Draft Guidance on Comparability Protocols for CMC Changes
FDA has posted a draft guidance on “Comparability Protocols for Human Drugs and Biologics: Chemistry, Manufacturing, and Controls (CMC) Information” that provides recommendations on implementing a CMC postapproval change under a comparability protocol (CP). “Submission of a CP in an original application or prior approval supplement (PAS) allows the agency to review a description of one or more proposed CMC postapproval changes, supporting information including any analysis and risk assessment activities, a plan to implement the change(s), and, if appropriate, a proposed reduced reporting category for the change(s),” the document says. Such a strategy can provide a sponsor with an agreed-upon plan to implement the specified changes, and in many cases, a justification to report them in a reduced reporting category, which is contingent upon the sponsor’s data analysis after the change is completed. “In many cases, using a CP will facilitate the subsequent implementation and reporting of CMC changes, which could result in moving a product into distribution or facilitating a proactive approach to reinforcing the drug supply chain sooner than if a protocol were not submitted,” the agency says.