ElMaestro
★★★

Denmark,
2012-01-19 16:19
(5257 d 21:40 ago)

Posting: # 7965
Views: 5,521
 

 FDA enforcing QbD from 2013 [Dissolution / BCS / IVIVC]

Hi all,

I note that FDA has been moving lately in the area of QbD and they seem to be mandating QbD from 2013 for ANDAs / 505(j)'s.
Here's a presentation.

They have even published an example on how it could be done for an MR generic.

I just skimmed through it and I think it is very, very extensive. If this example is in anyway representative of the amount of typically needed from an applicant/developer then I think US development is going to be a lot more expensive in the future.

What's your take on this?

Pass or fail!
ElMaestro
Helmut
★★★
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Vienna, Austria,
2012-01-19 16:48
(5257 d 21:11 ago)

@ ElMaestro
Posting: # 7966
Views: 4,511
 

 FDA enforcing QbD from 2013

Dear ElMaestro!

❝ What's your take on this?


Ooh–ooh! We discussed the draft already last year. Saw one presentation by a representative of the FDA last year (forgot where…) – seemed to be very serious about “That’s the way to go!”.
Would be tough to meet these requirements. Could FDA really reject an ANDA if BE was demonstrated in vivo, similar dissolution (f2), and an established IVIVC if the development was not done according to their interpretation (sic!) of Section 2.1 of ICH Q8(R2)? Any lawyers around?

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