Preparation is key in preventing delays for obtaining orphan drug designation

Orphan Drug products give patients with rare diseases hope. The Orphan Drug Act, originated in 1983, features incentives for companies to develop drugs to treat a rare disease or condition by giving tax credits on clinical trials, eligibility for seven years of market exclusivity and no user fees.  More and more companies are jumping on this bandwagon which no doubt means a demanding number of requests for the FDA to review.  FDA continues to work on their review processes as Gayatri Rao, M.D., J.D. explains in her recent article on the FDA voice.  Her message to companies is to prepare designation requests with much attention to detail and requirements.  This preparation will minimize the number of review cycles needed with the FDA and get the therapies to the patient faster.  Call on Pearl Pathways to work with you and provide the attention to detail you require in your orphan drug designation requests.

Could FDA be made into an independent federal body?

Former FDA commissioners recently gathered at the Aspen Ideas Festival’s Spotlight Health discussing ways to minimize bureaucratic and political red tape.  FDA’s science based recommendations of safety and efficacy of food and drugs many times have political pressures and challenges to overcome.  Former regulation executives coming together to share and leveraging their many years of experience may ultimately produce a positive change.   Perhaps there could be a better path forward than the current system we have in place?  Check out Sy Mukherjee’s informative article on Fortune.

Reminder of eCTD Deadlines Approaching

A reminder that Electronic Common Technical Document (eCTD) deadlines are approaching. All submissions to the FDA including NDA, ANDA, BLA and DMFs are required to be submitted in eCTD format beginning on May 5, 2017.  IND submissions are required to be submitted in eCTD format beginning on May 5, 2018.  FDA informs that submissions that do not meet the specifications in the eCTD guidance will not be filed or received.  Paper will no longer be accepted after the dates noted.

Pearl Pathways has an experienced team to help with your regulatory submission authoring, publishing, and eCTD filings. Contact us for a value added partner to assure no interruption in your regulatory filings.

Let Pearl Pathways help with your biocompatibility concerns

Pearl Pathways invites you to look over a final guidance just released by the FDA Use of International Standard ISO 10993-1, “Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process.”  This encourages medical device manufacturers to first start with a risk assessment to determine if new biocompatibility testing is required for premarket submissions.  It also explains new test-specific recommendations to follow.

The FDA is also holding a free webinar on July 21, 2016 discussing this final guidance. Click here for information on how you can dial-in to hear the presentation and also ask questions. Registration is not necessary.

Pearl Pathways’ experienced team is ready to assist your product development team with your biocompatibility evaluations. Contact us to be your partner in accelerating your product development regulatory pathways.

News on Compassionate Use

The FDA has been working to improve the process used by physicians to request Expanded Access — Compassionate Use to investigational drugs and biologics for their patients who need these therapies to stay alive.  In a statement released in early June from FDA Commissioner Robert Califf, M. D., the FDA released 3 guidance documents with information on Compassionate Use drugs and biologics.

The first guidance to note covers Individual Patient Expanded Access Applications – Form FDA 3926.  New Form 3926 is specifically for physicians to use to request access to investigational drugs for their patients who need these therapies to stay alive.  FDA also has instructions for completing the form.

There are 2 additional guidance documents to note that provide additional clarity on Compassionate Use. One of the guidance documents explains Compassionate Use using a Question and Answer format – click here to read.  The other guidance covers how a patient may be charged for these investigational drugs – click here to read.

Pearl Pathways’ and Pearl IRB’s experienced teams are ready to help you with this process. Expediting regulatory pathways is what we are about — contact us.

Update on OTC Drug User Fee program activity

FDA’s recent public meeting on June 10th discussing a user fee program for over-the-counter (OTC) drugs indicates new activity in this program. Expert opinion was heard at the meeting with the acknowledgement that this is a very enormous undertaking with a small staff of 18 employees to manage.  The idea is that implementing a user fee program may result in great benefits and advances in over-the-counter drugs to help us manage symptoms and conditions safely without the oversight of a doctor.

Zachary Brennan, RAPS, posted an article that has additional informative links that follow the current FDA activity on this topic.  Brennan indicates that FDA is still seeking input/perspectives from stakeholders as they work toward a more defined approach.  Help them take a first “bite” into this huge project by commenting.

Using Comparability Protocols for CMC postapproval changes

FDA issued a draft guidance in April with recommendations on using a Comparability Protocol (CP) when implementing a chemistry, manufacturing and controls (CMC) postapproval change. FDA defines a CP as a comprehensive plan for “assessing the effect of a proposed CMC postapproval change(s) on the identity, strength, quality, purity, and potency of a drug product or a biological product (i.e., product), as these factors may relate to the safety or effectiveness of the product (i.e., product quality).” When assessing how a CMC change may affect product quality under a CP, be sure to have the following established for continuous improvement:

  • An understanding of the product and manufacturing process
  • A robust control strategy
  • Risk management activities over a product’s life cycle
  • An effective pharmaceutical quality system

 

For more information, read Dan Stanton’s article at in-PharmaTechnologist. Let Pearl Pathways help you with your CMC approach and regulatory submissions for both drug substance and drug product. Contact us here.

Deadline fast approaching for Class II medical device compliance with UDI

September 24, 2016, a date fast approaching, is the deadline for Class II medical devices to be compliant with unique device identifier (UDI) regulations. For compliance, device manufacturers have to submit device identifiers (DI) to FDA for inclusion in the GUDID (Global Unique Device Identifier Database). Device labeling documentation planning is key since once the DI is submitted for a device and entered into the GUDID; further, there are rules for editing during a grace period only and companies may find themselves in situations requiring them to have to obtain a new DI for a device. Keep watching for any FDA updates that may post as this deadline approaches.

More details can be found in Michael Mezher’s informative article posted on RAPS. Pearl Pathways has an experienced team ready to help with your UDI compliance planning and execution, contact us here.

What is your company doing about Cybersecurity for Medical Devices?

cybersecurityEarlier this year, FDA released recommendations for medical device manufacturers in managing cybersecurity risks related to safety, efficacy, and integrity of medical devices and patient health. If you haven’t already, take a look at this timely draft guidance from the FDA to learn more. The draft guidance addresses cybersecurity issues throughout the entire product lifecycle of a networked medical device that utilizes software (firmware) and includes the ever important postmarket management. Risk to device functionality or loss of important data due to a cybersecurity risk is a consideration that could result in bad outcomes for patients. Device manufacturers need to take a look at their own risk management programs and assure they have a comprehensive plan established.

Pearl Pathways looks forward to the opportunity to work with you and provide support to your ongoing successful product development activities including risk management program development as part of your overall Quality System. Contact us to set up a discussion.

Image courtesy of thomasdinnocenzi.wordpress.com

Gretchen Bowker speaking at the IMDMC REG 101 workshop on April 21st

imdmcThe Indiana Medical Device Manufacturers Council (IMDMC) is hosting a workshop on April 21st for those new to the medical device industry or for those looking for a regulatory refresher. Pearl Pathways’ own, Gretchen Bowker COO & RAC, FRAPS, will be presenting on, Pathways to Market – 510(K) Requirements at 10:15am. The workshop provides a background in FDA regulations of medical devices.

What: A workshop exploring FDA regulations of medical devices and pathways to market.

When: Thursday, April 21st, 2016, 8:00 AM to 5:00 PM EDT

Where: The Montage – 8580 Allison Pointe Boulevard, Indianapolis, IN 46250

Are you new to the medical device industry? Do you want to learn more about the FDA and the Pathways to Market? Register here today! (Lunch will be provided.)

To learn more about the workshop and register for REG 101 & 102 Workshop, click here. We hope to see you there on April 21st!