CCH NetNews™

(July 29, 2008)

Food and Drug Law

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Featured This Week:

CGMPs for phase 1 drugs amended, guidance released

— The FDA amended the current good manufacturing practice (CGMP) regulations for human drugs, including biological products, to exempt most phase 1 investigational drugs. The agency reasoned that human drug products intended for use in phase 1 clinical trials should be exempt they remain subject to statutory adulteration requirements and because the FDA oversees these phase 1 trial drugs through its existing investigational new drug applications authority. FDA Order, ¶40,350D.

CPG for decomposing fish available; old CPG withdrawn

— A draft compliance policy guide (CPG) on fish decomposition provides regulatory action guidance relating to the FDA's direct reference enforcement policy, including a description of a two-class, pass/fail evaluating approach for detecting the presence of decomposition by sensory or chemical analysis. When the draft CPG is final it will replace withdrawn and revoked CPGs relating to decomposition in fish and shrimp. Comments on the draft CPG are due by September 16, 2008. FDA Guidance, ¶330,388.

Immune globulin intravenous products: trial designs

— A guidance providing information on the design of clinical trials to assess the safety, efficacy, and pharmacokinetics of investigational immune globulin intravenous products when used as replacement therapy in primary humoral immunodeficiency has been issued by the FDA. The document is intended to assist sponsors in the preparation of the clinical/biostatistical and human pharmacokinetic sections of a biologics license application and investigational new drug application. FDA Guidance, ¶320,384.

Ephedrine in dietary supplements ban

— A small entity compliance guide explaining the FDA's ban on ephedrine alkaloids in dietary supplements is available to help small businesses understand the regulation. The FDA issued the ban on February 11, 2004, finding that dietary supplements with ephedrine present an unreasonable risk of illness or injury under conditions of use recommended in labeling or under ordinary conditions of use. FDA Guidance, ¶330,386.

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