Today, the FDA has published revision 1 (here) of the draft guidance Determining Whether to Submit an NDA or a 505(b)(2) Application issued in May 2019. Its purpose is to further define which abbreviated pathway, ANDA, or a 505(b)(2) application, is the appropriate submission type for the market application. The guidance first defines what a […]
As the FDA’s first ANDA suitability petition coordinator at the time of the initial passage of Hatch-Waxman as well as having been involved for my full ten years at the FDA and 30+ years in industry, I’ve seen a lot of suitability petitions, a lot of responses, and some strange things in my day. I’ve also […]
As many in industry are already aware, suitability petitions began to be subject to review metrics at the beginning of Fiscal Year 2024, which started on October 1, 2023. As a reminder, the GDUFA III Commitment Letter (GIII CL) requires the FDA to review and respond to suitability petitions that have been assigned a goal date within six […]
Any frequent reader of the Lachman blog is well acquainted with the blog’s affinity for commenting on approval metrics from the Office of Generic Drugs (OGD). Today’s blog will also address metrics, but, in this case, the metrics are related to suitability petitions and are completely unofficial as the OGD has yet to publish or […]
Today, the FDA published a Product Specific Guidance (PSG) with recommendations for establishing bioequivalence of oxymetazoline hydrochloride ophthalmic solution (here). As we have all recognized through the publication of numerous other PGSs over the last five years, the Agency is moving to BE waivers to establish sameness of the product as well as meet the […]
Benzoyl Peroxide is the active ingredient in many acne creams, ointments, gels, and combination semi-solid products for the treatment of acne. These products are sold either by prescription or over the counter. Valisure is the same testing lab that uncovered the nitrosamine impurities in Ranitidine products that developed over the expiration dating life of drug […]
I last wrote about the topic of ANDA Suitability Petitions (SPs) in August 2023. At the conclusion of that blog post, I referenced an SP response that had been issued in April 2000 for a SP that was submitted in November 1999, which amounted to completed review and response by the FDA in less than […]
With summer in full swing and many people on vacation or thinking about their upcoming vacation, I decided to look forward to the fall and an upcoming GDUFA commitment on Suitability Petitions (SP) that begins on October 1, 2023. But first, let’s look back on events related to SPs in Calendar Year (CY) 2023. Earlier this year, […]
Back on January 30, 2023, I wrote a blog (here) concerning a petition that was filed by Vanda Pharmaceuticals regarding a perceived difference in labeling between the brand and generic drug. In this case (and please see original post to familiarize yourself with the details), the firm claimed that the generic excluded braille from its […]
A Citizen Petition submitted recently by McDermott Will & Emory (here) on behalf of Vanda Pharmaceuticals requests that the FDA “revoke approval of Abbreviated New Drug Application (ANDA) No. 211654, submitted by MSN Pharmaceuticals Inc. (MSN), for 20 mg tasimelteon capsules, and order a recall of any product that has been distributed under ANDA No. 211654 (if any) […]
