Under Section 902 of the Food and Drug Administration Reauthorization Act (FDARA) of 2017, the FDA is required to annually publicly report information regarding certain statistics on inspections of facilities associated with the approval of drugs and devices and the impact that they might have had on delaying applications. The calendar year 2017 report has recently issued and the full report can be found here.
Despite being the co-leader and taking the number one or two spots in Warning Letters received with India for the last few years, China had made great strides in obtaining ANDA approvals. According to an article by Jin Zhang M.D., Ph.D, on PharmaExec.com (here), Chinese firms received 38 ANDA approvals in 2017 (that is 5% of all approvals for the for FY 2017),
In June of 2017, FDA released a document entitled “Integration of FDA Facility Evaluation and Inspection Program for Human Drugs: A Concept of Operations.” This white paper/concept of operations (ConOps) reviews the coordinated operational efforts between the Center for Drug Evaluation and Research (CDER) and the Office of Regulatory Affairs (ORA).
The anticipated outcomes of the operating model will enable FDA to meet new challenges presented by the complex pharmaceutical industry intricacies.
Today, the AAM is providing written testimony to the Committee on Energy and Commerce Subcommittee on Health addressing Combating the Opioid Crisis: Prevention and Public Health Solutions, the full text of which can be accessed through the AAM website (here ).
The testimony addresses the following major points.
- It is critical that we combat the misuse of prescription medication while maintaining legitimate,
Since January 2018, the number of ANDA approvals has slowed dramatically. In the first three months of FY 2018 (beginning in October 2017), ANDA approvals were averaging 83 a month. The monthly average for January and February was 28.5.
We know that the slowdown in approvals was due in large part to the change in documentation requirements for elemental impurities (EI) in all applications.
Today, the FDA released a new report titled Activities Report of the Generic Drugs Program (FY 2018) – GDUFA II Quarterly Performance (here) which has some new figures we have not seen in any form before. The new information includes mean and median approval time by cohort action for both original and tentative approvals (see chart below).
Even though the slowdown in ANDA approvals, attributable to the issues of elemental impurities, has dampened the first two month of 2018 (here), the number of first-time generic ANDA approvals seems to be higher than would be expected. FDA reported 10 first-time generics (note that there may be multiple reports for the same drug if multiple applicants obtain approval on the same day) through March 8,
The Office of Generic Drugs (OGD) posted its updated Dashboard for ANDA workload activity on Friday. The new posting is current through the first quarter of FY 2018 as of January 1, 2018.
Original ANDA Activity for Pre-GDUFA Year 3 Application Cohort
Total Original ANDA Workload Activity for All Unapproved Applications
As noted in a previous blog post (here), I did not expect ANDA approvals to reach anywhere near normal levels for a few months. Since that post, OGD has posted a few more approval actions; the official numbers for February were reported today at 32 full approvals and 5 tentative approvals (as opposed to 29 and 4,
Even with this season’s flu season past its peak, FDA is warning consumers about potential fraudulent product touted as curing or lessening the flu. The FDA health fraud alert (here) warns consumers to be aware of fraudulent product claiming to treat, prevent, or lessen flu symptoms. In addition, they also warn patients to be wary of online pharmacy sites that may offer unapproved or fraudulent anti-viral products.
The US FDA just released their Guidance for Industry titled “E6(R2) Good Clinical Practice: Integrated Addendum to ICH E6(R1)” (here). The guidance provides a path forward for the mutual acceptance of clinical trial data across regulatory authorities from Canada, the European Union, Japan, Switzerland, and the United States.
The guidance clearly identifies the added revisions,
According to the FDA all Approvals list (here), approvals for February 2018 did inch up a bit to 29 full approvals and 4 tentative approvals, but they are still far below the OGD norm. We had previously predicted that it would take about 3 months before the approval train got back on track,
The FDA has issued a guidance (here) that provides clarification on the definitions of suspect and illegitimate products under the Drug Supply Chain Security Act (DSCSA). The definitions are designed to help those in the supply chain better and more accurately characterize problem products they may uncover.
The guidance provides the following definitions:
SUSPECT PRODUCT—The term ‘suspect product’ means a product for which there is reason to believe that such product —
(A) is potentially counterfeit,
Getting back to the elemental impurities (EI) issue, we received additional interesting feedback from one ANDA sponsor. They said sometimes “this stuff gets tricky.” The sponsor related a situation of a capsule ANDA product that could be administered multiple times a day at high maximum daily dose. The empty capsule shell had the standard limit for lead;
As the compounding Industry awaits the next round of Guidances from FDA on using bulk drug substances, one point of controversy appears to be the fairness of compounding for 503A and 503B entities. The most recent Guidances for Compounding from Bulk Drug Substances are: