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  • 1.  Type V DMF LOAs for BLAs

    This message was posted by a user wishing to remain anonymous
    Posted 24-Sep-2019 10:43
    This message was posted by a user wishing to remain anonymous

    I represent a CMO that manufactures biologic and drug products. Our clients have historically requested a Letter of Authorization (LOA) to our Type V DMF.  However, recently we have had more Biologic clients pushing back against the LOA based upon the June 2019 Federal Register Docket No. FDA-2019-N-1363.

    My question is how are CMOs protecting the confidentiality of their clients and facility processes without referencing their DMFs, while still providing information needed by clients for successful submissions?



  • 2.  RE: Type V DMF LOAs for BLAs

    This message was posted by a user wishing to remain anonymous
    Posted 25-Sep-2019 10:31
    This message was posted by a user wishing to remain anonymous

    At a CDMO, and struggle with the same challenge.  We are going global, and the DMF is not universal. Assume confidentiality agreement and Quality agreement is in place:

    I suggest a generic 32A1 (~10 pages), likely with drawings that will need to be maintained and updated in parallel for all commercial clients.
    The list of products in the plant is most challenging.  I keep two, one remaining confidential  to send directly to regulators, and a "blinded" one that is high level enough that it may be shared.  "CHO based oncology product".  For both, add a statement that nothing is highly potent or toxic.

    The mainenance and notification of changes is the real issue, and should be tied to annual reviews.  I think we are obligated to maintain any commercial submission, but for clinical submissions it may be a negotiation between you and the client if a US trial and they do not accept the LOA.  You are providing an accurate snapshot of the state of the facility at the time of production for the clinical material.