The Lachman Blog

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13
Sep
Shot of an asian businessman shouting into a megaphone against a studio background

Now Hear This!

Reviewed “under the FDA’s De Novo premarket review pathway, a regulatory pathway for some low- to moderate-risk devices that are novel and for which there is no prior legally marketed device,” the Agency has approved an OTC software solution that is compatible with certain Apple AirPods Pro headphones and provides, according to the FDA release […]

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12
Sep

Newest Chapter in the Nitrosamine Saga – A Revised Guidance and FDA Acknowledges Their Differences

The FDA has updated the original nitrosamine impurity guidance after publication last year of Recommended Acceptable Intake Limits for Nitrosamine Drug Substance-Related Impurities (NDSRIs) (here), also known as the RAIL guidance, caused a few disconnects between the two guidances.  Now that we’ve all had more time to carefully read and absorb the updates in the […]

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11
Sep
PDA Conference Day 2 - An Overview - Lachman Consultants

PDA Conference Day 2 – An Overview

Day 2 of the 2024 PDA/FDA Joint Regulatory Conference kicked off in a similar format to Day 1 with a panel discussion, moderated by Andrew Hopkins, that delivered key messages from various FDA leaders.  An explanation of the imminent changes in the Agency’s organizational structure (CBER, CDER, and CVM) dominated the conversation.  However, an impactful response from […]

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11
Sep
PDA/FDA Joint Regulatory Conference 2024 - Day 1

PDA/FDA Joint Regulatory Conference 2024 – Day 1

It’s been a pleasure to return to the PDA/FDA’s 2024 Joint Regulatory Conference.  This is the first FDA co-sponsored conference that I’ve attended since my retirement from the Agency in 2023, and it has a bit of a high-school-reunion atmosphere for me.  I’m grateful for the friendships with my FDA colleagues that have extended beyond […]

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10
Sep
CAPAs

Effective CAPAs are the “Root” of Positive Change

CAPAs are one of the most important elements of the pharmaceutical Quality System.  During Day 1 of the PDA/FDA Joint Regulatory Meeting, Jonathan Chapman, Senior Policy Advisor at the FDA, spoke about CAPAs. Traditionally, we think of CAPAs as follows: Corrective actions are actions implemented to correct an identified problem. Preventive actions are actions implemented to […]

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10
Sep
U.S. and EU Drug Shortages - Lachman Consultants

New Risks Discovered as U.S. and EU Drug Shortage Efforts Start to Merge

U.S. and EU efforts to manage supply chain shortages are slowly converging; however, the political winds in the Rest of World (ROW) may be diluting required oversight.  Both the U.S. (Risk Management Plans to Mitigate the Potential for Drug Shortages | FDA) and EU (Shortage Prevention Plan (SPP) – template (europa.eu)) have published either a […]

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09
Sep
Scientist working doing some research at a laboratory

Does Testing into Compliance Just Apply to Sample Release Test Data?

The WHO has a draft July 2013 guidance document titled “Deviation Handling and Quality Risk Management” that addresses the concept that not all Quality Events are equivalent and provides consideration for the classification of events.  For example, an incident would be an event that does not: “…affect a product attribute, manufacturing operational parameter or the […]

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06
Sep
Half full water glass over blue background

With a Snap of the Fingers – Just Like That, August Approvals Are Back in Business

At least unofficially, it appears the August 2024 approval numbers for ANDAs have popped back up.  As of the posting on the Daily approval listing (here) and the All approvals listing (here), there were 67 full approval actions, the second highest of Fiscal Year (FY) 2024 thus far, and 15 tentative approval actions. We will […]

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