Other Issues

On behalf of the Consumer Healthcare Products Association, enclosed herein are comments on the 2019 revised draft guidance document as well as FDA’s decision to revoke CPG 400.400.

While the “essential workforce” list is solely advisory in nature, it provides much-needed guidance to state and local governments as they proceed with their own “stay at home” orders across the country. It is important to make this list as precise as possible with few vagueries that can be left to interpretation.

It is imperative that the federal, state, and local governments come together with uniform definitions of “critical infrastructure”, making clear what manufacturers must continue to operate, and take seriously the need to transport those products and keep operations running.

We strongly agree that healthcare product manufacturers have a central role to play in the fight against this pandemic. Provided employers comply with CDC guidelines to protect workers, healthcare product manufacturers have the special responsibility to maintain their current work schedules.