The Lachman Blog

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21
Apr

The Hammer Comes Down on Hydroquinone Cream

Used for years as an “unapproved” drug for lightening of skin color, the FDA issued warning letters to twelve firms selling the drug, telling them that hydroquinone is not generally recognized as safe and effective. On August 29, 2006, the FDA issued a Notice of Proposed Rulemaking that would establish that over-the-counter (OTC) skin-bleaching drug […]

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19
Apr
Continuous Manufacturing and its Regulatory Challenge Image

Particles, Particles, Particles – Some Have a Game Plan

During day 2 of the PDA conference, there was a very enlightening session called “Game Plan: Progress to the Next Stage of Contamination Control.”  Anne Marie Dixon-Heathman, President of Cleanroom Management Associates, Inc., gave a presentation called “Contamination Control: A new approach to the Reduction of 5-micron particles.”  She discussed product loss resulting from five-micron […]

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19
Apr

February 2022 OGD Stats Come into View as Agency Updates Report

The OGD updated its usual February statistical report late yesterday (April 18, 2022) to complete the month’s reporting.  To start out with a bit of a startling number, February saw nine ANDAs issued refuse‑to‑receive (RTR) letters.  This is triple the number in any month this FY (only three RTRs were reported in each of the […]

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15
Apr

MaPP Out – What Constitutes a Complex Generic Drug? FDA Explains

On April 15, 2022, FDA published a Manual of Policy and Procedures (MaPP) that outlines the FDA thinking on what constitutes a complex drug product for purposes of classification.  A MaPP, as you know, is not an industry tool, but rather an instruction to FDA staff as to the policy and procedure that they  utilize […]

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14
Apr

FDA Issues Final Guidance on BA Studies in INDs and NDAs

Today, the FDA published the final guidance titled “Bioavailability Studies Submitted in NDAs or INDs — General Considerations” (here).  The final guidance comes after the FDA incorporated comments that it received on the draft of the same name issued on February 26, 2019.  That 2019 draft guidance replaced the March 2014 guidance titled “Bioavailability and Bioequivalence Studies […]

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13
Apr

FDA Has Hinted at It, You Have All Been Waiting, and Now It Is Here – pH adjusters May Be Put to Bed!

Yes, you heard me right; after years of problems caused by those pesky pH adjusters, there is a way around the regulations (and by the way this avenue has always been available for the Agency to utilize).  In a pre-publication of the Federal Resister (here), the FDA says “an ANDA applicant for a drug product […]

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11
Apr

The Hunt for the Elusive TE Rating for Certain 505(b)(2) Applications – So What’s Holding Up the FDA?

The 505(b)(2) application is really a hybrid of a New Drug Application (NDA) approved under Section 505C of the FFDCA  Act (the Act) and an Abbreviated New Drug Application (ANDA) which is approved under Section 505(j) of the Act.  The (b)(2) pathway was a creation born out of the Hatch-Waxman Act of 1984. It permits […]

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