Regulatory Affairs

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In April 2016, the FDA published its much-anticipated draft Guidance on Data Integrity.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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16
May

Can Prescription Prenatal Vitamins Be Medical Food?  FDA Says No!

The debate about whether prenatal vitamins are a medical food seems to have been clearly addressed once and for all in a revised Question and Answers Guidance entitled “Frequently Asked Questions About Medical Foods; Second Edition” (here).  Among other issues addressed in the Q&A document, FDA clearly states its position that prenatal vitamins are not […]

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11
May

What’s a Mother to Do?

We are not entirely sure how FDA makes its decisions to revise a BE Guidance document, but we are clearly in the dark as to how and when the FDA decision to require firms to repeat BE studies using the revised recommendation are made. I am sure that FDA will (as they have with certain products) tell a firm when it is absolutely necessary to repeat a study using a new BE recommendation, but FDA does not do this in all instances. What are the criteria for FDA’s decision making process?

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03
May

FDA Announces Approval of Brand Name Change

As we reported here back in July 2015, FDA has warned patients and healthcare professionals about a potential look-alike, sound-alike naming issue with an antidepressant Brintellix (vortioxetine) and Brilinta (ticagrelor), a blood thinning agent. Yesterday, FDA announced that they had approved a name change for the antidepressant product to Trintellix.  This change hopefully will help […]

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