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03
May
April 2024 Unofficial ANDA Approval Actions – Back on Track - Lachman Blog

April 2024 Unofficial ANDA Approval Actions – Back on Track?

Well, it must be true that April showers bring May flowers. A shower of approvals in April is something we haven’t seen in a while. The OGD unofficially issued sixty-eight full-approval actions and eleven tentative-approval actions for a total of seventy-nine for the month. We still must wait for the official numbers to be posted, […]

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01
May
Are You Still Using Your Grandma’s Container-Closure Integrity Approach - Lachman Blog

Are You Still Using Your Grandma’s Container-Closure Integrity Approach?

Container Closure Integrity (CCI) testing is a central aspect of contamination control for a product. Contamination control strategy begins with the design, qualification, and validation of a facility, equipment, and processes. Product containers and closures are a crucial element of contamination control. Package integrity is the ability of the package to prevent loss, maintain sterility, […]

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30
Apr
More on the Final Rule on ANDAs and 505(b)(2) Applications Image

Final Rule on IVDs Issued, Along with Two Guidance Documents 

FDA has finalized its long-awaited Final Rule on Medical Devices; Laboratory Developed Tests (here).  This Rule has been percolating within the Agency for a while and is the final step since the Proposed Rule was issued October 3, 2023.  FDA explains that since  “1976, the Medical Device Amendments of 1976 (the MDA) amended the FD&C […]

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29
Apr
Mortar and Pestle

New ISPE Guide on 503A Compounding

For anyone who wishes to gain a better understanding of all the complexities of running a 503A compounding pharmacy, a new resource is now available.  The International Society of Pharmaceutical Engineering (ISPE) recently published a new Guide titled “Guide: 503A Compounding – Regulatory Basis and Industry Good Practices for Pharmacies” (here). Some of you reading […]

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26
Apr
3d illustration of a battleship firing with heavy caliber guns

Q1/Q2 Formulation in Labeling Gets Promoted in New FDA Guidance Addressing Components and Composition in NDA and ANDA Applications

Today, the FDA has published a new draft guidance titled Content and Format of Composition Statement and Corresponding Statement of Ingredients in Labeling in NDAs and ANDA (here) that describes the FDA’s current thinking on consistency of composition statements in NDAs and ANDAs.  It provides a clear and unambiguous requirement to list both the qualitative […]

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24
Apr
Revised QA Document on Promotional Activities for Biosimilars Released by FDA - Lachman Blog

Revised Q&A Document on Promotional Activities for Biosimilars Released by FDA

Today, the FDA released a draft guidance titled Promotional Labeling and Advertising Considerations for Prescription Biological Reference Products, Biosimilar Products, and Interchangeable Biosimilar Products: Questions and Answers (here). Try saying that without taking a breath! This draft is a revision of the initial draft guidance issued on February 4, 2020 (85 FR 6201) (the 2020 draft guidance). The […]

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19
Apr
April 2024 FDA SBIA Generic Drug Forum - A Flair for the PLAIR - Lachman Consultants Blog

April 2024 FDA SBIA Generic Drug Forum – A Flair for the PLAIR

Last week, I was able to attend SBIA’s Generic Drug Forum in Bethesda, Maryland, and I’m sure that many readers of Lachman’s blog also attended virtually. The Forum offered a diverse array of presentations applicable to the generic industry at large. In this blog, I will focus on one presentation related to PLAIRs (Pre-Launch Activities […]

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19
Apr
Barriers to Parallel Scientific Advice Hurdles - Lachman Consultants Blog

Barriers to Parallel Scientific Advice Hurdles May Be Too High!

Although the pilot program for Parallel Scientific Advice (PSA) meetings with U.S. and the EMA for complex generics and hybrid products is relatively new, there have been only two requests for meeting participation thus far. According to the FDA, “The Parallel Scientific Advice (PSA) pilot program allows for applicants to engage in concurrent scientific conversation […]

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