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From Defensible to Predictive: How High-Functioning MLR Teams Are Evolving Their Risk Assessment Approach

For several years, FDA's Office of Prescription Drug Promotion (OPDP) maintained a relatively low enforcement profile. For example, between 2022 and 2024, the Agency issued only 14 Untitled and Warning Letters, leading many to view promotional enforcement as relatively predictable and infrequent....

Quality & Compliance

Understanding Statistical Intervals: Part 3 - Tolerance Intervals

We saw in Part 1 of this series how a confidence interval can be calculated to define a range within which the true value of a statistical parameter such as a mean or standard deviation is likely to...

Unapproved Codeine Products and Some DESI Drugs need FDA Approval or Cease Marketing

In a Federal Register notice published today, the Food and Drug Administration (FDA) announced its intention to take enforcement action against misbranded or unapproved prescription products...

Quality & Compliance

The $142 Million Question: Will the Kaiser Judgment Encourage More Private Payor Actions for Off-Label Promotion?

If enforcement against pharmaceutical companies for off-label promotion by the Office of Inspector General (OIG) and the Department of Justice (DOJ) and the Food & Drug Administration (FDA) were not...

Regulatory Sciences

FDA Guidance Follows USP Salt Policy & Aims to Make Conversions Between Salt Forms Simpler

The Food and Drug Administration (FDA) recently published a draft guidance that outlines the “Naming of Drug Products Containing Salt Drug Substances” in accordance with the recently implemented USP...

Quality & Compliance

The Transfer Process Map: Gate Four in the Nine Gate Transfer Process for Moving Production

If you have been following along, you now know that I have reviewed the first three gates to the Nine Gate Transfer Process for moving production from site to site. I have covered: Gate 1: Assessment...

What is the Future for Pharmaceutical Compounding Companies?

The Food and Drug Administration (FDA) may soon be cracking down on compounding pharmacies according to a recent bill introduced in the United States Legislature. The bill (Drug Quality and Security...

Critical Elements of Knowledge Management in a Pharmaceutical Quality System

The concepts detailed in ICH Q10, Pharmaceutical Quality Systems (PQS) are commonly understood and are progressively being employed in modern quality management systems. The intent of the PQS...

Regulatory Sciences

Not a Bitter Pill to Swallow: FDA Releases Guidance on Size and Shape of Generic Drugs

In a Federal Register notice to be published on Dec. 10, 2013, FDA announced the release of a new guidance titled “Size, Shape and Other Physical Attributes of Generic Tablets and Capsules.” The...

Full-Service CRO

The Transfer Plan: Gate Three in the Nine Gate Transfer Process

Today I would like to present the third entry in the series discussing the Nine Gate Transfer Process for moving production from site to site: the Gate 3 Transfer Plan. In case you missed them, you...

Why Measure and Report Quality Metrics?

A wise man recently told me that “honor and respect should be given freely, but trust is earned”. Whether it’s in politics, friendships, church, marriages, parenting or even the business world,...

Full-Service CRO

Stakeholder Review: Gate Two in The Nine Gate Transfer Process for Moving Production

In this, the second entry in the series, I will review Gate 2 of the Nine Gate Transfer Process utilized by ProPharma Group for successful technical transfers. Refer to my first entry for further...

Regulatory Sciences

FDA Proposes Controversial Rule Allowing ANDA Applicants to Change Drug Labels

On Nov. 13, 2013, the Food and Drug Administration (FDA) published a Proposed Rule in the Federal Register. The title of the Proposed Rule is “Supplemental Applications Proposing Labeling Changes for...

Quality & Compliance

OIG Signals Importance of Board-Level Compliance Committee in J&J Corporate Integrity Agreement

In the just issued Johnson & Johnson Corporate Integrity Agreement (CIA), the Office of Inspector General (OIG) has, for the second time in less than a year, required that a company maintain a...

Full-Service CRO

The Nine Gate Transfer Process for Moving Production from Site to Site: Gate 1

Pharmaceutical news today featured another article about a manufacturing plant closure and the layoff of a thousand employees. Demand for pharmaceutical products continues to grow and will continue...

Quality & Compliance

Government Aims its Sights on Smaller Pharmaceutical Companies

Big pharma and their deep pockets have been the focus of enforcement activities for a number of years but in 2013 that tide may be turning. In the past few months, settlements with ISTA...

What to Expect During the NDA Review Process

Compiling and submitting a New Drug Application (NDA) submission is a complicated and intensive activity. Once you have submitted your application to FDA, you may be curious about what can you expect...

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Safety Data Exchange Agreements (SDEAs) and Pharmacovigilance Agreements (PVAs) – An Overview

A Safety Data Exchange Agreement (SDEA) or Pharmacovigilance Agreement (PVA) is a legal written contract which ensures that all safety data, PV tasks and responsibilities are detailed between two or...

FDA Shelf Life Extension Program (SLEP)

The FDA’s homepage contains an item in the Public Health Focus section from the Office of Communications entitled “Don’t Use Expired Medicine.” Given this mandate, I recall from many years ago the...

An Overview of the PSMF: Pharmacovigilance System Master File

What is a PSMF? The EU Pharmacovigilance System Master File (PSMF) is a legally required document created and maintained by a Marketing Authorisation Holder (MAH). Essentially, the document is a...

Illustration of the Common Technical Document (CTD) Triangle

The Importance of the eCTD Structure for FDA Approval

The Importance of the eCTD To harmonize the process of regulatory reviews for global drug development, a unified structure was developed and implemented for electronic Common Technical Document...

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What is the FSP Model in Clinical Research?

The term Functional Service Provider (FSP) concept is highly regarded in the field of clinical research. With drug discovery and clinical trials becoming more complex, pharmaceutical firms and...