






| |
After several months of the downloads section being
offline,
we're ba-ack!
Look, we understand, from all of the e-mails that you really missed the
downloads section. Truth is, we missed it, too, and we are genuinely flattered
by your kind words.
But we had some legal details to sort
out. Those being resolved, let's start again:
|
|
A primer on the December 2006
changes to the Federal Rules for Civil Procedure that affect electronic
evidence.
|
|
|
This is the 21 OCT 2005 US Federal Court decision against FDA in the
Utah Medical case.
In this ruling, the Court affirmed
(among other things) that FDA may not
adopt "industry standards" as "current" Good
Manufacturing Practices (cGMP's) by fiat or Guidance. In order to be an
action-able item, the practice must be specifically included in the CFR's.
|
|
|
This is the "Plaintiff's Brief" or, in layman's
terms, the FDA's complaint against Utah Medical. It takes the form of
requesting the Court to issue a permanent injunction, ordering Utah
Medical to cease manufacturing of regulated medical devices. |
|
|
This is the "Defendant's Brief" or, in layman's
terms, the Utah Medical answer to FDA's complaint. It takes the form of
requesting the Court to deny the FDA request for injunction, and to find
the FDA arguments without merit. |
|
|
This is the 2005 go 'round of the FDA soliciting public comment
regarding the cost burden of 21 CFR Part 11.
(FDA opens a docket for public comment on 21 CFR Part 11 economic
burden every two years or so.)
|
|
|
This is where the FDA reports that there were no public comments in the
above announced document, and submits its own estimates for the paperwork
burden.
In summary, roughly 20-30 hours of labor per company, and (quoting
FDA) "...no capital costs or operating and maintenance costs associated with this collection of information."
Since there is no public comment, FDA requests
OMB approval of the analysis.
|
|
|
And OMB approves the analysis.
|
|