05
Jul

May 2023 Official Statistics Are in The Books

Well, we’re just four months from the end of FY 2023 and the approval numbers still stand strong.  In May, the OGD issued sixty‑three full‑approval actions and eighteen tentative‑approval actions for a total of eighty‑one approval actions.  Of the sixty‑three full‑approval actions, six were first‑time generic approvals and thirteen (20.6%) were approved in the first cycle.  […]

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28
Jun
Wholesaling by 503B Outsourcing Facilities - Lachman Consultants

What Constitutes Wholesaling by 503B Outsourcing Facilities?

The FDA released a guidance yesterday titled Prohibition on Wholesaling Under Section 503B of the Federal Food, Drug, and Cosmetic Act (here), which (as its title suggests) fully outlines what the Agency does and does not consider wholesaling by an outsourcing facility.  The examples of what a firm can and cannot do under the provisions of […]

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21
Jun

Unofficial Mid-June 2023 ANDA Approval Tally

Well, June got off to a rousing start!  In the first fifteen days, the OGD issued forty‑six full‑approval actions and nine tentative‑approval actions.  This represents one of the best mid‑month totals (fifty‑five) that we’ve seen in a long time.  If the month continues at this pace, we’re likely to see over 100 approval actions for […]

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08
Jun

OGD Provides Three Checklists to Aid Applicant’s Submissions

A few days ago, the FDA published a guidance document titled Cover Letter Attachments for Controlled Correspondence and ANDA Submissions (see here) that describes three checklist attachments for various types of ANDAs and related submissions.  The checklists are identified as being voluntary, but the OGD suggests that not only can they aid applicants in ensuring […]

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30
May

PMI – Add That to Your List of Acronyms as FDA Publishes a New Proposed Rule

Prescription Medication Information (PMI) will, if FDA has its way, replacing medication guides and other information provided to patients.  The goal of the new PMI is to “highlight essential information that the patient needs to know about the prescription drug product and basic directions on how to use the product. The pre-publication of the proposed […]

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19
May

Petition Tests OGD Guidance on Use of Males and Females in BE Study

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) […]

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18
May

FDA Releases New and Revised BE Product Specific Guidances

Today, the FDA released another batch of Product‑Specific Guidances (PSGs), outlining its current thinking on the bioequivalence (BE) testing requirements for generic products – twenty‑five new BE guidances and twenty‑one revised guidances.  The listing can be found here. The FDA has various goals regarding publication of these PSGs that are tied to getting information to […]

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