Regulatory Open Forum

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  • 1.  Change of Contract Laboratory with FDA

    This message was posted by a user wishing to remain anonymous
    Posted 26-Jul-2018 09:16
    This message was posted by a user wishing to remain anonymous

    Hello!

    Does anyone know if it's possible to change contract laboratory mentioned (or not) in an original NDA? We have a very very old paper NDA and can't find the mention of this lab. We want to change lab but we are not sure it even was ever mentioned in the NDA. What would be the best route to go about this?

    Thanks in advance for your help!


  • 2.  RE: Change of Contract Laboratory with FDA

    Posted 07-Aug-2018 11:58
    ​You could use the PAC-ATLS guidance to add a laboratory.

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    Ruth Collins RAC
    Manager Regulatory Affairs
    Euless TX
    United States
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  • 3.  RE: Change of Contract Laboratory with FDA

    This message was posted by a user wishing to remain anonymous
    Posted 21-Aug-2018 08:58
    This message was posted by a user wishing to remain anonymous

    ​Great - thank you for the direction!


  • 4.  RE: Change of Contract Laboratory with FDA

    This message was posted by a user wishing to remain anonymous
    Posted 21-Aug-2018 16:06
    This message was posted by a user wishing to remain anonymous

    It will be tricky to mention (unsure) contract testing site in your submission. As of now the best route I can think of is to submit the new contract lab site as an alternative in your supplement.


  • 5.  RE: Change of Contract Laboratory with FDA

    Posted 22-Aug-2018 11:10
    Short term, ​I agree the new site could be filed as an alternate - the risk is that if the original lab is listed in the filing, and any issues are discovered at the lab or the lab goes out of business, there may be issues.  If this is a product you plan to continue to support/market for some time, it might be a great opportunity to file a new "baseline" submission, and bring the filing into the electronic age.  Good luck!

    Cathy

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    Catherine Anderson PhD, RAC
    Senior Manager - Regulatory CMC
    Hillsborough NC
    United States
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