The Lachman Blog

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05
Mar
A young family sits talking to the doctor. The toddler is sat on his mother’s knee as the doctor kneels

US FDA Guidance – Good Clinical Practice: Integrated Addendum to ICH E6(R1)

The US FDA just released their Guidance for Industry titled “E6(R2) Good Clinical Practice: Integrated Addendum to ICH E6(R1)” (here).  The guidance provides a path forward for the mutual acceptance of clinical trial data across regulatory authorities from Canada, the European Union, Japan, Switzerland, and the United States. The guidance clearly identifies the added revisions, […]

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02
Mar
female mannequin hand on a pink background holding colorful pills. minimalism, place for text. the concept of fake medicines.

Defining Suspect and Illegitimate Products Under the Drug Supply Chain Security Act (DSCSA)

The FDA has issued a guidance (here) that provides clarification on the definitions of suspect and illegitimate products under the  Drug Supply Chain Security Act (DSCSA).  The definitions are designed to help those in the supply chain better and more accurately characterize problem products they may uncover. The guidance provides the following definitions: SUSPECT PRODUCT—The […]

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28
Feb
Confident business people are shaking hands after agreeing to a successful job. Business people shaking hands.Finishing up a meeting

Maybe There is a Reason After All!!

Getting back to the elemental impurities (EI) issue, we received additional interesting feedback from one ANDA sponsor.  They said sometimes “this stuff gets tricky.”  The sponsor related a situation of a capsule ANDA product that could be administered multiple times a day at high maximum daily dose.  The empty capsule shell had the standard limit […]

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27
Feb
Policy isolated on elegant green round button abstract illustration

Compounding Fairness???

As the compounding Industry awaits the next round of Guidances from FDA on using bulk drug substances, one point of controversy appears to be the fairness of compounding for 503A and 503B entities. The most recent Guidances for Compounding from Bulk Drug Substances are: Interim Policy on Compounding Using Bulk Drug Substances Under Section 503A […]

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23
Feb

FDA Warns of Potential Harm with Using Clarithromycin in Patients with Heart Disease

The new warnings which FDA says will be incorporated into both clarithromycin’s brand (Biaxin) and generics labeling come after review of a number of long-term studies revealed an increased risk of death in patients with preexisting coronary disease.  The interesting finding is that the risk is not necessarily immediate, but can occur in patients with […]

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