Comments on Good ANDA Submission Practices

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The Association for Accessible Medicines (formerly the Generic Pharmaceutical Association) says it welcomes issuance of an FDA draft guidance to assist ANDA applicants by highlighting common, recurring deficiencies in ANDAs and to provide recommendations on how to avoid these and other similar deficiencies with the goal of minimizing the number of review cycles to approval. The association comment says the draft guidance “offers opportunity for additional clarity regarding FDA’s expectations related to patents and exclusivity, labeling, product quality, and bioequivalence deficiencies.” The association lists several areas in the draft that need further clarification.

The International Pharmaceutical Excipients Council of the Americas says its members have some concerns on the need for a better understanding of expectations for atypical actives covered in the draft. It says it has asked the United States Pharmacopeia to establish an expert panel on atypical actives. FDA would be invited to participate on the panel once it is established, it says.

In its letter, Perrigo asks that FDA in the final guidance tabulate all guidance documents considered applicable to ANDAs and cross reference them by number as applicable throughout this guidance. It also says it would be helpful to have a keyword tag or organization system to allow sponsors to more readily identify which guidance documents are applicable to their specific product.

Specific line-by-line comments were provided by these three organizations as well as Apotex and Sanofi.

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