Some Guidance Changes Helpful, More Needed: AAM

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The Association for Accessible Medicines (AAM) says that while some FDA changes to a draft guidance on pre-submission facility correspondence (PFC) related to prioritized generic drug submissions are helpful, it believes that additional changes are needed. The association’s comment letter says the revised draft guidance provides some additional explanations for why certain information is requested in a pre-submission facility correspondence, but AAM believes the rationale is flawed in some respects and still is not granular enough for applicants to fully understand why some of the requested information is necessary.

“FDA should critically examine each of the items requested to be provided in the PFC with an eye towards paring down the items to only those that are absolutely necessary for FDA to determine whether an inspection must be conducted,” the letter says. “For each of the items requested to be provided in the PFC, FDA should provide the rationale for why it is necessary.” The association also submitted specific line-by-line comments.

The Apotex comment commends the agency for working with industry to address industry’s concern regarding the information required for a PFC to be considered complete and accurate. “By reducing the information required and adopting a more flexible approach, the agency has made it more feasible for applicants to utilize the PFC option,” Apotex says. The company also submitted specific comments.

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