The Lachman Blog

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03
Mar

Final Voluntary Recall Guidance Issues

The FDA has published its guidance on Voluntary Recalls (here), revising the initial draft guidance issued April 24, 2019.  The Agency notes that “[I]n addition to editorial changes made to improve clarity, changes from the draft to the final guidance include the addition of the terms correction and market withdrawal to the terminology section, the […]

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02
Mar

If You Have a Flair for the Plair, Your Final Guidance Has Just issued!

Yesterday, the FDA issued its final guidance on the Pre-Launch Activities Importation Requests (PLAIR), a process that permits importation of unapproved NDA, ANDA and CDER-regulated BLA products into the United States in anticipation of imminent approval.  The original draft guidance was issued on July 24, 2013. The FDA says that it considered comments received on […]

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25
Feb

Maybe a First? A Cartridge Without a Device

In an FDA announcement today titled Approved First Generic for Apokyn Injection Cartridges Requires Separately Packaged Pen (here), the Agency noted that this is the first generic approved without a delivery device.  While I am aware of other FDA approvals where an off-the-shelf autoinjector was available to inject a prefilled syringe (that can be procured […]

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24
Feb

QSR – ISO Harmonization – All Things Being Equal…They Are Not – A Deeper Dive

The US Food and Drug Administration published their much-anticipated proposed rule (PR) to amend the Quality System Regulation (QSR) (21 CFR Part 820) on February 23, 2022.  After four years in the works and much debate about what the PR would include, we can finally read it for ourselves.  The question in my mind was […]

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22
Feb

Proposed Rule for Medical Devices; Quality System Regulation Amendments Officially Publishes Tomorrow

In the prepublication edition of the Federal Register, the proposed rule on revisions to the Quality System Regulation was published today and may be found here.  According to the notice, the Agency “is proposing to amend the device current good manufacturing practice (CGMP) requirements of the Quality System (QS) Regulation to align more closely with […]

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17
Feb
Caution Tape

Potential Serious Risks Associated with Compounded Nasal Ketamine

The FDA is warning healthcare professionals of potential risks associated with compounded ketamine nasal spray (here).  The Agency states that there is no approved ketamine nasal spray.  Hey, wait a minute! (you might say); I could have sworn that I read about a ketamine nasal spray approval?  Well, close!  The product you may be thinking […]

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16
Feb

Final Day at AAM Annual Meeting – “CEOs Unplugged” Highlights

The most popular program of each year’s AAM Annual Meeting is always the CEO unplugged session.  Oftentimes there are significant disagreements between the different CEOs regarding strategy, but this year there was almost complete agreement on strategic issues, policy, the marketplace, and regulatory issues.  The four panelists were Sven Dethlefs, Ph.D, Executive Vice President, North […]

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