I don't think BOT are free of blame here.
They make it pretty clear.
Last page of their guidelines. (Portrait format)
Instructions for Use — Patient Labeling for Human Prescription Drug and Biological Products — Content and Format
https://www.fda.gov/regulatory-info...ug-and-biological-products-content-and-format
PDF: https://www.fda.gov/media/128446/download
They also seem to have overlooked the advice about reverse typeface, amongst a few other things.
webinar, page-51
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