23
Dec
FSD gage

Does Your Data Integrity Risk Assessment Assess Full-Scale Instrument Deflection? It Should!

Why Using Full-Scale Deflection Introduces Data Integrity Risks In pharmaceutical manufacturing, Accuracy is a critical ALCOA+ principle that can sometimes get lost, particularly when assessing the holistic system. The field instrument level needs to be adequately integrated into the overall assessment, especially in aseptic manufacturing environments where sterilization is critical (and accurate data, such as […]

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04
Sep
caucasian person holds snus tobacco pouch over black background. copy space. alternative chewing nicotine smoking.

FDA Asks for Action Regarding Authorized Nicotine Pouch Products

Citing an increase in “accidental, harmful exposure” among children, the FDA is urging firms to use childproof packaging to help reduce the risk of such events.  The notice (here) indicates that over the period “[f]rom April 1, 2022, to March 31, 2025, the number of reported nicotine pouch exposure cases reported to U.S. Poison Centers steadily increased. […]

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01
Aug
toy Monarch butterfly emerging from its chrysalis.

Protocol Design and Lifecycle Following the Draft ICH Stability Guidance

  As discussed in a recent Lachman blog Revised Q1 Draft Stability Document Issued by FDA, the draft guidance titled Q1 Stability Testing of Drug Substances is a consolidated revision of ICH Q1A(R2), Q1B, Q1C, Q1D, Q1E, and Q5C.  This draft guidance provides guidance on product categories, such as advanced therapy medicinal products, vaccines, and other […]

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30
Jul
FDA Issues Final Guidance on Medical Device User Fee - Lachman Blog

FDA Issues Final Guidance on Medical Device User Fee Small Business Qualification and Determination

The FDA has revised its previous guidance of the same name, which was issued on August 1, 2018. The FDA notes that “[a] draft select update to this document was issued on February 22, 2024.” The revised final guidance (Medical Device User Fee Small Business Qualification and Determination) “includes updates that describe how FDA will determine if […]

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03
Jun
Do More with Less - Lachman Blog

Do More with Less – Looks Like That Is What the FDA Budget Request Asks

Now, here is a head scratcher. According to the Pink Sheet article written by Sue Sutter (here), “The White House requested $6.76bn, a decrease of 3.9%, or $271.5m, from the FY 2025 funding level. The proposal includes $3.17bn in budget authority, a decrease of 11.4%, and $3.59bn in user fees, a 4% increase.” What a dandy, […]

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22
May

Two Chinese Testing Labs Come Under Serious FDA Scrutiny

Today, May 22, 2025, “[t]he U.S. Food and Drug Administration (FDA)’s Center for Devices and Radiological Health (CDRH) issued General Correspondence Letters to two third-party testing companies in China after discovering data that was falsified or otherwise found to be invalid” (see the FDA announcement here).  The two labs receiving the so-called General Correspondence Letters are […]

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13
Sep
Shot of an asian businessman shouting into a megaphone against a studio background

Now Hear This!

Reviewed “under the FDA’s De Novo premarket review pathway, a regulatory pathway for some low- to moderate-risk devices that are novel and for which there is no prior legally marketed device,” the Agency has approved an OTC software solution that is compatible with certain Apple AirPods Pro headphones and provides, according to the FDA release […]

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27
Aug
Navigating Future Quality and Regulatory Challenges for Medical Device Companies - Lachman Blog

Navigating Future Quality and Regulatory Challenges for Medical Device Companies: Understanding the FDA Quality Management System Regulation (QMSR)

The FDA’s long-awaited QMSR will be released in February 2026. The amended 21 CFR 820 will incorporate by reference the Quality Management System (QMS) requirements of the 2016 edition of ISO 13485. We will explore the key differences between an FDA inspection and a notified body audit as well as the distinctions between ISO 13485 and the QMSR. […]

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20
Aug
Solving the Puzzle of Single-Use Consumables - Lachman Blog

Solving the Puzzle of Single-Use Consumables

Although the FDA’s regulatory requirements for acceptance of vendor test results in lieu of testing is clearly specified in 21 CFR 211.84 for incoming raw materials and container closures, the FDA has not put forth specific regulations for the acceptance of single-use consumables. Biologics manufacturers may use dozens or even hundreds of different single-use consumables […]

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