DSI Pharmatics

The following three rules of engagement are recommended to take place at an End of Phase II meeting, either face to face or by telephone. Each rule helps to ensure a successful negotiating strategy based on the actual discussions with the Agency. Note the fundamental position of the approach in every case:

1) Bring the discussion to the data presented on e.g., the process capability and robustness, acceptance criteria, effectiveness of the analytical capabilities etc.

2) Seek clear understanding of the FDA position

3) Seek agreement that the data package is adequate to support the approach while understanding that the FDA must review the actual NDA submission to come to a final determination

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A Fundamental Transparency? FDA Reports BLA CMC Problems

September 27, 2011

Speaking for the Center for Biologics Evaluation and Research (CBER) Division of Manufacturing Product Quality (DMPQ) at the PDA Annual Meeting in San Antonio, Texas in April, David Doleski emphasized the importance of transparency around changes in a roundtable on regulatory expectations for BLA CMC filings.  In his portion of the presentation at the meeting, [...]

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Everything You Would Ever Want to Know about the New ICH Q11 (draft) on Bastille Day Eve.

July 13, 2011

Coming Soon! Perhaps the new (draft) ICH Q11 will be much like the storming of the Bastille which was more important as a rallying point and symbolic act of rebellion than a practical act of defiance. Shortly after the storming of the Bastille, feudalism was abolished and the Declaration of the Rights of Man and [...]

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European Medicines Agency and US Food and Drug Administration receive first parallel quality-by-design application

June 20, 2011

The European Medicines Agency (EMA) and the United States Food and Drug Administration (FDA) have agreed to accept the first application under their pilot program for the parallel evaluation of marketing-authorization applications involving ‘quality by design’ (QbD). This should be interesting to watch. http://www.ema.europa.eu/ema/index.jsp?curl=pages/news_and_events/news/2011/06/news_detail_001279.jsp&murl=menus/news_and_events/news_and_events.jsp&mid=WC0b01ac058004d5c1

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A CGMP Framework: The New Non-Penicillin Beta-Lactam Risk Assessment

June 2, 2011

Application of these recommendations covers separation of areas manufacturing different classes of non-penicillin beta lactams, as well as sections producing unrelated products. Structural isolation is defined in the guidance as “completely and comprehensively separated”. In a clarification of cGMP (current good manufacturing practice) penicillin guidance the FDA said options other than completely separate buildings are [...]

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Final Process Validation Guidance – More Concepts less Terminology

June 1, 2011

coming soon

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The New Guidance: Process Validation has moved back into process development and characterization

March 3, 2011

FDA has recently revised its process validation guidance stating: “Data gathered (during the Continued Process Verification stage) might suggest ways to improve and/or optimize the process by altering operating ranges and set-points, process controls, components, or in-process materials.” So the FDA is stating clearly that it expects manufacturers to study, learn, and improve their processes. [...]

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Phase 2 to Early Phase 3 Regulatory Opportunities:Crucial Considerations on the Path to Product Approval

January 20, 2011

COMING SOON!

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Quality Resolutions

December 31, 2010

By defining hurdles to registration, emerging companies benefit from early regulatory guidance. There are no holidays or time off when it comes to complying with regulations. Companies need to be ready to meet the latest standards at all times. With that in mind, new FDA programs are sure to keep pharmaceutical companies of all sizes [...]

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