FDA Denies Amneal Levothyroxine Petition

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FDA has denied a 12/21/2018 Amneal Pharmaceuticals petition asking it to (1) change the therapeutic equivalence code published in the Orange Book for all strengths of Provell’s Euthyrox (levothyroxine sodium) tablets from AB2 to BX to mitigate the risk of look-alike medication errors and (2) refuse to approve any sNDA for Euthyrox that seeks approval of bulk or loose packaging of the current off-white tablets without color-coded blister packaging to help distinguish strengths. The agency’s 10/2 denial letter says that during the original NDA review, it raised a concern that the lack of tablet color coding had the potential to increase the risk of medication errors.

In working with the NDA applicant, it says, FDA determined that it would be acceptable to market Euthyrox using the universal color-coding system to denote different dosage strengths on the blister packaging and carton labels only. At the time of a supplement filing, the letter says, FDA reviewed the FDA Adverse Event Reporting System and did not identify errors or confusion regarding the strength of the drug.

The letter further says that the non-color-coded Eythyrox tablets met the criteria for the AB2 therapeutic equivalence code and thus it will not be changed.

The petition request involving sNDAs for a change in packaging was denied, FDA says, because each such request must be considered on a case-by-case basis. “FDA recommends that applicants take steps to minimize risks associated with the design of the drug product and its container closure system,” the letter says, “and will request information regarding potential risks on a case-by-case basis as part of its review of the application.”

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