Boy, FDA Can Move Fast When It Wants to!

The FDA announced the approval of Narcan (naloxone hydrochloride) Nasal Spray as an alternative emergency treatment for accidental opioid drug overdose.  Previously, naloxone hydrochloride, which reverses the effects of opioids very rapidly, was available only as an injection available in a syringe or auto-injector.

In a press release issued today (here),

Real Time Release Testing – Has its Time Come?

Generally, pharmaceutical manufacturing involves laboratory testing on product sampled at the end of the manufacturing process to assure the product quality as part of the product release.  However, traditional release testing is not the only acceptable approach used to assure the quality product prior to release.  On September 15, 2015, the European Commission published a revised draft Guidance,

 FDA Quality Metrics News

On 11/11/15, at the ISPE Annual Meeting in Philadelphia, Russ Wesdyk from the FDA Office of Surveillance spoke about quality metrics. Since the FDA Metrics Guidance is still in draft and the comment period is still open, he didn’t provide any specifics about the Guidance itself. Since its issuance, industry has been studying and commenting on each and every aspect of the Guidance,

Have We Come Full Circle? 

Dr. John Peters, the newly appointed Deputy Director of OGD, just posted a piece on the FDA website on the “Importance of the Physical Characteristics of Generic Drugs”. Dr. Peters also noted that OGD has taken a particular interest in what he termed “Patient-Focused equivalence” or something that I have termed “functionality” when I have been questioned about whether the concept of generic drug “sameness” had taken on new definitions.

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. 

ISPE “Drug Shortages Assessment and Prevention Tool” is Launched Today

Today, at the ISPE Annual Meeting in Philadelphia, an important new tool in the battle against drug shortages will debut. The “Drug Shortages Assessment and Prevention Tool” drew on feedback from ISPE 2013 Drug Shortages Survey and 2014 Drug Shortages Prevention Plan, and focuses on the prevention and practical application to help industry assess its preparedness for mitigating drug shortages.

2015 ISPE Annual Meeting

Fran Zipp, President of Lachman Consultants, presented at the 2015 ISPE Annual Meeting, November 8-11 at the Philadelphia Marriott Downtown. She spoke about the launch of the ISPE Drug Shortage Assessment and Prevention Tool, on Monday, November 9 at 10:45 AM. For a preview of the tool, please see this article authored by Fran in November’s issue of Pharmaceutical Engineering.

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.