Generics

08
Nov

FDA Announces the Issuance of New PSGs

Today, FDA issued a Federal Register notice (here) announcing the release of 24 new product specific guidances (PSGs) and 20 revised guidances. These guidances provide the FDA’s current thinking on the methods to establish bioequivalence for specific products. The new and revised guidances can be found on the FDA webpage here. Please note that, as […]

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04
Nov
Red arrow. Vector

Unofficial OGD Approval Figures for October 2021

Well, the first month of FY 2022 appears to be an improvement over the last month of FY 2021, which was reported as forty-nine total approval actions, as the OGD hit an unofficial total of sixty-two in October 2021.  The total is broken down into fifty full-approval actions and twelve tentative-approval actions.  Usually, a few additional […]

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31
Oct

OGD Published GDUFA III Commitment Letter

Every 5 years, the user fee programs (UFAs) are renegotiated and, for each UFA program, there is a commitment letter that outlines the agreed-upon goal dates and program enhancements that will dictate the five-year reauthorization period when Congress passes the Reauthorization Act (likely in mid to late FY 2022). This is a piece of must-pass […]

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14
Oct
Blackboard Business Strategy Concept

OGD Updates August Metrics and Provides Some Critical Official September Numbers

Overnight, FDA updated its metrics for August and also provided some critical metrics to end out FY 2021 (here). Let’s take a look at the August update first. OGD issued three (3) Refuse-to-Receive letters in August, which appears to be consistent with the numbers for the year (with the exception of 11 RTRs that were […]

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01
Oct

Slicing the Bologna Too Thin Leads to Appeals Court’s Overturning District Court’s Ruling – Harkens Back to Skinny Label in Recent “Inducement to Infringe” Decisions – I’m Confused

Everyone knows that I am not a lawyer; I’m just a regulatory geek.  But in the case of Catalyst Pharmaceuticals v. FDA and Jacobus in an orphan drug dispute, where the case rested on whether the phrase “same disease or condition” is ambiguous, there are few things that confuse me. The central issue is the […]

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