Compliance

06
Jan

New or Revised Guidances to Look for from FDA in Calendar Year 2015

FDA issued a Guidance today entitled “Guidance Agenda: New and Revised Draft Guidances CDER is Planning to Publish During Calendar Year 2015”. This document gives us an idea of what is new and what changes we can expect on various issues over the coming year. It is not specific as far the specific changes that are upcoming, but at least it provides direction as to where changes or new advice may be forthcoming from FDA.

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28
Dec

What, No More Paper? The FDA is Going Green on Labeling!

Well, after a lot of talk and years of discussion, “The Food and Drug Administration (FDA) is proposing to amend its labeling regulations at 21 CFR 201.100, 201.306, 201.310, 606.121, 606.122, 610.60, and 610.61 for human prescription drugs and biological products, and blood and blood components intended for transfusion, to require that the prescribing information (commonly referred to as the package insert) intended for health care professionals be distributed electronically and, with few exceptions, not in paper form.”

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15
Dec

Look in Those Stockings – Is it Coal or a New Approval?

Just a few days ago, I posted a memo from Cook (Acting Director, Office of Generic Drugs [OGD]) about the new personnel changes there and the vision of how OGD will drive applications to approval. The plan sounds good and I believe we will see movement in the coming year (remaining 9.5 months of GDUFA year three). But today is December 15th and, thus far, we have seen only one approval in December.

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11
Dec

Now That the Foundation Has Been Laid, OGD is Making Moves to Crank Up the Machine

On December 11, 2014, Dr Kathleen (Cook) Uhl, Acting Director, Office of Generic Drugs (OGD) sent the following memo to all OGD and CDER Ops staff announcing some personnel changes and revisions in the way OGD will be approaching the significant backlog of applications and how it will approach the GDUFA goals it must meet.

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08
Dec

Obtaining Samples for BE Testing for Products with Restricted Distribution Systems or REMS

The generic industry has been having a hard time (to say the least) in obtaining samples of certain Reference Listed Drugs (RLDs) that have Risk Evaluation and Mitigations Strategies (REMS) with elements to assure safe use (ETASU) upon which to conduct the necessary bioequivalence (BE) studies to support ANDA approval. Today, FDA has published a draft guidance entitled, “How to Obtain a Letter from FDA Stating that Bioequivalence Study Protocols Contain Safety Protections Comparable to Applicable REMS for RLD”.

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22
Nov

Here’s a Shock – Alpha Male Contains Undeclared, Hidden Drug Ingredient

Today, FDA issued a Public Notification indicating that the supplement Alpha Male, marketed with a tag line of “Knock it out of the Park with Alpha Male!” contains derivatives of both tadalafil (the active ingredient in Cialis) and derivatives of sildenafil (the active ingredient in Viagra). This is just another in a long line of supplemental products containing adulterants that makes them not only new drugs, but also dangerous.

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07
Nov

Rx vs OTC- the Debate Continues

On November 12, 2014, the FDA responded (here) to a September 23, 2014 correspondence to Dr. Janet Woodcock, Director, Center for Drug Evaluation and Research and also submitted the same to Docket No. FDA-2012-P-0566 regarding the safety of PEG 3350 for pediatric patients. The big debate is a bit broader than just pediatric safety; it involves an Agency determination stating that, when a product is completely switched from prescription to OTC status,, the product can no longer be marketed by prescription.

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