Commenting Guidelines

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Commenting Guidelines

Please follow these Guidelines when submitting your comments to ISPE for consideration:

  1. Comments should provide technical, scientific feedback to help the agency improve the document, and must include sound justification for any suggested change(s).
  2. Language appropriate for a business interaction should be used.
  3. Comments must be specific and include language that could be substituted for what the regulators propose. For example, a comment of “This is unclear” without providing an explanation and proposed replacement language will generally be eliminated.
  4. Comments should be limited to what is in contained in the document and should not introduce additional regulations to the document. Comments proposing additional regulations will be eliminated from consideration.
  5. If the guidance is a revision to a current guidance, focus comments on the new items in the regulation/ guidance rather than on the existing sections that remain unchanged (applies to documents which have been previously released by the agency). This is generally most relevant for EMA publications.
  6. Identify either the line or section on which you are commenting. In most cases the comment template will provide the structure.
  7. Provide the information requested in each column of the comment template. Comments lacking any requested information will be eliminated from consideration.
  8. If the incorrect grammar in a document could result in a misinterpretation of the requirements, then please note it. If not, and if there are many grammatical errors, a single suggestion that the “…grammar should be reviewed and edited as necessary prior to issuance of the final document” is an appropriate comment to be made one time.
  9. When making reference to other regulations/guidance, be specific and provide the official title and publication date where relevant either within the text or as a footnote.
  10. Avoid comparing the document under consideration to a similar one published by another regulatory authority. While this is important to do internally within a company, it’s not generally met with any favor by the regulatory authorities.
  11. Check and correct grammar, punctuation and spelling before submitting for review. Comments should be publication-ready when you are done.

The ability to comment on draft regulations is an individual Member benefit. The comments you submit are assumed to be your own, rather than those of your company.

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