FDA and NIH Release the Best Free Tool to Write Clinical Protocols

This week, FDA and NIH released a template for clinical trial protocols that practically took away any excuses one may have to not write a good quality clinical protocol. This template was jointly developed by clinical trial experts at NIH and FDA for government-funded researchers, in collaboration with a non-profit group that was developing a … Read more

Using Foreign Vendors? FDA’s Warning Letter Points A Common Issue   

This week FDA released a Warning Letter* issued to a GMP vendor in India that points to a very important issue that all companies using vendors, specifically foreign vendors, should be aware of, namely, who is listed as the manufacturer on the Certificate of Analysis (COA). Is the vendor being truthful about its sub-vendors and … Read more

How Much Diversity is Required for FDA Approval?   

Clinical trial populations are not very diverse. Minority populations form a very small fraction of the trial populations, much below their proportion in the US population leading to concerns about the effectiveness of approved products in populations under-represented in clinical trials. Since 2014, FDA’s Action Plan to Enhance the Collection and Availability of Subgroup Data requires … Read more

FDA’s Action-Inaction About Unapproved Drugs

This week FDA announced that it sent Warning Letters to 14 manufacturers of about 65 dietary supplements making claims to treat cancer. One wonders what triggered this event and why did it take this long as obviously these companies did not spring up overnight. FDA’s news release about this event painted a rather innocent picture; … Read more

What Are the Most Common GMP Deficiencies Found by FDA?  

The regulators publish lists of common deficiencies to create awareness about the kind of concerns raised by auditors in a given period. Such lists are useful to understand the common areas of error and may help reduce those findings in future at other organizations. Few weeks back, MHRA, the regulators in the UK, published common … Read more

Should Medical Food Clinical Trials be Conducted Under INDs? May

Last month, FDA issued a Warning Letter to a California medical foods company, Targeted Medical Pharma (TMP), for conducting clinical trials without an IND. This is an interesting case study that highlights common regulatory issues with most companies doing clinical trials, and more specifically medical food and supplement developers. First, FDA regulates products based on … Read more

FDA Does Not Regulate Smartphone Apps, But Courts and FTC Do

FDA does not treat most healthcare related smart-phone apps as medical devices, leaving it to the FTC and state regulators to regulate apps based on claims and complaints. Healthcare apps, mostly hosted on Smartphones, smart watches and other wearable devices, are popular due to high acceptance by consumers and seemingly endless possibilities. Apps can be … Read more

Off-Label Promotion Gets Political Support But Is It Good For Consumers? 

On 21 March 2017, the State of Arizona became the first state to pass the “Free Speech in Medicine Act” which allows manufacturers to practically discuss all kinds of off-label information with doctors and healthcare providers, without fear of prosecution. The day after, a similar bill, “Medical Product Communications Act, 2017”, was introduced in the … Read more

FDA Audit Processes to Change Dramatically in May 

The FDA’s Office of Regulatory Affairs (ORA), which is responsible for all audits conducted by FDA, is undergoing a major reorganization starting 17th May this year, which is expected to dramatically change how FDA audits. ORA will distribute its auditors into five specialized commodity-based groups, plus one group for clinical trial audits. This is radically … Read more