05
Sep
Guidance on Post-Warning Letter Meetings Will They Provide Some for Only a Special Few - Lachman Consultants

Guidance on Post-Warning Letter Meetings: Will They Provide Some for Only a Special Few?

The GDUFA III commitment letter (here) outlined a number of industry-requested improvements to the GDUFA program. One such request related to the age-old problem of timely resolution of compliance problems resulting in a warning letter at a facility and the clearance of that warning letter. Specifically, in section VII(D) of the commitment letter, the “FDA agreed to […]

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01
Sep

Is your company suitably staffed? Our article in Contract Pharma takes this issue head on.

According to reports, the pharmaceutical job market has been expanding exponentially in recent months and is on an upward trajectory for job seekers. Occupational profiles are changing and many existing jobs, as a result of automation, are evolving, while completely new jobs are emerging. In this post-pandemic growth period, pharmaceutical companies are beginning to recognize […]

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29
Aug
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Vyvanse Shortages Should Be Resolved but What Will the Market Do?

On August 25, 2023, the Office of Generic Drugs approved a total of 14 different applications for lisdexamfetamine dimesylate products after the expiration of a patent on August 24, 2023. (This is the first time in a long while where I remember this many applications being approved on a single day.) While this is good […]

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25
Aug
Pitfall-Journey_blog_LachmanConsultants

Surviving the Perils of Submitting Controlled Correspondences (Part 2)

In Part 1, we focused on drafting the Controlled Correspondence and tips for formatting and presenting the correspondence, but, after submission, the CC must be accepted by the coordinator to be placement in the queue for review. The office has been very strict, perhaps rightly so, but there have been a few headscratchers too. Some examples […]

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24
Aug
New-ISPE-Guide-on-503B-Compounding-Lachman-Consultants-Blog

New ISPE Guide on 503B Compounding

For those struggling with understanding all the complexities of running a 503B compounding facility, a new resource is now available. The International Society of Pharmaceutical Engineers (ISPE) has a new guide coming out titled “503B Compounding – Regulatory Basis and Industry Good Practices for Outsourcing Facilities” (here). Do you know why compounding exists? Shouldn’t all […]

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24
Aug
Pitfall-Journey_blog_LachmanConsultants

Surviving the Perils of Submitting Controlled Correspondences (Part 1)

Of the many benefits that have come from the Generic Drug User Fee Act (GDUFA) over the years, one has been the addition of response times for the FDA to answer Controlled Correspondences (CCs) that were first negotiated under GDUFA II. The Agency issued an FDA CC guidance, which was finalized in December 2020. Having a […]

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24
Aug
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5 Reasons Why You Should Perform a Mock Inspection Now

As U.S. consumers are facing critical drug shortages, leading Congress to question the FDA’s foreign inspection program, particularly for products with supply chains from India and China, the oversight of CGMP inspections is high on the Agency’s radar. With approximately 32% of generic drugs and 45% of active pharmaceutical ingredients (APIs) from these two countries, […]

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22
Aug

Two Bulk Drug Substances Are Denied for Inclusion on Bulk Drug List for 503B Compounders

In a Federal Register Notice, FDA explains that ephedrine sulfate and hydroxychloroquine sulfate are not to be included on the bulk drug list for use in compounding by 503B outsourcing facilities (here). As mentioned by the Agency “[O]ne of the conditions that must be met for a drug product compounded by an outsourcing facility to […]

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