Archive for January, 2008

505(b)(2) – Part 3: Pre-IND submission & meeting

Before filing an IND, it is desirable (we counsel imperative) to have a pre-IND meeting with the FDA.  The goal is to get FDA’s concurrence with the proposed development plan and regulatory submission pathway.  The steps for this meeting (known as a Type B meeting) include: Prepare a pre-IND submission package. This package outlines where we [...]

Oral Sleep-Aid Spray Approved Based on BE/Pharmacodynamic Studies

NovaDel announced on January 23, 2008  that FDA accepted their 505(b)(2) filing for an oral spray ZolpiMist (TM).  The reference listed drug is Ambien(R) Tablets.  The press release indicated that the filing was based on “two randomized, open-label, dose-ranging studies comparing ZolpiMist(TM) with Ambien(R) tablets in young and elderly healthy volunteers. Both studies compared the pharmacokinetics [...]

505(b)(2) Audioconference January 28, 2008

I have been invited to present an audio-conference entitled : “The FDA 505(b)(2) Drug Approval Process: How to Navigate the Pathway “.  The event will take place January 28, 2008 from 2:00 – 3:30 EST.  The cost is $349 (I receive no remuneration).  The announcement is here.

505(b)(2) with Only Phase 1 Study

We are often asked if a 505(b)(2) application always requires a clinical study (i.e., Phase 2 or 3 in patients).  The answer is a resounding NO.  On January 14, 2008 ADVENTRX Pharmaceuticals announced the successful completion of a bioequivalence study that demonstrated similar blood levels and a “statistically significant reduction in injection site reactions”.  The company further [...]

505(b)(2) – Part 2: The Assessment: Timeline, Cash Flows

Once the clinical development plan is established, the CMC, regulatory and medical communication plans can be matched up. We use MS Project to develop a high-level overall plan.  MS Project then can be used to generate cash flows and Gantt charts.  This information can be used by the sponsor to determine if the project is financially feasible. [...]

PDUFA 2008 – New Submisison Fees for 505(b)(2) Applications

FDA announced that for 2008 the full application fee for a 505(b)(2) that requires a clinical study will be $1,178,000.  In addition, the establishment fee is $392,700 and the product fee is $65,030.  Small  businesses (defined as entities, including affiliates, with less than 500 employees) may request a  waiver of the PDUFA review fee for [...]

FDA takes action against compounding pharmacies’ estriol-containing hormone products

On January 7, 2008, the FDA issued warning letters to several compounding pharmacies (example) advising them stop compounding hormone products contain estriol, an unapproved new drug.  This activity has been going on since the mid-1990′s, popularized by the actress Suzanne Somer’s books. The general term used by this industry is bio-identical hormone replacement therapy – BHRT. [...]