OGD Senior Management Responds to Yesterday’s Post

On Monday we posted about an issue that was brought to our attention relative to OGD’s position on goal date assignment, or lack thereof, to an ANDA with unresolved eCTD problems.  We provided examples of some of the issues that firms were finding and we found that while there is merit to asking firms to fix their submissions if problems are found in the review,

CDER Outlines Proposed Guidance Documents it Proposes to Issue in 2016

On Friday January 22, CDER issued its yearly document outlining what Guidance documents it hopes to issue in 2016.  This yearly wish list is always a highlight of the beginning of every calendar year.  The document identifies either new guidance documents FDA hopes to release, as well as those it plans to revise.  This year the guidance agenda has 15 different categories and lists 102 different guidance documents it hopes to issue this year. 

Health Fraud – Dietary Supplements Warning Letters


A little more than a year ago, I gave a presentation on FDA hot topics.  One of the areas that was identified in my presentation was a potential for an increase in FDA enforcement efforts relative to dietary supplements, their claims, and the issues of new drug claims. I stumbled across a posting on the FDA webpage that gave examples of dietary supplement Warning Letters that were identified by FDA under the general classification of “Health Fraud”.

The Battle Over “Natural”


I usually cover drug and device issues in this blog, but today, I had some “food for thought” as I read a Federal Register Notice (here), in which the FDA is asking for comment on what the term “natural” should mean when used in food products. It seems that over the years many have weighed in on what the definition should be and some even believe that the term should be banned from use in the food industry because it has no standard or defined meaning. 

Sit! – Stay! – No IND Needed as Part of Guidance Document is Stayed

Last Friday, FDA published a Notice in the Federal Register (here) relative to staying a portion of its September 2013 Guidance Document titled Investigational New Drug Applications (INDs) – Determining Whether Human Research Studies Can Be Conducted Without an IND.  The Agency indicated that, based on comment received on various sections of the final Guidance,

OGD Revision of BE Guidance – What Does it Mean for Product Development and Approved Products?

How does the Office of Generic Drugs (OGD) make a determination to revise an existing bioequivalence (BE) guidance? What happens to the requirements for drug product under development or those products that are approved when a BE guidance is revised? These questions were addressed by Dr. Robert Lionberger and Dr. Larissa Lapteva in a session at the GPhA Fall Tech Conference.

Controlled Correspondence Responses Beat GDUFA Goals

As you know, the issue of controlled correspondence has historically been a contentious issue between the Office of Generic Drugs and the generic industry mostly related to timing of the response. The situation is not different today but the contention addressed today is more about the new definition of controlled correspondence and who may submit them.

OGD Provides Updates at the GPhA Fall Tech Meeting

Dr. Kathleen Uhl (Cook), Director Office of Generic Drugs (OGD), provided an excellent update on OGD’s progress under GDUFA. There were a number of interesting charts that described approvals, receipts and actions that defined what Cook called the “In Box” (what’s coming into OGD) and “Out Box” (productivity or what is going out of OGD).

Another 70 Month for ANDA Approval Actions

The Office of Generic Drugs (OGD) is starting off FY 2016 at the same level that they ended FY 2015, with a total of 70 approval actions, one less than September’s record total.  The breakdown is- 49 full approvals and 21 tentative approvals (TA).

While I am certain that industry would like to see more full approvals,

The Ying and Yang – CRLs vs IRs ECDs and Approvals

Complete Response Letters (CRLs) (remember those letters where FDA was going to respond all at once with Division level review and you were not going to get any more discipline specific letters?) are a harbinger of “approval issues that are too great to resolve through other means”. Yes, that’s right, expect a CRL if issues are complex or too vexing to permit approval.