02
Mar
female mannequin hand on a pink background holding colorful pills. minimalism, place for text. the concept of fake medicines.

Defining Suspect and Illegitimate Products Under the Drug Supply Chain Security Act (DSCSA)

The FDA has issued a guidance (here) that provides clarification on the definitions of suspect and illegitimate products under the  Drug Supply Chain Security Act (DSCSA).  The definitions are designed to help those in the supply chain better and more accurately characterize problem products they may uncover. The guidance provides the following definitions: SUSPECT PRODUCT—The […]

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28
Feb
Confident business people are shaking hands after agreeing to a successful job. Business people shaking hands.Finishing up a meeting

Maybe There is a Reason After All!!

Getting back to the elemental impurities (EI) issue, we received additional interesting feedback from one ANDA sponsor.  They said sometimes “this stuff gets tricky.”  The sponsor related a situation of a capsule ANDA product that could be administered multiple times a day at high maximum daily dose.  The empty capsule shell had the standard limit […]

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27
Feb
Policy isolated on elegant green round button abstract illustration

Compounding Fairness???

As the compounding Industry awaits the next round of Guidances from FDA on using bulk drug substances, one point of controversy appears to be the fairness of compounding for 503A and 503B entities. The most recent Guidances for Compounding from Bulk Drug Substances are: Interim Policy on Compounding Using Bulk Drug Substances Under Section 503A […]

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23
Feb

FDA Warns of Potential Harm with Using Clarithromycin in Patients with Heart Disease

The new warnings which FDA says will be incorporated into both clarithromycin’s brand (Biaxin) and generics labeling come after review of a number of long-term studies revealed an increased risk of death in patients with preexisting coronary disease.  The interesting finding is that the risk is not necessarily immediate, but can occur in patients with […]

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22
Feb
Blackboard Business Strategy Concept

Only 5 Working Days Left in February, and Month Two of the Elemental Impurities Impact is Being Felt

As of this morning, there were only 20 full ANDA approvals and 2 tentative approvals listed on FDA All Approvals list (here).  In contrast, there were 9 NDAs with full approvals and one tentative approval.  Looks like ANDAs have been more impacted by the elemental impurities (EI) documentation requirement than it has for NDAs.  I […]

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14
Feb
Old Way x New Way Crossroad

A New OGD/OPQ Review Assessment Coming to an Application Near You – But Not for a While!

Dr. Janet Woodcock, Director, Center for Drug Evaluation and Research (CDER) at the AAM Annual Meeting today, gave some hope to generic applicants regarding the way agency assessments will be conducted in the not too distant future.  The goal is to improve the efficiency and effectiveness of the review process.  Why is this necessary?  Dr. […]

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13
Feb
Frontal view on a simple security barrier with a warning exclamation sign, isolated on pure white background. The image is suited for further compositing and derivation.

President’s Budget Has a Hidden Change to Hatch-Waxman — Watch Out.

There is a proposed change to 180-day exclusivity which is awarded to the first -to-file (FTF) applicant with a paragraph IV certification.  The proposal would trigger the 180-day exclusivity period if a subsequent applicant obtains tentative approval prior to the FTF applicant gaining final approval.  While this on its face may in some instances appear […]

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