Paper

Journal of Generic Medicines (2007) 4, 239–248. doi:10.1057/palgrave.jgm.4950073; published online 1 May 2007

US FDA question-based review for generic drugs: A new pharmaceutical quality assessment system

Lawrence X Yu1, Andre Raw2, Robert Lionberger3, Radhika Rajagopalan4, Lai Ming Lee5, Frank Holcombe6, Rashmikant Patel7, Florence Fang8, Vilayat Sayeed9, Paul Schwartz10, Richard Adams11 and Gary Buehler12

Correspondence: Lawrence X. Yu, Food and Drug Administration, Office of Generic Drugs, 7500 Standish Place, Rockville, MD 20855, USA. Tel: +1 240 276 9310; Fax: +1 240 276 9327; E-mail: Lawrence.Yu@fda.hhs.gov

1is Director for Science, Office of Generic Drugs, Food and Drug Administration.

2is Chemist, Office of Generic Drugs, Food and Drug Administration.

3is Chemical Engineer, Office of Generic Drugs, Food and Drug Administration.

4is Chemist, Office of Generic Drugs, Food and Drug Administration.

5is Pharmacologist, Office of Generic Drugs, Food and Drug Administration.

6is Associate Director, Office of Generic Drugs, Food and Drug Administration

7is Director, Division of Chemistry I, Office of Generic Drugs, Food and Drug Administration.

8is Director, Division of Chemistry II, Office of Generic Drugs, Food and Drug Administration.

9is Director, Division of Chemistry III, Office of Generic Drugs, Food and Drug Administration.

10is Deputy Director, Division of Chemistry I, Office of Generic Drugs, Food and Drug Administration.

11is Deputy Director, Division of Chemistry II, Office of Generic Drugs, Food and Drug Administration.

12is Director, Office of Generic Drugs, Food and Drug Administration.

Received 9 March 2007; Revised 9 March 2007; Published online 1 May 2007.

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Abstract

The US Food and Drug Administration Office of Generic Drugs has developed a question-based review (QbR) for the Chemistry, Manufacturing, and Controls (CMC) evaluation of an abbreviated new drug application (ANDA). This new QbR system incorporates quality by design and implements risk-based assessment. It recommends that ANDAs be submitted using the Common Technical Document and include the Quality Overall Summary (QOS) that addresses all the QbR questions. The main benefits of this QbR system are to (1) assure product quality through design and performance-based specifications, (2) facilitate continuous improvement and reduce CMC supplements through risk assessment, (3) enhance the quality of reviews through standardised review questions, and (4) reduce CMC review time when applicants submit a QOS that addresses the QbR questions. The QbR was partially implemented in 2006 and is being fully implemented in 2007.

Keywords:

generic drugs, abbreviated new drug application, chemistry, manufacturing, and controls, question-based review, quality by design

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GPhA 2009 Annual Meeting, 23-25 Feb 2009, Naples, Florida, USA
World Generic Medicines Congress Europe 2009, 24-27 Feb 2009, London
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