Regulatory Affairs

06
Feb

May Not Be a Rash Decision to Worry About a Rash

The FDA issued a safety warning on Thursday afternoon regarding the potential for rare but serious adverse reactions (including anaphylaxis, hives and severe rash) for a common skin sanitizing agent.  The warning focuses on chlorhexidine gluconate which is available both as a prescription and over-the-counter product for use as a skin sanitizer.  In addition, the […]

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02
Feb

Let’s See if We Get this Right

Remember the old FDA Monthly Approvals Report that never really provided numbers that matched the approvals that OGD reported in their Activities Report of the Generic Drug Program (Activities Report)?  (see story here). We reported a usual 5-10% discrepancy relative to approvals between the reports.  Well, the FDA Monthly Approval Report was discontinued many months […]

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27
Jan
USP, BP, EP or JP - Which Should You Cite? - Lachman Consultants

USP, BP, EP, JP – Which Can You Cite In Your Application?

FDA published an updated Manual of Policy and Procedure (MaPP), 5310.7 after a 10-year first edition and this one (in my opinion) really clears up one of the age-old questions – can I cite a foreign compendia as the basis for establishing a specification or test method in my application?  The answer is a resounding […]

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24
Jan

No New Regulations – No New Hires – Will the Administration’s Actions Impact the Drug Approval Process?

Donald Trump signed an Executive Order freezing government hiring, except for the military, national security, or public safety personnel, and issued a memorandum placing a moratorium on any new regulations or Guidance. In addition, it is reported that the memorandum noted that if new regulations have been sent to the Federal Register, but yet unpublished, […]

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23
Jan

FDA 2017 List of 101 Guidances – How Many Apply to Compounding Pharmacies and Are You Current and in Compliance???

For 503A and 503B compounding pharmacies, how do you protect your business from heavy-handed interventions from State and Federal Regulators? Can you affirmatively respond to the following questions? Do you know the Federal and State laws you are required to follow? Do you have the right enabling documentation (procedures, policies, records, etc., in place and […]

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19
Jan

FDA Declares Drug Product Removed for Safety Reasons

Acthar Gel Synthetic (seractide acetate) injection, 80 units/mL and 40 units/mL, was the subject of NDA 017861, approved for Armour Pharmaceuticals on February 21, 1978, but was never marketed by the company.  A Federal Register notice (here) announces the FDA’s determination that the product, that was ultimately withdrawn in 2014, due to failure to submit […]

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16
Jan

An Injection of Advice on Generic Drug-Device Combination Products from FDA

In another generic drug Guidance issued in the beginning of the year, OGD Guidance tsunami, FDA has provided advice on how to decide what might be necessary to gain approval of an ANDA, where there is a drug-device patient interface.  FDA notes throughout the Guidance that each ANDA will be evaluated on a case-by-case basis […]

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