CMC Draft Guidance to Better Define Changes That Must Be Reported to FDA – Clear as Mud

Industry does not always get either the filing type or the need to file the change correct and, sometimes, due to an overabundance of caution, makes supplemental submissions when they may be able to either report the changes in an Annual Report or may not need to report the change at all, but manage it under their Pharmaceutical Quality System (PQS).

CMC Draft Guidance to Better Define Changes That Must Be Reported to FDA – Clear as Mud

Industry has been dealing with deciding which post-approval changes need to be reported to FDA, based on a series of Guidance documents (i.e., SUPAC-IR, the three Changes to Approved Application documents, CMC Post-Approval Changes to be Documented in Annual Reports) and, of course, the regulations at 21 CFR 314.70 and 601.12.  Industry does not always get either the filing type or the need to file the change correct and,