Generics

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FDAs Final Determination that Ciprofloxacin 100 mg was Withdrawn for SE Reasons - Lachman Blog 2

FDA’s Final Determination that Ciprofloxacin 100 mg was Withdrawn for S&E Reasons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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26
Jul
Quick checklist and clipboard task management, filling survey forms online. Document Management System (DMS) and process automation to efficiently manage files, Corporate business technology.

One from Column A, One from Column B – Now All Together for Glass Vials and Stoppers

Dealing with different product requirements is often difficult, especially when the regulation office or center may differ as well.  Over the years, individual post-approval change requirements have been scattered in documents from different centers and, if you have a good enough memory, then maybe you picked the right reporting requirement based on the product and […]

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24
Jul
Risk Assessment in Visual Inspection Programs

The Crucial Role of Risk Assessment in Pharmaceutical Visual Inspection Programs

In pharmaceuticals, maintaining product quality and safety is paramount.  Visual inspection plays a vital role in detecting particulate matter and/or container/closure defects, though it may fall short in pinpointing the root cause of defects or material origins.  To fortify visual inspection programs effectively, a comprehensive risk assessment serves as the foundational pillar.  This blog delves […]

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