Regulatory Affairs

09
Jan

Drug Shortages Continue to Plague the Industry

Whether it be the supply chain, compliance issues, manufacturing issues, issues with packaging components, or just plain bad luck, the number of drug shortages continues to plague the pharmaceutical industry both domestically and overseas.  The FDA current shortage list (here) contains 191 entries and, of that number, only 66 have been resolved, leaving 125 drug […]

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23
Dec

Analytical Method Validation, Verification, or Qualification – What to use and when?

Analytical development and/or QC groups at early-stage pharmaceuticals and biopharmaceuticals often ask themselves about the level of level of confirmation of suitability required for their methods. Often the term ‘validation’ is used without understanding the full implications of the term. Sometimes, the terms validation, qualification and verification are used interchangeably. While ‘validation’ is well understood […]

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21
Dec

Revised Guidance on Controlled Correspondence for ANDAs

The FDA published a revised guidance issue today (here) that revises a December 2020 guidance on Controlled Correspondence (CC) by the Office of Generic Drugs.  This December 2020 guidance is being updated to reflect the new provisions of GDUFA III and its commitment letter relative to the submission of CC. “This guidance provides information regarding the […]

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20
Dec

December May Not Be a Month to Remember for OGD Approvals

Taking a look at the unofficial approval information on the FDA website through December 16th, we found only twenty‑five ANDAs receiving full‑approval actions and six receiving tentative‑approval actions.  That is a total of (obviously) thirty‑one approval actions.  Given that number, if the OGD could double its approval output by the end of the month, that would […]

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16
Dec

New Reporting Structure and Metrics for OGD Statistical Reports

Well, the new statistics started rolling off the assembly line last night and appear in a new report that combines the generics monthly statistical report and the Quarterly Report.  The new name of the report, which we discussed in a blog post (here), is the Generic Drugs Program Monthly and Quarterly Activities Report.  We will […]

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15
Dec

Devices to Head onto the Inspection Delay or Refusal Bandwagon

Since July 9, 2012, the day that the Food and Drug Administration Safety and Innovation Act (FDASIA) (Public 19 Law 112-144) was signed into law, drug products are deemed “adulterated for which a manufacturer processed, packed, or held in any factory, warehouse, or establishment and the owner, operator, or agent of such factory, warehouse, or […]

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15
Dec

Newly Revised Guidance on Failure to Respond to a CRL

The FDA has revised the guidance, originally issued in July 2022, titled Failure to Respond to an ANDA Complete Response Letter Within the Regulatory Timeframe (here) to include additional information as required relative to the performance goals outlined in the commitment letter for GDUFA III.  While there aren’t many changes in the revision, it is certainly […]

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14
Dec

Bi‑Yearly Update of Off‑Patent Off‑Exclusivity Drugs with No Generic Approvals

Twice a year, the FDA publishes an update of the List of Off‑Patent, Off‑Exclusivity Drugs without an Approved Generic (see here).  This list is designed to generate interest from the industry in increasing competition among such products.  It is made up of two parts.  Part I is for drugs for which the path to approval is […]

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