Regulatory Affairs

08
Sep
August 2023 Delivers for ANDA Approval Actions Unofficially - Lachman Consultants

August 2023 Delivers for ANDA Approval Actions (Unofficially)

We had predicted, based on mid-month statistics (here), that August would be a big month for approval actions and, boy, was it! The OGD issued ninety-six full-approval actions along with twelve tentative-approval actions for a total of 108 approval actions. This was the second biggest month in FY 2023, behind the 117 approval actions in March […]

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05
Sep
Guidance on Post-Warning Letter Meetings Will They Provide Some for Only a Special Few - Lachman Consultants

Guidance on Post-Warning Letter Meetings: Will They Provide Some for Only a Special Few?

The GDUFA III commitment letter (here) outlined a number of industry-requested improvements to the GDUFA program. One such request related to the age-old problem of timely resolution of compliance problems resulting in a warning letter at a facility and the clearance of that warning letter. Specifically, in section VII(D) of the commitment letter, the “FDA agreed to […]

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01
Sep
Quality Management Maturity Document Released by FDA

Quality Management Maturity Document Released by FDA

The FDA issued a White Paper titled CDER’s Quality Management Maturity (QMM) Program: Practice Areas and Prototype Assessment Protocol Development, designed as the next step in the evaluation of key quality assessments designed to identify a high level of commitment to quality management at a manufacturing firm. In the document, the FDA cautions that “Information […]

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01
Sep

OOS: Whose Line is it Anyway? The Contract Testing Laboratory’s or Sponsor’s?

When it comes to investigating OOS results, a clear line should be drawn between the responsibilities of a contract testing laboratory (CTL) and that of the manufacturer/sponsor. Before we come to the testing part, here are some questions (not all inclusive) to be asked by your firm before selecting a CTL for outsourced testing: (1) […]

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29
Aug
Vyvanse_BlogImage_LachmanConsultants

Vyvanse Shortages Should Be Resolved but What Will the Market Do?

On August 25, 2023, the Office of Generic Drugs approved a total of 14 different applications for lisdexamfetamine dimesylate products after the expiration of a patent on August 24, 2023. (This is the first time in a long while where I remember this many applications being approved on a single day.) While this is good […]

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23
Aug
Here’s a Surprise! FDA Warns About Undeclared Active Ingredients in Sexual Enhancement Products!

Here’s a Surprise! FDA Warns About Undeclared Active Ingredients in Sexual Enhancement Products!

Today FDA has warned consumers (here) that the products listed below that are offered for sale in the US contain undeclared active ingredients that can be dangerous for some users. This is not really a surprise as unscrupulous manufacturers and distributors try to cash in on patients with erectile disfunction or on users that merely […]

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22
Aug

Two Bulk Drug Substances Are Denied for Inclusion on Bulk Drug List for 503B Compounders

In a Federal Register Notice, FDA explains that ephedrine sulfate and hydroxychloroquine sulfate are not to be included on the bulk drug list for use in compounding by 503B outsourcing facilities (here). As mentioned by the Agency “[O]ne of the conditions that must be met for a drug product compounded by an outsourcing facility to […]

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17
Aug

The Curious Case of the LateCycle Amendment under GDUFA III

Many of our blog readers have likely encountered moving goal dates for their ANDAs since October 1, 2022 and the beginning of GDUFA III.  The GDUFA III Commitment Letter, available here, included several new enhancements to the generic drug user fee program as each iteration of the program has continued to do.  The changes made to promote transparency […]

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