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Presented by: Edward Basile

Presented by: Edward Basile

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PRE-APPROVAL PROMOTION<br />

• FDA prohibits pre-approval promotion of an<br />

investigational biologic or drug. 21 C.F.R. §<br />

312.7(a).<br />

• Failure to adhere to § 312.7(a) is a violation of the<br />

IND regulations and can result in termination of<br />

the IND or other FDA enforcement action. 21<br />

C.F.R. § 312.44(b)(1)(v) and (2)(1).<br />

• Promotion of an investigational device is<br />

prohibited, and subjects the violator to FDA<br />

enforcement action. 21 C.F.R. § 812.7

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