Regulatory Affairs

19
Apr

Top Risks of the 510(k) Premarket Notification Process

As with any regulatory submission, there are inherent risks associated with the submission and approval process if required data are incomplete or missing.  In addition, compliance activities can play a major role in risks following approval and with commercialization of products. Some of the risks specific to 510(k)‑cleared devices include: Submission Rejection/Approvals: FDA 510(k) submissions […]

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18
Apr

Mid-April 2023 Peek at OGD Approval Actions

With half of April in the books, the number of OGD approval actions posted as of April 14th includes twenty‑seven full‑approval actions and four tentative‑approval actions for a total of thirty‑one approval actions.  It looks like the OGD is heading towards an average approval month for April.  Average definitely isn’t a bad thing, especially since […]

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17
Apr

Biosimilar Interchangeability: The Need to Reconsider?

Introduction On November 17, 2022, Sen. Mike Lee (R-UT) introduced a Bill entitled the “Biosimilar Red Tape Elimination Act” with the intent to increase competition within the US biosimilar market and reduce consumer costs associated their development.  The Bill proposes to eliminate the interchangeability requirement of conducting switching studies associated with biosimilar drug development. In […]

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17
Apr

TDS Adhesion and I/S Testing Can Always Be A Sticky and Irritating Subject

Those of us that have been in the trenches since the passage of Hatch-Waxman have seen the issue of adhesion and sensitization studies for transdermal delivery systems (TDS) change dramatically.  Well, there are now two new guidance documents that take us to the next step in recommended adhesion and irritation/sensitizations (I/S) testing revisions. First is […]

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11
Apr
FDA Guidance Snapshot Pilot Program - Lachman Consultants

CDER to Launch Guidance Snapshot Pilot Program

Those of us in the industry are usually reasonably technically savvy and can understand some of the more complex guidance documents that the FDA issues.  However, there are times that even those among us in the industry, depending on our individual academic tracks and professional experiences, whether regulatory, CMC, bioanalytical, pharmacokinetics, medical, and on and […]

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06
Apr

Unofficial March 2023 Approval Actions Almost Record Breaking!

March 2023 was an outstanding month for approval actions, with OGD unofficially issuing 123 total approval actions comprised of 95 full approval actions and 18 tentative approval actions.  There were other months with 100 or more total approval actions, but we have not seen that level of approval productivity in a while. The record of […]

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05
Apr
Mailbox

New FDA Program for Mail Back Envelopes for Opioids – Good News or Bad News?

On Monday, the FDA announced a change to the REMS for opioids to include a requirement “to make prepaid mail‑back envelopes available to outpatient pharmacies and other dispensers as an additional opioid analgesic disposal option for patients.”  As part of the new, revised REMS requirement, “all manufacturers of opioid analgesics used in outpatient settings are […]

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05
Apr

503B Outsourcing Facilities Batting 1 for 11 in This Round of Bulk Substances Reviewed

The 503B outsourcing facilities are able to compound drug products in certain circumstances using bulk ingredients but “[O]ne of the conditions that must be met for a drug product compounded by an outsourcing facility to qualify for the exemptions under section 503B of the FD&C Act is that the outsourcing facility may not compound a […]

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