Today, the FDA issued Revision 1 to the above-referenced guidance. According to the Federal Register notice announcing the availability of the revision, “[T]he draft guidance announced in this notice revises and replaces the draft guidance for industry on ‘Assessing User Fees under the Generic Drug User Fee Amendments of 2017.’ This draft guidance addresses changes […]
We are pleased to announce that Michelle Ryder has accepted the position of Principal Consultant in the Regulatory Practice at Lachman Consultants, effective October 28, 2019. Ms. Ryder is a seasoned Regulatory professional with more than 20 years of experience in the pharmaceutical industry. She has provided strategic leadership and plans for ANDA, NDA, and […]
Drug shortages have been in the headlines for years but getting them under control has proved to be a complex, multifaceted problem. Reports of critical shortages for chemotherapeutic agents, saline solutions, other injectables, and oral medications have lead healthcare providers oft times to seek other options for therapy. There has even been one firm created […]
I have recently touched upon the subject of nitrosamines in drug products as part of a blog on Extraneous Peaks (here). The concern about nitrosamines in drug products continues to grow, and it will be a significant challenge for the regulators and pharmaceutical industry to establish meaningful policies and procedures to ensure there are no […]
In two separate Federal Register (FR) Notices on the FR prepublication page (here and here), the FDA proposed to withdraw approval of two ANDAs based on lack of confidence in the bioequivalence data contained in the applications. The concern relates to a problem at a bioequivalence testing laboratory. The Notices state: “In May 2010 and […]
The FDA issued a revised draft guidance titled “Drug Products Labeled as Homeopathic Guidance for FDA Staff and Industry” (here) describing the FDA’s proposed risk-based enforcement approach to homeopathic products. This compliance guidance represents current Agency thinking after comments were reviewed based on the initial guidance (here) that was issued in December 2017. The document […]
Well, another full FY has come and gone and OGD has posted the rest of its FY statistics. Let’s take a look at how this full second year of GDUFA II stacks up with the first year of GDUFA II and journey back a bit to GDUFA I for certain metrics to see what we […]
FDA published a revised draft guidance titled Postmarketing Studies and Clinical Trials—Implementation of Section 505(o)(3) of the Federal Food, Drug, and Cosmetic Act Guidance for Industry. If you have any post approval study requirements for any of your products, you should pay close attention to this document. In describing the document, the Agency says: “This […]
The FDA released a final Q&A document titled “Identification of Manufacturing Establishments in Applications Submitted to CBER and CDER: Questions and Answers” that provides answers to some of the most frequently asked and problematic questions raised by incomplete manufacturing, testing, packaging, etc. The document provides specific guidance on what, where, and how to list such […]
A new draft guidance titled (quite originally) Drug Master Files (here) has replaced the Drug Master Files: Guidelines that was published in 1989. There have been many changes to the requirements and procedures for DMFs based on new laws, policies, and procedures, as well as procedures associated with GDUFA commitment letters for ANDAs, and (of […]
