The Lachman Blog

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07
Aug

Avoid Another Elemental Impurity Meltdown – Read the Final Guidance

After a disastrous start to the new year and the significant slowdown in approvals resulting from the OGD’s strict application of the provisions of the USP Elemental Impurity Chapter while awaiting harmonization with ICH Q3D, the approvals have begun flowing again.  There are some changes in the final guidance (here) from the draft that the […]

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06
Aug

Ready Set Go! NDC Number Change Needed in Next Ten to Fifteen years

The National Drug Code (NDC) number is a unique identifier for prescription drug products.  The format, as explained by the FDA below, will need to be changed in the coming years to accommodate the entry of new labelers into the U.S. market.  The advanced Federal Register Notice published today (here) outlines the issues and announces […]

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01
Aug

Welcome to the 21st Century – FDA Goes Greener!

On May 30, 2018, Diana Amador, Program Division Director, Office of Pharmaceutical Quality Operations (OPQO), Division I, issued a letter to “Our Regulated Pharmaceutical Industry”. This letter offers firms an opportunity to submit all FDA 483 responses in electronic format up to 100 megabytes. If files exceed 100 megabytes, they may be submitted as smaller […]

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31
Jul

Outsourcing Compounder Fees Announced for FY 2019

In a Federal Register notice today, the FDA announced the outsourcing FY 2019 fees (here) for regular and small business establishment fees and for the reinspection fee.  FDA estimates that 82 outsourcing facilities, including 14 small businesses, will be registered with FDA in FY 2019 and will be subject to establishment fees. Qualified small business […]

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31
Jul

PDUFA Fees for FY 2019 Announced

A Federal Register Notice (here) released today announced the new Prescription Drug User Fees (PDUFA fees) for FY 2019.  And while there had been a modest increase, the fact is the there is an increase signifies that there is little expectation that fees will retreat anytime in the next few years.  The PDUFA total budget […]

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30
Jul
Wooden Blocks with the text: Fees

Biosimilar User Fees Announced for FY 2019

The Federal Register notice published today (here) announces the FY 2019 biosimilar user fees. The initial Biologic Product Development (BPD) fee is due when the sponsor submits an Investigational New Drug (IND) application to the Agency or within five days after the FDA grants the first BPD meeting.  The annual BPD fee is assessed the […]

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