20
Aug
Solving the Puzzle of Single-Use Consumables - Lachman Blog

Solving the Puzzle of Single-Use Consumables

Although the FDA’s regulatory requirements for acceptance of vendor test results in lieu of testing is clearly specified in 21 CFR 211.84 for incoming raw materials and container closures, the FDA has not put forth specific regulations for the acceptance of single-use consumables. Biologics manufacturers may use dozens or even hundreds of different single-use consumables […]

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19
Aug
Pre- and Post-PSG Telcons, Meetings Outlined in New Final FDA Generic Guidance - Lachman Blog

Pre- and Post-PSG Telecons, Meetings, Etc. Outlined in New Final FDA Generic Guidance

Today, the FDA released a final guidance titled Product-Specific Guidance Meetings Between FDA and ANDA Applicants Under GDUFA (here). Wading through the 26-page document is a bit of a chore, but there is a lot of useful information that will provide applicants with advice on what to do, when to do it, and how to […]

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12
Aug
Section viii label carve-out - Lachman Blog

Generic Carve Outs and Inducement to Infringe Still Under Attack

We have written extensively about the attack on the section viii label carve-out that is permitted under the Hatch-Waxman Act (H-W); this carve-out allows certain changes to a generic drug’s labeling to avoid patent infringement or certain exclusivity protection (here, here, here, here, and here). This so-called section viii label carve-out was part of the delicate balance […]

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07
Aug
June 2024 Official OGD Statistics and Some Projections - Lachman Blog

June 2024 Official OGD Statistics and Some Projections

The official numbers for June 2024 are in and posted on the FDA’s website here. The OGD issued fifty final full approvals along with fifteen tentative approvals in June. Of the fifty approvals, four were first time generic approvals and nine (18%) were first-cycle approvals. Of the fifteen tentative approvals, there were no first-cycle approvals. […]

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07
Aug
FDAs Final Determination that Ciprofloxacin 100 mg was Withdrawn for SE Reasons - Lachman Blog 2

FDA’s Final Determination that Ciprofloxacin 100 mg was Withdrawn for S&E Reasons

Based on a Federal Register (FR) notice issued in December 2023 (here), the FDA has determined that ciprofloxacin 100 mg tablets taken in a three-day regimen to treat uncomplicated urinary tract infections are ineffective based on resistance developed over time to E. coli, the primary causative agent for uncomplicated UTIs (see previous post here). Since that time, […]

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06
Aug
July 2024 Unofficial ANDA Approval Actions - Lachman Blog

July 2024 Unofficial ANDA Approval Actions – Not Quite What We Predicted Mid-Month

It seems that the pace of approvals in July 2024 slowed and, as a result, our mid-month estimate of possibly hitting 90 approvals was dashed by a late-month drop in approval actions. The OGD did, however, unofficially issue 63 full-approval actions and 12 tentative-approval actions for a total of 75. (As a reminder, at mid-month, the OGD had […]

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01
Aug
USP General Chapter on Temperature Mapping Studies

Finally – A USP General Chapter on Temperature Mapping Studies is Official!

On May 1, 2024, the first version of USP General Chapter <1079.4> on Temperature Mapping for the Qualification of Storage Areas became official, and it is the fourth part of USP General Chapter <1079> on Risks and Mitigation Strategies for the Storage and Transportation of Finished Drug Products, which also includes: USP General Chapter <1079.1> on Storage and Transportation […]

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