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You may wish to note that this FDA document is issued only by CDER, CBER, CVM and ORA. If your concern is medical devices i.e. CDRH, the applicable guidance is in fact the above-referenced GHTF document, in the creation of which CDRH played a key role. Tim Ulatowski, the CDRH Director of Enforcement, is a major proponent of GHTF efforts.
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