Regulatory Affairs

06
Jun
OGD Updates Additional Metrics In March Stats Image

May Monthly ANDA Approval Information – But the Wait is On!

Information on the FDA’s Monthly Approval Report (here)  is usually not complete.  Typically, there may be up to a 5-10% discrepancy (lower than actual) in the numbers of Approvals and Tentative Approvals reported.  The discrepancy improves over time but seldom do the numbers actually match the reported number of approval actions on the Activities Report […]

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31
May

Stick it to Me!

Today, the FDA announced the availability of a draft Guidance titled “Assessing Adhesion with Transdermal Delivery Systems and Topical Patches for Abbreviated New Drug Applications” (here).  The document discusses the way in which sponsors should document the adhesion of their proposed product with that the of reference listed drug (RLD). Clearly, for a generic transdermal […]

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23
May

FDA’s Most Recent Delay on the Generic Drug Labeling Rule Bodes Well for Industry (Hopefully)?

There are obviously two schools of thought on the Proposed Rule that would permit generic companies to unilaterally update their labeling to include new safety information.   On the consumer advocacy side, and from FDA’s view, it will improve patient safety (but personally I don’t see how).  But when you look at the Proposed Rule (as […]

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20
May
Is FDA Starting to Think (Again) About Cloud Computing Image

Is FDA Starting to Think (Again) About Cloud Computing?

In April 2016, the FDA published its much-anticipated draft Guidance on Data Integrity. This Guidance is a great way for industry and FDA to start and continue the dialogue about data integrity. An interesting note about this Guidance is that buried, deep down on line 142, is a mention of “cloud infrastructure” as a “system” as it relates to “computer or related systems” in § 211.68. Up until this point, the FDA has been largely silent on the use of cloud computing for FDA regulated systems, and industry has taken this silence to be, in many ways, a prohibition to its use.

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