PMOA Proposed Rule:
May 7, 2004 Federal Register

  • "Mode of Action" would be defined as the means by which a product achieves a therapeutic effect

    • "Therapeutic" includes any effect or action of the combination product intended to diagnose, cure, mitigate, treat, or prevent disease, or affect the structure or any function of the body

  • Three types of modes of action: biological product, device, drug

  • Combination products are comprised of more than one type of regulated article [or constituent part] and will typically have more than one identifiable mode of action (e.g., drug and device, device and biological product, etc.)

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