01
Sep

OOS: Whose Line is it Anyway? The Contract Testing Laboratory’s or Sponsor’s?

When it comes to investigating OOS results, a clear line should be drawn between the responsibilities of a contract testing laboratory (CTL) and that of the manufacturer/sponsor. Before we come to the testing part, here are some questions (not all inclusive) to be asked by your firm before selecting a CTL for outsourced testing: (1) […]

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30
Aug
Another Year Reprieve for Another Aspect of Track and Trace Legislation - Lachman Consultants

Another Year Reprieve for Another Aspect of Track and Trace Legislation

This morning, the FDA published a revision to the Wholesale Distributor Verification Requirement for Saleable Returned Drug Product and Dispenser Verification Requirements When Investigating a Suspect or Illegitimate Product — Compliance Policies guidance originally issued in draft in 2019 and then finalized in 2020. The revision provides for another one-year delay in enforcement for the […]

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15
Aug

Something’s Not Right Here – How Does This Happen?

On August 8, 2023, Axios reported (here) that the Pentagon began contracting with Valisure, a drug testing facility, to test the generic drugs that it is purchasing.  On August 9, 2023, Bloomberg reported much the same thing in an article titled “Tainted Medicine Fears Spur Pentagon to Seek Outside Testing” (here; subscription required).  Congress has been pushing […]

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27
Jul
Fees

PDUFA User Fee Rates for FY 2024

The PDUFA user fees all rose, not much of a surprise!  However, we are now getting into some serious money to submit a new NDA.  These fees could (in some instances) deter smaller applicants from entertaining NDA submissions as they might price them right out of the market.  And if it is not the NDA […]

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24
Jul

FDA Approves First Treatment for Molluscum Contagiosum – But There is a Hitch!

The Agency announced today the first approval of a drug (Ycanth [cantharidin]) available for the treatment of molluscum contagiosum, a viral skin infection that is fairly contagious and is spread by direct skin-to-skin contact. It is approved for use for adults and pediatric patients two (2) years of age and older.  However, most infections occur […]

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21
Jul

Mother Nature Just Can’t Cut the Drug Industry a Break

With the latest news that a tornado severely damaged a Pfizer sterile injectable plant in North Carolina, it is clear that Mother Nature is yet another interloper into the drug shortage problem in the United States.  Ed Silverman, of the publication STAT, reports  that “Among the damaged buildings was a Pfizer plant in Rocky Mount, […]

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14
Jul
PostMarketing Study Requirements - Lachman Consultants

What Constitutes “Good Cause” for Noncompliance with PostMarketing Study Requirements?

The FDA answers this question in a newly released guidance titled Postmarketing Studies and Clinical Trials: Determining Good Cause for Noncompliance with Section 505(o)(3)(E)(ii) of the Federal Food, Drug, and Cosmetic Act (here).  “[H]olders of applications for human prescription drugs (hereafter applicants) who are required to conduct postmarketing studies or clinical trials under section 505(o)(3) of the […]

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