Regulatory Open Forum

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  • 1.  Excipient question

    Posted 30-Jan-2016 14:28

    I have a client who formulated a topical cream.  They used 0.625% pantothenate (aka Vitamin B5) in the formulation as a functional excipient to enhance solubility as a weak acid.  I don't see it in FDA's excipient database, but have found Bayer's Bepanthen Cream sold OTC in France has 5% pantothenate in it and that back in 1978 FDA's Select Committee on GRAS Substances declared it safe.  So:

     

    1. Is there any alternate database to refer to levels of specific excipients in products for safety, other than the IIG database the FDA currently uses?  And if not …

     

    2. What is the official, or best way to declare an old, unlisted excipient, to avoid a RTR from FDA's OGD division where there's no DMF to reference, it's a B vitamin and declared safe by an FDA committee back in 1978?

     

    Perhaps go in with a Controlled Correspondence first?

     

    Thanks for any suggestions.

     

    Chris

     

    Christopher Smith, CQE, RAC

    President, Coastal Pharmaceutical Consultants, Inc. ®

    7950 Old River Road, Burgaw, NC 28425 USA

    910-259-8877 (land)

    910-789-1232 (mobile)

    chrissmith@coastalpharmaconsultants.com

     



  • 2.  RE: Excipient question

    Posted 31-Jan-2016 09:19
    Is this a Rx or OTC drug?

    David Steinberg, FRAPS
    President
     

    SteinbergAndAssociates.com
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  • 3.  RE: Excipient question

    Posted 01-Feb-2016 07:20

    The product is Rx.