Recalls and Withdrawals
Amanda Klingler
Partner
King & Spalding LLP (Washington, DC)
Frederick A. Stearns
Partner
Keller and Heckman LLP (Washington, DC)
- Differentiating device recalls from drug recalls
- Evaluating FDA reporting requirements for device recalls
- Examining FDA’s recall and oversight authority
- 21 CFR part 7
- Voluntary vs. mandatory recalls
- Seizure and injunction powers
- 21 CFR part 810 – Mandatory Medical Device Recall Procedures
- Cease distribution and notification order
- Regulatory hearing
- Mandatory recall order
- Public notice
- Part 806, Corrections and removals reporting
- Weighing the pros and cons of working with FDA vs. alone
- Consequences of not instituting a recall
- Post-recall surveillance issues
- Reintroducing a product to the market