Compliance

23
Oct
Anxiety is creeping in

Inspectorate Reorganization 2.0 – Flip Flop

The move to link inspectors to specific organizational units (i.e., drugs, devices, biologics) to more closely align with the Centers responsible for the products seems to have taken a turn back to a more generalist approach.  According to a Pink Sheet article (here, subscription required) authored by Sarah Karlin-Smith and Derrick Gingery, the so-called “‘Simple […]

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09
Oct

Computer Software Assurance (CSA): Truths and Myths Demystified

The FDA’s new guidance on Computer Software Assurance or CSA (here) marks a shift—one that prioritizes critical thinking, product quality, and patient safety. In the world of regulated life sciences, the validation of software has long been guided by strict requirements. For decades, companies followed traditional Computer System Validation (CSV) approaches, often focusing on generating extensive […]

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12
Sep
Risk Management and QRM

No Form 483? No Comfort Zone: Quality Risk Management in the Digital Age

In today’s regulatory climate, avoiding an FDA Form 483 after an inspection isn’t necessarily a sign of success, it’s the bare minimum. True industry leadership in Current Good Manufacturing Practice (cGMP) goes beyond damage control. It demands a proactive, risk-based approach to quality that starts well before the regulator arrives for an inspection. The finalization of […]

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11
Sep
FDA_BadgeIcon_BlogImage

FDA Cracks Down on Prescription Drug Advertising—Prepare for Increased Enforcement Action

According to an FDA bulletin (here), “the FDA is sending thousands of letters warning pharmaceutical companies to remove misleading ads and issuing approximately 100 cease-and-desist letters to companies with deceptive ads.” A copy of the letter warning firms to remove misleading ads can be downloaded here. The bulletin says, “The FDA is concerned patients are […]

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19
Aug
New Nitrosamine Impurity Issue - Lachman Blog

FDA Notes the Emergence of a New Nitrosamine Impurity Issue and Requests Data

Yesterday, the FDA quietly posted another update to the CDER Nitrosamine Impurity Acceptable Intake Limits webpage. The latest update is not an extended timeline for submitting changes or new acceptable intake (AI) limits as might be expected but instead because CDER has become aware of an emerging issue related to small-molecule nitrosamine impurities such as […]

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14
Aug

Onshoring the Manufacture of Your Drug Products Soon? FDA Wants To Hear From You!

The FDA has announced the establishment of a public docket to receive comments on issues related to accelerating the establishment of new pharmaceutical manufacturing facilities in the US. You can read the full docket announcement here. Not only is the Agency opening a docket for comment, but that same announcement included information on a public […]

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08
Aug
Change Management and ICH Q12 - Lachman Blog

Change Management and ICH Q12 – Part 2 of 2

The ICH Q12 Guideline complements ICH Q8 to Q11 Guidelines and provides a framework to facilitate the management of post-approval Chemistry, Manufacturing and Controls (CMC) changes in a more predictable and efficient manner across the product lifecycle. The Q12 guideline highlights the need for an effective PQS as described in ICH Q10 and in compliance […]

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07
Aug

Embracing QRM Principles

I recently had the honour to be invited to speak at the PDA India’s annual conference in Hyderabad. The event was well supported by the local India office of FDA in person and senior FDA personnel (including Carmela Rosa and Jose Melendez amongst others) virtually. It was great to see the FDA continue to support […]

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