FDA Drug Onshoring Policies Could Work: Attorneys
Reporting on the FDA 9/30 public meeting on onshoring manufacturing of drugs and biological products, attorneys Mark Schwartz and Julie Kim (Hyman, Phelps & McNamara) write in their firm’s FDA Law Blog that if the agency can rapidly implement a PreCheck program that formalizes early, durable engagement; modernizes post-approval pathways; and alleviates lifecycle inspection bottleneck, “the pharmaceutical industry appears poised to translate expertise into faster, more resilient domestic manufacturing capacity.” Much of the meeting, they say, involved introducing the PreCheck initiative, which is intended to be FDA’s core mechanism for streamlining regulatory pathways for domestic manufacturing.
The initiative has two phases — facility readiness and application submission — and is built on three guiding principles: partnership, predictability, and preparedness, Schwartz and Kim write.
“While participants broadly accepted PreCheck,” they say, “they were candid about the most significant regulatory hurdles to establishing new U.S. active pharmaceutical ingredient facilities. Representatives from innovator, generic, biologic, and contract manufacturing organizations identified several key challenges that must be resolved to unlock domestic capacity.”
The post concludes with these recommendations that companies should consider in preparing to participate in PreCheck:
- draft a facility drug master file architecture;
- propose an engagement plan;
- document prior knowledge; and
- nominate a single point of contact.