Comment from University of California system

AnonymousOpposeAcademic
Summary: The University of California system argues that the proposed guidance incorrectly equates all IND safety reports with "unanticipated problems" requiring IRB reporting. They request that the FDA restore a risk-based filtering approach to prevent IRBs from being overwhelmed by high volumes of non-actionable safety information.
Please see attached letter sent on behalf of the University of California system.

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