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Christopher Hanson advises international and domestic clients on regulatory strategies and compliance for medical devices, pharmaceuticals, biological products, cosmetics, animal products, radiation-emitting electronic products, and laboratories. His broad range of clients include large multinational companies, venture capital firms, industry associations, clinical and forensic laboratories, and development-stage companies.
Mr. Hanson has extensive experience counseling clients on interactions with state, federal, and foreign regulatory agencies, including the Food and Drug Administration (FDA), the Drug Enforcement Administration (DEA), the Federal Trade Commission (FTC), and the Centers for Medicare and Medicaid Services (CMS).
Mr. Hanson regularly assists clients with drafting state, federal, and foreign legislation as well as preparing public comments for agency rulemakings, guidance documents, advisory committees, and other public policy venues. He provides strategic advice and regulatory due diligence to support corporate transactions and securities filings. He also has experience advising in enforcement matters and conducting global internal investigations and audits of the firm’s life science clients in the United States, Asia, Australia, Europe, and Latin America.
Mr. Hanson is an active firm member having served as Vice Chair of the Summer Associate Program (2015, 2016) in the Washington, DC office. Additionally, he pursues extensive pro bono work related to the lesbian, gay, bisexual, and transgender (LGBT+) community and speaks across the country on issues of LGBT+ diversity and inclusion in the legal community.
He is a graduate of Northwestern University School of Law, where he was elected to the Order of the Coif and graduated in two years. He holds a Masters of Divinity degree from Harvard University, where he was a Presidential Scholar, and an honors undergraduate degree from Yale University. Mr. Hanson previously served as the Chairperson of the Harvard Divinity School Alumni/ae Council.
- Advised global healthcare company GSK on FDA and CLIA regulatory components of the company's $300 million equity investment and collaboration with 23andMe.
- Co-drafted legislation signed into law in California and New Jersey concerning the regulation of state clinical laboratories.
- Successfully petitioned FDA for removal of certain Class II medical devices from an import alert.
- Assisted diagnostics manufacturer in preparing a 510(k) notification and receiving FDA premarket clearance for a Class II device.
- Represented industry association in FDA meetings regarding medical device and radiation-emitting electronic product proposed rulemakings.
- Drafted Congressional white paper and request for a hearing in response to FDA’s Notice of Opportunity for Hearing (NOOH), proposing to withdraw approval of certain new animal drug applications (NADAs).
- Represented industry association before the Division of Clinical Laboratory Improvement & Quality (CMS) and prepared public comments concerning various CLIA proposed rulemakings.
- Assisted medical device manufacturer in preparing response to FDA Warning Letter and drafting CDRH Pre-Submission (Pre-Sub) materials.
- Represented industry association in submitting public comments to Congress concerning in vitro diagnostic (IVD) draft legislation.
- Prepared responses to several FDA “It Has Come to Our Attention” (IHCTOA) letters and represented medical device manufacturers in FDA meetings.
- Assisted medical device and pharmaceutical manufacturers in preparing initial and follow-up responses to FDA Form 483 Observations.
- Advised global pharmaceutical company in interactions with California and New York state clinical laboratory regulators.
- Drafted FDA regulatory expert report and presentation for Swedish arbitration concerning certain Class II medical devices.
- Provided FDA regulatory diligence to client for $1.7 billion acquisition of a clinical-stage biopharmaceutical company.
- Prepared public comments and drafted proposed regulations on behalf of client before the Texas Forensic Science Commission.
- Wrote position papers concerning proposed legislation involving medical device and pharmaceutical regulation in foreign jurisdictions, including Canada and India.
- Conducted large-scale, internal assessment of global pharmaceutical company’s manufacturing division.
- Represented top global pharmaceutical company in internal review of procedures and policies concerning investigator-initiated trials (IITs).
- Led internal review of procedures and policies concerning product labeling for cosmetics manufacturer.
Pro Bono
- Represented Federally Qualified Health Center (FQHC) in drafting several rounds of FDA public comments and advisory committee public testimony concerning agency blood donation guidelines.
- Represented federal inmate in seeking a Presidential clemency grant.
- Successfully represented Latin American immigrant in U visa application.
- Authored white paper on behalf of global pro bono law firm analyzing how parties become signatories to intrastate peace agreements.
- Represented LGBT organization in litigation involving transgender military service members.
- Assisted LGBT organization in preparation for potential election referendum on state transgender rights law.
- Advised transgender individuals on legal name and gender change procedures in Maryland, Virginia, and Washington, DC.
- Conducted 50-state survey of Medicaid and prescriptive authority law for health care non-profit.
Memberships and Affiliations
- Harvard University, Divinity School Alumni/ae Council (Chairperson, 2016-2017) and Divinity School Bicentennial Host Committee (Co-Chair)
- Yale College, Class of 2005 Reunion Chair and Association of Yale Alumni (AYA) Class Representative
- Point Foundation, Wells Fargo Scholar and Mentorship Committee (former)
Previous Experience
- United States Senate, Constituent Services (2008-2010)
- Harvard University, Harvard Humanitarian Initiative Instructor (2008)
- Yale University, Assistant Director of Undergraduate Admissions (2005-2007)
May 20, 2020, Financial Times
Christopher Hanson is quoted in the Financial Times regarding the private sector’s undertaking of COVID-19 testing for its employees. Mr. Hanson notes that diagnostic testing “presents an array of regulatory considerations” in the U.S., such as checking whether a test has been approved by regulators. He says that even in the U.S. “the landscape is changing ...
May 18, 2020, Covington Alert
Businesses are developing plans for reopening workplaces. As they do, many employers are considering ways to determine which employees can safely return to the workplace, and what protective equipment should be provided to employees once they return. In both the United States and European Union, many of the products used in these strategies are regulated as ...
May 14, 2020, Covington Alert
The recently-enacted Coronavirus Aid, Relief, and Economic Security Act (CARES Act) added new section 506J to the Federal Food, Drug, and Cosmetic Act (FDCA). This section requires manufacturers of certain devices to notify FDA of an interruption or permanent discontinuance in manufacturing during, or in advance of, a declared public health emergency. On May 6, ...
April 1, 2020, Covington Alert
This e-alert is part of a series of e-alerts summarizing publicly available FDA enforcement letters (i.e., warning letters and untitled letters) relating to the advertising and promotion of prescription drugs, medical devices, and biologics.
March 29, 2020, Covington Alert
Medical device manufacturers are facing numerous novel legal, regulatory, and commercial issues as a result of the evolving COVID-19 public health emergency. This slide presentation addresses key regulatory considerations for medical device companies seeking to supply products that are in critical need, including the Emergency Use Authorization pathway and other ...
February 24, 2020, Covington Alert
This e-alert reviews trends emerging from warning letters and untitled letters concerning product advertising and promotion issued in 2019 by the Office of Prescription Drug Promotion (OPDP) of the Center for Drug Evaluation and Research (CDER), the Advertising and Promotional Labeling Branch (APLB) in the Office of Compliance and Biologics Quality (OCBQ) of the ...
2019, American Bar Association
Our cross-disciplinary Internet of Things initiative contributed to the ABA's first book on IoT, The Internet of Things: Legal Issues, Policy, & Practical Strategies. Laura Kim and Jennifer Johnson authored the chapter “U.S. Regulatory Framework for IoT,” with contributions from Sarah Wilson (product safety); Wade Ackerman, Elizabeth Guo, Christopher Hanson, ...
Informed Consent, Institutional Review Boards, and the Protection of Human Subjects
October 25, 2018, Food and Drug Law Institute's In-House Training Course
FDA Regulation of Medical Devices
October 9, 2018, U.S. Healthcare Compliance Certification Program
July 30, 2018
SILICON VALLEY—Covington advised GlaxoSmithKline on its multi-year collaboration with and $300 million equity investment in 23andMe. GSK will become 23andMe’s exclusive collaborator for drug target discovery programs. The collaboration will focus on research and development of innovative new medicines and potential cures using human genetics as the basis for ...
FDA Regulation of Medical Devices
June 12, 2018, U.S. Healthcare Compliance Certification Program
Informed Consent, Institutional Review Boards, and the Protection of Human Subjects
June 8, 2018, Food and Drug Law Institute's In-House Training Course
December 20, 2017, Covington Alert
On December 8, FDA addressed the agency’s evolving approach to digital health by issuing two new draft guidance documents: “Clinical and Patient Decision Support Software” (the “CDS Draft Guidance”) and “Changes to Existing Medical Software Policies Resulting From Section 3060 of the 21st Century Cures Act” (the “Software Policies Draft Guidance”). These draft ...
President Issues New Executive Order, Requires Agencies to Establish Regulatory Reform Task Forces
February 28, 2017, Covington Alert
On February 24, 2017, President Donald Trump signed an executive order entitled “Enforcing the Regulatory Reform Agenda” (the “Executive Order” or the “Order”). The Order is one of several actions the Trump Administration has taken concerning regulatory reform since inauguration.
January 17, 2017, Covington Alert
On January 13, 2017, the U.S. Food and Drug Administration (FDA or Agency) released a discussion paper synthesizing public feedback on FDA’s 2014 draft guidance documents and outlining a possible approach to regulation of laboratory developed tests (LDTs) (Discussion Paper). This approach is intended to “advance the public discussion by providing a possible ...
December 6, 2016, Covington Alert
On November 8, 2016, the U.S. Food and Drug Administration (FDA) published a final guidance titled Medical Device Reporting for Manufacturers (“Final Guidance”). The guidance explains and clarifies FDA’s interpretations of its regulations under 21 C.F.R. Part 803 for adverse event and malfunction reporting and recordkeeping for manufacturers. On November 30, ...
September 18, 2015, Covington Alert
August 21, 2014, InsideMedicalDevices Blog
August 18, 2014, Covington E-Alert
June 19, 2014, Covington E-Alert
February 24, 2014, Covington E-Alert
Section 111(d) of the Clean Air Act and State Compliance Flexibilities
January 28, 2014, Center for Clean Air Policy’s Midwest Policy Dialogue
Education
Northwestern University School of Law, J.D., 2012
- Order of the Coif
- Graduated in two years
- Point Foundation Scholarship
- Study abroad at Bucerius Law School (Hamburg, Germany)
Harvard University, M.Div., 2010
- Harvard Presidential Scholarship (2007-2010)
- Resident Tutor (Adams House)
Yale University, B.A., 2005
- Dupuy Graduation Prize for Scholarship
- Bergin Graduation Prize in the Humanities
- Hilgendorf Fellowship (Norway)
- Humanity-in-Action Fellowship (Denmark)
- Association of Yale Alumni Community Service Fellowship (Princeton, NJ)
- Study abroad at University of New South Wales (Sydney, Australia)