The Lachman Blog

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07
Oct

Managing Risks of an Outsourced Facilities Management Program Webinar

Join Lachman Consultants’ Data Integrity Consultant Patrick Day for a live webinar, Outsourced Facilities Management. The 90-minute session will be held on November 9th at 10:00 am EST and November 16th at 1:30 pm EST. A manufacturing operation is only as good as the facility that supports it. As more businesses outsource their facilities management […]

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06
Oct

GDUFA User Fee Rates Will Publish Officially on October 12 in the FR – Here Is a Preview

Just after we posted the blog about the other User Fee programs from the prepublication of the Federal Register, we receive an email from FDA indicating that the Fee Schedule was available, but there was a problem with the FR publication (here). Here are the new FY 2023 Generic Drug User Fees compared with the […]

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06
Oct

Most User Fees for FY 2023 Appear on Federal Register Pre-Publication Page Today – But a Glitch with GDUFA Fees?

The schedules for the 2023 Prescription Drug User Fees (PDUFA) (here), Biosimilar User Fees (BSUFA) (here), and Medical Device User Fees (MDUFA) (here) have been posted and are scheduled for final publication on October 7, 2022.  However, the Generic Drug User fees (GDUFA) FR Notice has a stark word “WITHDRAWN” on the prepublication page with the […]

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04
Oct

Facility Not Ready for Inspection Used to Get a Pass but Not Anymore!

As former OGD Director Kathleen “Cook” Uhl, MD used to say, “Read the commitment letter.”  This certainly applies for GDUFA III and in spades.  Why?  Because a number of enhancements that were made in the GDUFA III negotiations are designed to make the review process more efficient and improve the number of first‑cycle approvals. In GDFUA I and […]

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04
Oct

Connect with Lachman Consultants at the 2022 ISPE Annual Meeting

ISPE 2022 Annual Meeting Gaylord Palms Resort & Convention Center Orlando, FL October 30th – November 2nd, 2022 We are looking forward to seeing you at the 2022 ISPE Annual Meeting & Expo. This annual event will usher in a revitalized focus on excellence, modernization, and harmonization in pharmaceutical science and manufacturing. FEATURED SPEAKER Day […]

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03
Oct

The User Fee Reauthorization Passed – The President Signed the Bill Into Law – But Still No Word on Where That Leaves the Industry

While passage of the Continuing Resolution by Congress on September 30, 2022 and corresponding reauthorization of user fees for the different programmatic areas is a relief, the extremely late passage of the Bill leaves FDA and Industry in an awkward position in relation to one of the most important elements of the reauthorization-submission of applications […]

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30
Sep

To Average or Not to Average, That is the Question?

Earlier this year, we posted about FDA’s new revision for the OOS Guidance for Industry.  The new revision allows ‘averaging’ results from a pool of replicate results even though one of them is OOS for ‘certain circumstances.’  This was the most significant change in this revision.  So the question is, can you always average?  If […]

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29
Sep

Validation Still the Key to Success

The 16th annual WRIB (Workshop on Recent Issues of Bioanalysis) is being held in Atlanta, GA this week with approximately 800 attendees at the workshop.  The workshop which runs through Friday, is well represented by regulators from across globe, and industry (both from Pharma and CROs) with numerous discussions and topics for bioanalysis ranging from […]

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28
Sep

Know Your Systems!

It is evident from reviewing recent health agency citations that the FDA expects that firms have a deep understanding of any systems that generate data/records and that this is reflected in the firm’s lifecycle management of those systems. What does that mean, in a practical sense? Well, a component of this understanding must extend to […]

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