pharmacological action because it disrupts the integrity of the bacterial membrane, which causes organism death, thereby treating the bacterial infection. Hydroxocobalamin Hydroxocobalamin is used as an antidote to cyanide poisoning. The cobalt moiety of hydroxocobalamin exhibits pharmacological action because it chemically reacts with cyanide, a toxic chemical agent, to form cyanocobalamin, a non-toxic compound, and the ability of hydroxocobalamin to interact with cyanide facilitates the removal of the toxic agent in order to inhibit the toxic effects of cyanide on the body.

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Product Description Abdominal Adhesion Barrier Inert, biodegradable synthetic polymers can be used to reduce post-operative adhesions with tissues and organs within the abdominal cavity. An implanted physical barrier sheet composed of such polymers would act to reduce adhesion through physical separation of tissue and not through pharmacological action on the surrounding tissue. PMMA is built from methyl methacrylate monomer units, which undergo free radical polymerization in the presence of an initiator compound.

The molecules that are part of the polymerization process interact with each other to create a solid mass to fill a bone void physically.

The process does not require an interaction between the PMMA and the bone at the molecular level and, therefore is not considered chemical action within or on the body.