Regulatory Open Forum

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  • 1.  FDA action dates

    Posted 28-Jun-2019 10:42

    Hi Regulatory family, 


    Happy Friday!!!

    Can anyone help with the FDA action dates on the following submissions:


    Annual report, CBE-0, CBE-30, PAS, OPDP, ODD, IR's, LDR, PADER, Draft/Final protocols.


    In other words, when can I expect from the FDA to hear back regarding my submission.

    By reading the guidance, CBE-0 and CBE-30 FDA has 1 year to respond. For PAS is 6 months. Attending some of the FDA conferences people mentioning for PAS, FDA action date would be 4 months after submission-when initial FDA review is done. SO ai ma very confused on when is the initial review done vs approval/reject of the submission.


    I would really appreciate your help for any of these submissions,


    Thank you,


    Masa



    Maša Razić
    Regulatory Affairs Specialist
    m:339.223.7784 I masa.razic@partnertx.com 
    PARTNER THERAPEUTICS



  • 2.  RE: FDA action dates

    Posted 01-Jul-2019 11:54
    NDA Annual Reports are due within 60 days after the reporting period ends and FDA won't acknowledge, approve or respond.
    I thought CBE-0 and CBE-30 supplements have a 6-month review clock although you can implement the changes immediately for CBE-0 and after 30 days for a CBE-30, but formal approval won't be received until 6 months.
    PAS have 6-month review for efficacy supplements, but only 4 months for CMC so that may be why you are hearing both 4 and 6 months.
    Information Requests (IRs) from FDA typically include a date that FDA wants a response by.
    Protocol submissions to INDs typically don't warrant FDA response unless you specifically request.  I don't believe FDA is held to any formal PDUFA review clock, but if you request feedback I think 1-2 months is typical (others with more experience may comment otherwise). The initial protocol in your original IND gets a 30-day review with the entire IND before you can proceed to starting the study.  FDA will issue a May Proceed Letter for the original IND as long as they have no issues.
    A formal Special Protocol Assessment (SPA) submission is a 45 day review.

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    Tom
    Senior Director, Regulatory Affairs CMC
    Chicago
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