10
Sep
U.S. and EU Drug Shortages - Lachman Consultants

New Risks Discovered as U.S. and EU Drug Shortage Efforts Start to Merge

U.S. and EU efforts to manage supply chain shortages are slowly converging; however, the political winds in the Rest of World (ROW) may be diluting required oversight.  Both the U.S. (Risk Management Plans to Mitigate the Potential for Drug Shortages | FDA) and EU (Shortage Prevention Plan (SPP) – template (europa.eu)) have published either a […]

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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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12
Aug
Section viii label carve-out - Lachman Blog

Generic Carve Outs and Inducement to Infringe Still Under Attack

We have written extensively about the attack on the section viii label carve-out that is permitted under the Hatch-Waxman Act (H-W); this carve-out allows certain changes to a generic drug’s labeling to avoid patent infringement or certain exclusivity protection (here, here, here, here, and here). This so-called section viii label carve-out was part of the delicate balance […]

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08
Aug
Meet Lachman Consultants at Booth #314 during the PDA/FDA Joint Regulatory Conference 2024!

The focus is on quality at the PDA/FDA Joint Regulatory Conference 2024.

Visit with Lachman Consultants at Booth #314 during the event. We hope you’ll be joining us at the annual PAD/FDA Joint Regulatory Conference on September 9th-11th at The Westin Washington, DC Downtown. This years can not miss event is entitled Current Good Manufacturing Practice (CGMP): Leading with Quality and Integrity,” and will provide in-depth knowledge […]

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06
Aug
July 2024 Unofficial ANDA Approval Actions - Lachman Blog

July 2024 Unofficial ANDA Approval Actions – Not Quite What We Predicted Mid-Month

It seems that the pace of approvals in July 2024 slowed and, as a result, our mid-month estimate of possibly hitting 90 approvals was dashed by a late-month drop in approval actions. The OGD did, however, unofficially issue 63 full-approval actions and 12 tentative-approval actions for a total of 75. (As a reminder, at mid-month, the OGD had […]

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26
Jul
Quick checklist and clipboard task management, filling survey forms online. Document Management System (DMS) and process automation to efficiently manage files, Corporate business technology.

One from Column A, One from Column B – Now All Together for Glass Vials and Stoppers

Dealing with different product requirements is often difficult, especially when the regulation office or center may differ as well.  Over the years, individual post-approval change requirements have been scattered in documents from different centers and, if you have a good enough memory, then maybe you picked the right reporting requirement based on the product and […]

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24
Jul
Risk Assessment in Visual Inspection Programs

The Crucial Role of Risk Assessment in Pharmaceutical Visual Inspection Programs

In pharmaceuticals, maintaining product quality and safety is paramount.  Visual inspection plays a vital role in detecting particulate matter and/or container/closure defects, though it may fall short in pinpointing the root cause of defects or material origins.  To fortify visual inspection programs effectively, a comprehensive risk assessment serves as the foundational pillar.  This blog delves […]

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