The Lachman Blog

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07
Apr
Pattern obtained by superimposing black numbers on multicolored background. This is obtained by multiple colors paint watercolor technique on paper.

Unofficial March 2022 Approval Action Estimates

March ANDA full‑approval actions (reported thus far) sit at sixty‑three, the second highest total this fiscal year (FY), eclipsed only by the sixty‑seven full‑approval actions in November.  That’s the good news!  The OGD only issued four tentative‑approval (TA) actions in March, the lowest number this FY (the previous range was eight in November to twenty‑two […]

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06
Apr
Hand Holding a Chemical Solution Test-tube in a bio-Chemistry DNA Research Laboratory

ICH Q14: Analytical Procedure Development and Revision of Q2(R2) Analytical Validation

The ICH has developed a draft of the new ICH Quality Guideline, ICH Q14, Analytical Procedure Development, and revision of ICH Q2(R2), Guideline on Validation of Analytical Procedures, both endorsed on March 22, 2022 for public consultation.  The draft, along with other ICH guidances on validation and analytical procedures, can be found here. The draft revision of […]

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06
Apr

Some Interesting Takeaways from PDA Meeting Day 1

The theme for the PDA annual meeting this year is “Agility in the New Normal.”  The plenary address kicked off the meeting with an interesting presentation by Dr. Jeffrey Baker, Senior Fellow, National Institute for Innovation in Manufacturing Biopharmaceuticals (NIIMBL), titled “Pandemic Response, Regulatory Rubric, and the Nature of Rubber Bands.”  He spoke about the intrinsic […]

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05
Apr
Close-up medical syringe with a vaccine.

Compounders of Sterile Products Remain on FDA’s Radar

In the past six (6) months, FDA has issued two (2) Alerts (here and here), for patients and caregivers to not use sterile products manufactured by the two companies cited in the alerts. One company compounds product for human patients, and the other for veterinarians and animals (pet owners, beware). In that same 6-month period, […]

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29
Mar
First

Update on First Generic Approvals in Calendar Year 2022

After almost three months of calendar year 2022, the OGD is reporting twenty‑two first-time generic approvals.  That seem like a whole lot but remember that if there are multiple first‑to‑file or first‑to‑approve ANDAs (which can sometime happen) for the same drug product, all of those that receive final approval on the same day are counted […]

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25
Mar
Female Chief Analyst Holds Meeting Presentation for a Team of Economists. She Shows Digital Interactive Whiteboard with Growth Analysis, Charts, Statistics and Data. People Work in Creative Office.

OGD Posts Official February Approval, CRL, and Receipt Numbers and Updates January Stats

We were close with our estimates for February approval actions, but the FDA reported one fewer full-approval action than we did (fifty-nine vs. sixty) and, upon review, note that it was because one of the ANDAs was listed in a separate line item as an action.  Sorry we missed that!  Of the fifty-nine full-approval actions, […]

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25
Mar

March 31 End Date for Alcohol Hand Sanitizer Distribution Under Temporary Policy

In an announcement today, the FDA reminded manufacturers of alcohol-based hand sanitizers that they can no longer distribute products made under the temporary policy, which was withdrawn on December 31, 2021 and gave manufacturers until March 31, 2022 to comply (see the announcement here). The Agency notes that distribution from manufacturers to all outlets, which […]

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22
Mar

Deficiencies Abound – FDA Reports on ER and DR Application Study – Why?

The FDA released a summary table from a study report that was designed to help applicants for extended-release (ER) and delayed-release (DR) products; the FDA is aware of the types of deficiencies that are being seen and is making an effort increase the first-cycle approval rate for these products. The report summary (here) covers 186 […]

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21
Mar
The FDA Inactive Ingredient Database (IID) - Lachman Consultants

The Agency Requests Comments on IID – Will Changes Help or Hinder Drug Development?

In the prepublication of the Federal Register today, the FDA asked for comments on issues related to trying to reduce the confusion on maximum daily intake (MDI) and maximum daily exposure (MDE) limits in its Inactive Ingredient Database (IID).  The industry uses the IID to identify the level of inactive ingredients that may be safely […]

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