Reduced testing of Active Pharmaceutical Ingredients (API), excipients, and other raw materials can be a valid approach to gaining overall efficiencies in the pharmaceutical quality control laboratory. However, the choice of tests to perform and the justification for choosing those tests are key elements of operating a compliant Reduced Testing Program that is also scientifically sound.
The GDUFA II reauthorization process involved a lot of agreements from the FDA. One of those agreements was for the Agency to publish a guidance on changes to drug substances that addressed the type of changes, their categories for submission (PAS, CBE, CBE-30, or annual report) and the necessary documentation that must be submitted to support the proposed changes.
The GRx+Biosims Conference held in Baltimore, MD from September 5-7, had a session on the GDUFA II Pre-ANDA Program for Complex Products on the last day, presented by FDA.
The presenter, Kris Andre, Associate Director of Regulatory Affairs, Office of Research and Standards, Office of Generic Drugs (OGD), discussed in detail the logistics and agency’s expectations related to the meetings for complex generics.
I know that the flag was raised in victory when the first generic of EpiPen was approved. Not many people outside those familiar with the plight of complex generic products could understand how or why it took so long for a generic version of that product to make it through the approval process. This is discussed in an interesting article by Avik Roya,
FDA’s User Fee Staff provided an overview of the progress and implementation of the first year of GDUFA II and BsUFA II user fees during the afternoon session of the second day of the GRx +Biosims Conference held at Baltimore, MD from September 5-7. The presentation recapped how the user fee structure for GDUFA II an BsUFA II changed,
On the second day of the first annual 2018 GRx+Biosims Meeting in Baltimore, MD held from September 5-7, 2018, Kurt Karst, JD and Mark Schwartz, JD (Directors, Hyman, Phelps & McNamara, P.C) provided a very informative overview of cGMP trends and emerging legal issues concerning GDUFA and FDARA. The on-going modernization of the generic drug approval process has presented industry with new legal considerations.
The GRx+Biosims Conference held at Baltimore, MD from September 5-7, had a panel discussion regarding Successfully Managing Priority Generic Submissions on September 6th. The panel members were representatives from the industry.
Discussions centered around the experience with priority submissions in the first year of GDUFA II. The consensus was that the submission of PFC (pre-submission facility correspondence) related to the priority submissions were labor intensive.
With eCTD submission format becomming binding as of May 5, 2017 for NDA, BLA, and ANDA and May 5, 2018 for Commercial IND and Master Files, the number of submissions to the FDA in eCTD format has significantly increased. According to Jonathan Resnick of the Office of Business Informatics (OBI), CDER received nearly 180,000 eCTD submissions in 2017.
The Association of Accessible Medicines (AAM) meeting in Baltimore this week saw a number of FDA presentations. One that caught my attention was presented by Sarah Barkow, Ph.D., Acting Director, Manufacturing Quality Guidance and Policy Staff, Office of Manufacturing Quality in CDER. It had to do with data integrity.
Dr. Barkow noted, “about 40% of OMQ’s warning letters include data integrity lapses.
Historically, the Office of Generic Drugs (OGD) has classified major/minor amendments on the time necessary for review. Minor amendments required minimal review, while major amendments required extensive review. If there was an issue with a facility (e.g., cGMP), the old Deficiency Letters (DLs) and Complete Response Letters (CRLs) used to state that the firm should not respond to the letter until the facility issues have been resolved.
According to our best calculations and current data on the FDA “All Approvals” page (here), it appears OGD has approved forty-seven ANDAs and tentatively approved eleven ANDAs in the month of August. These numbers are far below the record breaking ninety-six full and thirty tentative approvals seen in the month of July.
As we know July was a record breaking month for approvals as reported here, but it was also a record shattering month for Complete Response Letters, beating the October 2017 previous total of 325 with a whopping 357 CRLs. This may be a little disturbing as the trend in FY 2018 is for an overall increase in CRLs.
I just searched through 643 hits on Regulations.gov for 505(j)(2)(C) petitions. Granted, all of those were not actually for ANDA suitability petitions under the citation listed above, but most were. The good news is that the industry still submits these petitions (an ANDA suitability petition requests a change from a reference listed drug in strength,
The Food and Drug Administration announced yesterday that the Biosimilar User Fee (BsUFA) program invoices for Fiscal Year (FY) 2019 were emailed to sponsors on August 27, 2018. Sponsors should expect to receive their invoices by August 29, 2018. This follows the PDUFA FY 2019 PDUFA program fee invoices which were emailed on August 15,
July was an amazing month for generic drug approvals with a total of 126 (ninety-six full approvals and thirty tentative approvals). We were wondering whether such a figure would be sustainable or whether it might empty the “ready-to-approve” bucket at OGD. We know the effort it takes to pump out that many applications and refill the pipeline and get those approval packages lined up for the next month.