Inactive Ingredient Database Suggestions

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The Association for Accessible Medicines suggests that FDA include additional details concerning expected justification content when referencing an Inactive Ingredient Database (IID) listing that differs from the proposed excipient in nomenclature, molecular weight, viscosity, or grade. The group made the suggestion in its comment to an FDA draft guidance on using the IID. The association also notes that since the IID is updated quarterly, the timing of an ANDA could be in jeopardy, and recommends that the agency provide further detail on the receipt of an application when excipient usage was previously guided by a previous version of the IID.

The group also raises concerns about the accuracy and integrity of information in the IID since inconsistencies with respect to the maximum potency per unit dose have been frequently observed across different IID versions.

In its letter, AbbVie identified several potential enhancements to the IID for FDA to consider, including extending the scope of the guidance to include BLAs managed under CDER and including the excipient information reported in CDER-led BLAs within the scope of the IID. It also recommends adding specific information on different grades of excipients to the IID and updating the guidance to address how the same excipient with different grades will be managed in the IID.

Apotex submitted line-by-line technical comments.

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