Beruflich Dokumente
Kultur Dokumente
ADVICE
Please refer to your July 20, 2016 submission to docket FDA-2015-N-01 01- 1295 (Safety and
Effectiveness for Health Care Antiseptics; Topical Antimicrobial Drug Products for Over-the-
Counter Human Use). You provided a list of organisms that would be tested as part of a
proposed single time-kill study and a single Minimum Inhibitory Concentration (MIC) and
Minimum Bactericidal Concentration (MBC) study for potential pathogens that may be
encountered in consumer use settings, health care settings, and food handler settings. You
indicated that most of the organisms identified come directly from the Consumer Wash proposed
rule (2013), Health Care Antiseptics proposed rule (1994 & 2015) and Consumer Hand Rub
proposed rule (2016). In addition, you have added other relevant organisms based on the
experience of your scientific experts, such as community-acquired methicillin-resistant
Staphylococcus aureus (A TCC# BAA-1683). You provided the following list of organisms to
include in your proposed time-kill study:
Time-Kill Testing
You propose to test 261 microorgani sms as part of a single time-kill test including 36 strains of
particular organisms based on FDA guidance, and an additional 225 clinical isolates; 25 clinical
isolates for each of the nine organisms identified by FDA in the Consumer Wash proposed rule:
• Enterococcus faecalis
• Staphylococcus aureus
• Streptococcus pyogenes
• Listeria monocytogenes
• Campylobacter jejuni
• Escherichia coli
• Pseudomonas aeruginosa
• Salmonella enterica Serovar Enteritidis
• Shigella sonnei
American Cleaning Institute
Page 2
MIC-MBC Testing
Additionally, you propose to test 900 organisms by the MIC and MBC methods, and propose to
test 25 strains and 25 clinical isolates of each of the following 18 microorganisms identified by
FDA in the Health Care Antiseptic proposed rule and the Consumer Hand Rub proposed rule:
• Haemophilus influenza
• Bacteroides fragilis
• Enterobacter species
• Burkholderia cepacia
• Escherichia coli
• Klebsiella pneumoniae
• Pseudomonas aeruginosa
• Serratia marcescens
• Campylobacter j ejuni
• Salmonella enterica
• Shigella sonnei
• Enterococcus faecalis
• Staphylococcus aureus (including methicillin-re sistant strains of Staphylococcus aureus
(MRSA))
• Streptococcus pyogenes
• Listeria monocytogenes
• Streptococcus pneumoniae
• Acinetobacter baumannii
• Candida albicans
We recommend that you test a total of 268 microorganisms as part of a single time-kill.
This includes: a) 43 strains of particular organisms based on the three antiseptic
categories (Consumer Antiseptic Wash, Consumer Antiseptic Hand Rub, and Health Care
Antiseptic), and b) an additional 225 clinical isolates, 25 clinical isolates for each of the
nine organisms identified in the Consumer Antiseptic Wash proposed rule. See previous
guidance given to you in an advice letter dated March 8, 2016, and Table 1 below.
Table 1. Organisms for In Vitro Time-Kill Efficacy Testing for OTC Topical Antiseptic Monographs
MIC/MBC Testing
2. Include the following additional organisms as described in the 1994 and 2015 Health
Care Antiseptic proposed rule:
• Enterococcus faecium (including vancomycin resistant strains of Enterococci)
• Micrococcus luteus
• Proteus mirabilis
• Staphylococcus epidermidis (including methicillin resistant strains of
Staphylococcus epidermidis)
• Staphy lococcus haemolyticus (ATCC 29970)
• Staphylococcus hominis (ATCC 27845)
• Staphylococcus saprophyticus (ATCC 15305)
We recommend that you test 1,250 organisms by the MIC/MBC test method. You would
need to test 25 strains and 25 clinical isolates of each of the following 25 microorgani sms
identified in the Health Care Antiseptic proposed rule and the Consumer Antiseptic Hand
Rub proposed rule. See Table 2 below.
Table 2. Organisms for MIC/MBC Efficacy Testing for OTC Topical Antiseptic Monographs
If you have any questions, call Celia Peacock, Regulatory Project Manager at (301) 796-4154.
Sincerely, ~
~UJ) IVJ1 1rrr-vuLV, ~to
Theresa Michele, MD
Director
Division ofNonprescription Drug Products
Office of Drug Evaluation IV
Center for Drug Evaluation and Research