Thought FDA Was Tempering Back Its Oversight and Enforcement of Compounding Operations? Think Again!

Commissioner Dr. Scott Gottlieb shared FDA’s 2018 Compounding Policy Priority Plan (here) providing an overview of the Agency’s key priorities to implement (and enforce) the federal law on compounding (Drug Quality and Security Act [DQSA], signed into law November 2013). He also states that this plan advances FDA’s mission to protect the health and safety of the public.

Guidance Agenda New & Revised Draft Guidances CDER Plans to Publish During Calendar Year 2018

FDA listed 106, either new or draft and/or revised draft guidances that it plans to issue in CY 2018.  This is quite an ambitious agenda!  This is a yearly exercise that FDA does and they have a tendency to come close to meeting their projections; be sure to review the entire list (here) to see if some of your interests will be met or augmented by some additional Agency guidance.

Elemental Elements Appear to Sink January Approvals

On January 11, 2018, we went out on a limb prognosticating that the very low numbers of ANDA approvals in January might be linked to a new USP requirement on documentation of elemental impurities that went into effect January 1st (see post here).  Since that time, the number of approvals has jumped from 2 to 4 (as posted on the FDA All Approvals site [here] through January 16th) but,

Never on Sunday!?

The proverbial title of a 1962 hit song by Petula Clark is something that piqued my curiosity today.  And yes, I am that old (I was 13 when that song came out and I loved to play with my pet dinosaur).  Anyway, I digress!  The reason I bring up “Never on Sunday” is, because, as I flip through the FDA’s All Approvals list,

First Quarter FY 2018 ANDA Approvals, Receipts and More!

Well, the first quarter of approval actions for original ANDA and receipts are in the books.  We reported late last week that OGD fully approved 78 ANDAs and tentatively approved 19 ANDAs – well, we were as close as we ever have been, estimating using numbers derived from various FDA statistical reports… and the official numbers for November 2018 are – 78 full ANDA approvals and 20 ANDA tentative approvals for a total of 98 approval actions. 

DUE FEBRUARY 14, 2018 – One-Time Report on Marketing Status Required by FDARA- Don’t Forget!

To reiterate our post of December 27, 2017 (here), please start working on your one time report on the marketing status of your products listed in the Orange Book.  The deadline is approaching and FDA even republished its advice to industry (here) again today!

Don’t be left without a retort – be sure to submit your report!  

Draft Guidance and a MaPP to Help Firms and Reviewers Get It Right the First Time (or Second Time)

Today, the FDA issued a draft guidance entitled “Good ANDA Submission Practices” (here) along with a new Manual of Policy and Procedure (MaPPs) 5241.3, entitled “Good ANDA Assessment Practices: Manual of Policies and Procedures.” These establish good ANDA assessment practices for the Office of Generic Drugs and the Office of Pharmaceutical Quality to increase their operational efficiency and effectiveness.

New Year – New Class Labeling for Combined Hormonal Contraceptives

It has been quite a while since FDA totally updated the class labeling guidance for combined hormonal contraceptives (CHC).  FDA notes “this newer CHC labeling may be different from the labeling for some older CHC products. The updates to this guidance set forth labeling recommendations that represent newer class labeling that should be included in all CHC prescribing information consistent with the labeling requirements set forth in the PLR and PLLR (21 CFR 201.56 and 201.57)…”  There have been some minor modifications such as the “Content and Format of Labeling for Human Prescription Drug and Biological Products;

One-Time Report on Marketing Status Required by FDARA – Are You Ready?

After the glow of the holiday season, and after the big bowl games and national football championship, you better get the team prepared to file your one-time report of the marketing status of every one of your NDA and ANDA products.

FDARA requires every firm to submit the one time written report telling FDA if:

  1. the NDA or ANDA holder’s drug(s) in the active section of the Orange Book are available for sale;

First Time Generic Approvals 2013-2017

 

It is interesting that the FDA provides reports of first generic approvals by calendar year, but activity by fiscal year.  Today we will look at the last 5 calendar years of first approvals and try to make some assumptions of what these numbers reflect in the scheme of generic approvals in general.

Final Rule on Surgical Scrubs, Preps, and Hand Washes for OTC Use – Well, Almost!

FDA published a Final Rule (here), finding that 24 ingredients in the proposed monograph, “Health Care Antiseptics; Topical Antimicrobial Drug Products for Over-the-Counter Human Use,” are not considered,  or generally recognized, as safe and effective (GRAS/GRAE) for OTC use.   However, as noted in the Rule, the FDA has deferred regulatory action on 6 active ingredients: benzalkonium chloride,