A pharmaceutical company is developing a novel drug-eluting stent, a product combining a drug and a device. To formulate an effective regulatory strategy in the United States, what is the MOST critical initial step?
-
A
Submitting a Request for Designation (RFD) to the Office of Combination Products (OCP) to determine the product's Primary Mode of Action (PMOA).
-
B
Beginning clinical trials immediately to gather efficacy data for both the drug and device components.
-
C
Developing separate marketing applications for the drug and device components to streamline the review process.
-
D
Engaging a contract manufacturing organization that is compliant with both 21 CFR 211 and 21 CFR 820.