Changes Urged in ANDA Amendments Appendix

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The Association for Accessible Medicines (AAM) says FDA should change the 2018 ANDA Amendments guidance and its Appendix A to conform to changes included in the recent GDUFA 3 commitment letter. “In reevaluating each item in Appendix A,” the association says in a comment letter, “we encourage FDA to consider if a specific deficiency can be resolved through a mechanism or communication other than a major complete response letter. AAM members maintain that many examples exist for which the answer is yes….”

The letter includes a lengthy chart of specific comments and recommendations.

In its response, Apotex says it would be beneficial to both the agency and applicants if FDA would consider resolving deficiencies initially via information request or discipline review letters where applicable. “This approach would align with the GDUFA 3 objective to ‘promote the efficiency and effectiveness of the review process …, increase the overall rate of approval, and facilitate greater access to generic drug products.” Apotex says.

The Teva comment letter says that revisiting Appendix A was an important item of discussion during the GDUFA 3 negotiations. It praises the agency for soliciting public feedback on possible changes rather than committing to specific changes. Teva says it is critical that FDA classify deficiencies as major only when truly warranted, that is, when the deficiency cannot be resolved through another mechanism and the additional review time is necessary to assure the safety and efficacy of the drug. The company also references the AAM chart of specific comments and says it agrees with all of them.

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