The Lachman Blog

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14
Jul

Tolling of Forfeiture – A Hint of FDA’s Thinking

Ever since the forfeiture provision related to 180-day exclusivity as it relates to the requirement that firms receive approval or tentative approval within 30 months from receipt of an ANDA, there has been some industry confusion regarding the exception of a “change in requirements” and how that might toll the 30-month provision.  Kurt Karst provides […]

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13
Jul

FDA SUPPORTS SHARING FEEDBACK ON INVESTIGATOR CONDUCT DURING INSPECTIONS

If you work in regulated industry, you will eventually be inspected by the Food and Drug Administration (FDA).  With each inspection comes an opportunity to forge good working relationships with the individuals on the forefront of your compliance status.  With so much riding on any given inspection, what do you do if problems arise with […]

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10
Jul
Draft Guidance on Changes to ANDA Labeling Where the RLD Has Been Removed from the Market Image

Draft Guidance on Changes to ANDA Labeling Where the RLD Has Been Removed from the Market

FDA issued a draft Guidance titled “Updating ANDA Labeling After the Marketing Application for the Reference Listed Drug Has Been Withdrawn” (here)  describing how and what type of changes FDA anticipates ANDA applicants to make in such situations. FDA makes clear in the Guidance that it the Guidance does not have applicability to the FDA’s […]

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08
Jul

Additional Guidance for Compounders of Commercially Available Copies of Products

Yesterday, FDA issued two draft Guidance documents that address the compounding of essentially commercially available drug products.  The two documents, one for compounding pharmacies under Section 503A of the Act (here) and the other that addresses outsourcing facilities under Section 503B of the Act (here) describe FDA’s view of how the issue of compounding essentially […]

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06
Jul
FDA’s Program Alignment: More Questions Than Answers Image

FDA’s Program Alignment: More Questions Than Answers

In February 2014, then FDA Commissioner Margaret Hamburg issued a memorandum directing all Centers and the Office of Regulatory Affairs (ORA) to develop a plan for more collaboration and efficiency in operations.  As a result of this mandate, the Centers and ORA have developed fiscal year plans to move toward a distinct commodity-based, vertically-integrated regulatory […]

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05
Jul
Its Elemental, My Dear Watson Image

Its Elemental, My Dear Watson

The FDA recently issued a draft Guidance document; entitled “Control of Elemental Impurities in Drug Products”.  This document provides guidance in light of the issuance of ICH Q3D Elemental Impurities and USP<232> Elemental Impurities – Limits and USP<233> Elemental Impurities – Procedures. USP <232>.  Upon implementation (scheduled Jan 1, 2018), USP<232> and USP<233> will replace […]

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