FDA And TTB Issue Guidance To Increase Hand Sanitizer Production During COVID-19 Outbreak

Husch Blackwell LLP
Contact

The Food and Drug Administration and the Alcohol and Tobacco Tax and Trade Bureau (TTB) have both recently issued guidance documents to allow for the increased production of alcohol-based hand sanitizer during the COVID-19 outbreak.

The FDA issued two guidance documents to increase the supply of alcohol-based hand sanitizers. The first indicates that FDA will not take action against manufacturing firms that produce alcohol-based hand sanitizers for consumers and healthcare workers. The second allows pharmacists to compound alcohol-based hand sanitizers without a patient-specific prescription.

The guidance only applies to production that uses the United States Pharmacopoeia or Food Chemical Codex grade ingredients listed in the guidance. There is also additional information about product labeling, manufacturing methods, and reporting requirements as Drug Registration and Listing System (DRLS) information will have to be prepared and submitted to FDA.

The TTB announced that the agency is allowing distilled spirits permittees (DSPs) and alcohol fuel plants (AFPs) to more easily participate in the hand sanitizer market as well. DSPs do not have to obtain authorization to produce hand sanitizer or distilled spirits for use in hand sanitizer. AFPs and beverage DSPs are also exempted from obtaining additional permits or bonds to manufacture hand sanitizer or supply ethanol for other TTB permittees to manufacture hand sanitizer. AFPs and beverage DSPs must continue to maintain records of their operations. Many states have announced similar flexibility for distilled spirits manufacturers, but manufacturers should check with their local licensing authority prior to supply ethanol for or producing hand sanitizer.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Husch Blackwell LLP | Attorney Advertising

Written by:

Husch Blackwell LLP
Contact
more
less

PUBLISH YOUR CONTENT ON JD SUPRA NOW

  • Increased visibility
  • Actionable analytics
  • Ongoing guidance

Husch Blackwell LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide