Never Mind Next-Gen UV Filters; Existing Sunscreen Ingredients’ GRASE Status May Be In Danger
FDA aims to publish a tentative final monograph for OTC sunscreen drugs in 2019 that identifies “data gaps that FDA believes need to be filled” for 16 currently listed UV filters to support their continued marketing in the US without new drug approvals.
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Following FDA’s proposed sunscreen rule in February, the Consumer Healthcare Products Association has opened a line of communication with the American Cleaning Institute to gain insight into the GRASE data delivery process that kicked off for consumer antiseptic products in September 2016.
CDER's enforcement policy guidance for OTC monograph sunscreens clarifies that spray sunscreens are included in the agency's enforcement discretion. But CDER closes the door on other dosage forms that it also identified in its 2011 ANPR for whether delivery formats other than lotions, creams or other traditional forms would be eligible for the monograph.
It’s known that challenges posed by FDA-advised maximal usage trials have been the bane of OTC sunscreen and antimicrobial drug ingredient sponsors of late, but new draft guidance from the agency signals that MUsTs will be expected generally from companies looking to add topical ingredients to OTC drug monographs.