The Lachman Blog

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17
Jan
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New Release: Global Drug Supply Chain Diversification Alert White Paper

Lachman Consultants has continued its active engagement with efforts to combat the global drug supply chain shortages.  Despite the FDA’s significant success in helping to prevent 236 drug shortages in 2023, the problem persists and may be about to get worse.  The current problem, external environment, and emerging risks are highlighted in a recent publication […]

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16
Jan
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Cleaning Validation Documentation and Monitoring

Some common FDA 483 citations pertaining to cleaning validation are regarding consistency in monitoring of cleaning and the complete documentation of cleaning.  It is critical to implement a robust monitoring process that is supported by detailed documentation.  Ensuring that the SOPs for all aspects of cleaning are clear, detailed, and contain illustrations (where appropriate) to ensure […]

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14
Jan
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Is the “Skinny Label” On the Verge of Protection? Is this the last Chapter?

For those of you that have been following the saga of the attack on the skinny label, we may be getting close to a solution.  Remember that a skinny label is labeling that cuts out a particular use or information protected by patent or market exclusivity of the branded product.  This allows for a generic […]

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14
Jan
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The FDA’s Spotlight on CDER Science – Nitrosamines and the Acceptable Intake Approach

In the latest CDER Science Spotlights, available (here), the FDA provides some insight into the development of the Carcinogenic Potency Categorization Approach (CPCA) to determine recommended acceptable intake limits of N-nitrosamine impurities in drug products.  The latest revision of the Nitrosamine Impurity guidance updated in September 2024 (here) provided better integration of the overall assessment […]

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09
Jan
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November 2024 Official OGD Statistics Published

The OGD published the second month of the Fiscal Year (FY) 2025 statistical report titled, Generic Drugs Program Monthly and Quarterly Activities Report (here).  There is some continued good news and also some troubling news in the report. On the positive side, we previously reported (here) in our unofficial posting, the full approval actions as […]

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08
Jan
The Promise of ACNU A New Era in Self-Care and Market Innovation - Lachman Blog image

The Promise of ACNU: A New Era in Self-Care and Market Innovation

The pharmaceutical industry is entering a transformative era with the Food and Drug Administration’s (FDA) newly established pathway for nonprescription drug products with an Additional Condition for Nonprescription Use (ACNU), with the final rule announced in a December 2024 Federal Register Notice (here). This new rule aims to broaden consumer access to safe and effective […]

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06
Jan
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December 2024 Brought Gifts for ANDA Approval Actions (Unofficially)

The OGD had some late-month stocking stuffers as it issued 68 full-approval actions and 16 tentative-approval actions for a total of 84 approval actions in December.  Despite the hectic holiday schedule, if these numbers are confirmed in the official totals for the month, it would mean that the OGD managed to tie the second highest […]

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