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IA #57-15 - 5/20/02, IMPORT ALERT #57-15, "DETENTION WITHOUT PHYSICAL
   EXAMINATION OF ALLERGENS ***AND/OR ALLERGENIC PRODUCTS*** ATTACHMENT
REVISED 5/20/02


          NOTE:     This alert has been revised to create an attachment and
                    clarify the products covered.  Additional changes are
                    bracketed by asterisks (***).

          TYPE OF ALERT: Detention Without Physical Examination

          NOTE:     This import alert represents the Agency's current guidance
                    to FDA field personnel regarding the manufacturer (s) and/or
                    product(s) at issue.  It does not create or confer any
                    rights for or on any person, and does not operate to bind
                    FDA or the public.

PRODUCT:  Allergens (allergenic extracts)
          Allergen delivery systems (allergy patches)

PRODUCT
CODE:     See attachment

PROBLEM:  No U.S. License and Misbranding

PAC:      45R800

PAF:      REG

COUNTRY:  Canada (CA)
          Sweden (SE)
     ***  United Kingdom (GB)***

MANUFACTURER
/SHIPPER:      ***See Attachment***


CHARGE:   "The article is subject to refusal of admission pursuant to
          Section 801(a)(3) in that the labeling of the article does not
          appear to contain adequate directions for use, and the article
          does not appear to be exempt from such requirements.[Misbranding,
          Section 502(f)(1)]."

                               AND

          "The article is subject to refusal of admission pursuant to
          Section 801(a)(3) in that the article appears to be a biological
          drug for which a biologics license is not in effect under Section
          351 of the Public Health Service Act. [PHS Act, Section 351(a)]."
          (OASIS Charge Codes:  NO LICENSE; DIRECTIONS)

RECOMMENDING
OFFICE:   CBER, Office of Compliance and Biologics Quality, Division of Case
          Management, HFM-610


REASON FOR
ALERT:    FDA has determined that the firms listed ***below*** have been
          sending unlicensed allergens and/or ***allergenic products*** to
          the U.S.

          ***Many allergenic products identified as part of Enzyme
          Potentiated Desensitization or EPD treatments have been
          misdeclared or inappropriately identified in previous entries as
          enzymes, reagents, biochemicals, and dietary supplements.***

GUIDANCE: Districts may detain without physical examination the specified
          biologic product(s) from the firms listed *** on the attachment to
          this alert ***.

          NOTE:     (For Allergen Delivery Systems/Patches) - Allergen delivery
                    systems only that are pre-filled with allergenic extracts or
                    unfilled allergen delivery systems that accompany allergenic
                    extracts in shipping should be detained.  Unfilled allergen
                    delivery system components are not subject to this guidance.

FOI:      Purging between ^     ^ is required.

KEY WORDS:     Allergen, allergy patches, allergen extract

PREPARED
BY:       Stella Notzon, DIOP, (301) 443-6553

DATE LOADED
INTO FIARS:    May 20, 2002

                                    *** ATTACHMENT TO IMPORT ALERT # 57-15, Revised 5/20/02 ***

                   [FIRMS RECOMMENDED FOR DWPE]

Manufacturer             Products            Product Code

Chemotechnique Diagnostics    All allergens and/or     ^            ^
Malmo, Sweden            allergenic products ^            ^
FEI # 3002096442                                  ^            ^
                                             ^            ^
                                             ^            ^

Chemotechnique Diagnostics    All allergens and/or     ^            ^
Box 80                   allergenic products ^            ^
Tygelsjo, Sweden                                  ^            ^
FEI # 3001620868                                  ^            ^
                                             ^            ^

Dormer Laboratories,Inc. All allergens and/or     ^            ^
91 Kelfield Street #5         allergenic products ^            ^
Rexdale, Ontario, Canada                     ^            ^
M9W 5A3                                      ^            ^
FEI # 3001344828                                  ^            ^

McEwen Laboratories      Enzyme Potentiated  ^            ^
12 Horseshoe Park             Desensitization          ^            ^
Pangboorne, Berks, England    products including: ^            ^
RG87JW United Kingdom         Beta-glucuronidase  ^            ^
FEI # 3001190779              Chondroitin X-Theta ^            ^
                         Chondroitin X-E
                         Chondroitin I-C
                         Chondroitin LA
                         Chondroitin W
                         Chondroitin Formalin
                         Chondroitin P/K.C.
                         Chondroitin O&E
                         Chondroitin T
                         Chondroitin Bacteriodes
                         Chondroitin M
                         Chondroitin D