Adequate Directions for Use
The "adequate directions for use" requirement is a core US labelling concept with no direct equivalent in other frameworks. It underpins the prescription/OTC device distinction.
The requirementโ
Under 21 CFR ยง 801.5, labelling must bear adequate directions for use โ directions under which a layperson can safely use the device for the purposes for which it is intended.
"Adequate directions for use" means directions that are:
- Stated in ordinary terms
- Include the quantity of each application
- Include any frequency of application
- Include the duration of application
- Include any relevant precautions, warnings, and contraindications
Prescription device exemptionโ
Devices that are restricted to sale by or on the order of a licensed practitioner (prescription devices) are exempt from the adequate directions for use requirement under 21 CFR ยง 801.109 โ because a layperson is not the intended end user.
Instead, prescription device labelling must include adequate information for practitioners, including:
- Indications for use
- Effects, routes, methods, and frequency of use
- Relevant contraindications, side effects, and precautions
Exemption for OTC devices already in common useโ
Some OTC devices (those sold directly to consumers without a prescription) are sold with labelling that achieves adequate directions for use through the combination of label and IFU.