The American Cleaning Institute (ACI)

“Quality and Safety” Concerns Should Lead FDA to Withdraw Temporary Hand Sanitizer Guidance

04/29/2021
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  • American Cleaning Institute, Consumer Healthcare Products Association Say Pandemic-Inspired Policy is No Longer Needed
  • Long-time Sanitizer Manufacturers Have Secured Supply Chains, Are Able to Meet Product Demand, Groups Say

The American Cleaning Institute (ACI) and the Consumer Healthcare Products Association (CHPA) called on the U.S. Food and Drug Administration (FDA) to withdraw its temporary guidance for the manufacturing of alcohol-based hand sanitizer products.

In the early days of the COVID-19 pandemic, FDA issued its Guidance for Industry: Temporary Policy for Preparation of Certain Alcohol-Based Hand Sanitizer Products During the Public Health Emergency (COVID-19), to help meet unprecedented demand, allowing non-traditional sanitizer companies to manufacture these FDA-regulated products. While FDA’s temporary guidance provides instructions for developing hand sanitizers, the newer manufacturers were not required to meet FDA’s typical manufacturing requirements which have historically applied to companies that traditionally make the products to ensure quality and safety.

“FDA issued this temporary policy in the early days of the COVID-19 pandemic in order to meet the huge increase in market demand for hand sanitizers to help address the COVID-19 public health emergency,” wrote ACI and CHPA in a letter to FDA. “We appreciate the actions of all manufacturers to provide hand sanitizer products to support peak consumer and health system demand during the pandemic.”

“We note that FDA has had to address ongoing quality and safety issues associated with many of the products manufactured under the temporary policy, likely due to lack of compliance with Current Good Manufacturing Practice requirements (cGMPs). We believe that it is now appropriate to withdraw the guidance and return to manufacturing only by those firms in full compliance with applicable requirements, including cGMPs.”

The groups added that the hand sanitizer supply has now stabilized to meet demand and the market has now “become oversaturated with hand sanitizers manufactured under FDA’s temporary policy.”

“ACI and CHPA recommend that FDA promptly withdraw the temporary policy and require alcohol-based hand sanitizer manufacturing that is not in compliance with cGMPs and other applicable requirements to stop, allowing a reasonable period for manufacturers marketing under the temporary guidance to finish out their pre-existing supply contracts. We further recommend that any product manufactured and placed into interstate commerce prior to the withdrawal of the temporary policy be permitted to remain in distribution to allow distributors time to clear current inventory of temporary hand sanitizer.”


The American Cleaning Institute® (ACI – https://www.cleaninginstitute.org) is the Home of the U.S. Cleaning Products Industry® and represents the $60 billion U.S. cleaning product supply chain. ACI members include the manufacturers and formulators of soaps, detergents, and general cleaning products used in household, commercial, industrial and institutional settings; companies that supply ingredients and finished packaging for these products; and chemical distributors. ACI serves the growth and innovation of the U.S. cleaning products industry by advancing the health and quality of life of people and protecting our planet. ACI achieves this through a continuous commitment to sound science and being a credible voice for the cleaning products industry.

Founded in 1881, the Consumer Healthcare Products Association (CHPA) is the national trade association representing the leading manufacturers and marketers of over-the-counter (OTC) medicines, dietary supplements, and consumer medical devices. Every dollar spent by consumers on OTC medicines saves the U.S. healthcare system more than $7, contributing a total of $146 billion in savings each year. CHPA is committed to empowering consumer self-care by preserving and expanding choice and availability of consumer healthcare products. www.chpa.org

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