Yes. FDA's
Guidance for Industry Q1A(R2) Stability Testing of New Drug Substances and Products states "Where possible, batches of the drug product should be manufactured by using different batches of the drug substance.". I would manufacture DP registration batch #1 with API Lot #1, DP registration batch #2 with API Lot #2, and then DP registration batch #3 with a mix of API Lots #1 & 2.
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Tom
Senior Director, Regulatory Affairs CMC
Chicago
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Original Message:
Sent: 16-Feb-2020 09:35
From: David Lucking
Subject: Number of API Lots
Dear Colleagues,
Is it acceptable to submit a NDA with 3 drug product registration batches manufactured with 2 different lots of API rather than 3?
Thank you for your asiatnce.
Best regards,
David Lucking
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David Lucking
FL
United States
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