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The agenda for a meeting of the FDA Advisory
Committee for Pharmaceutical Science in early October basically
contained two topics: an update on International Conference on
Harmonisation (ICH) quality issues and the discussion about their impact
on current regulatory direction and the discussion about the status, the
challenges and next steps for implementing Quality-by-Design.
With regard to ICH's quality topics the committee felt that "ICH
guidance is adequate in providing appropriate level of details for both
experienced and inexperienced companies for most topics." It recommended
the agency though to consult with the industry and to observe
submissions for deciding on further guidances. Relative to developing
additional guidelines for the new concept "Design Space" the committee
preferred a certain flexibility to avoid limiting companies when making
their submissions. In the committee's opinion it is also premature to
decide on additional guidance for something that has only been existing
for a short period of time and in a small number.
Concerning the implementation of Quality-by-Design (QbD) the
committee agreed that QbD principles should increase product quality
assurance, provide applicants with more flexibility for continuous
improvement and decrease the need for FDA regulatory control on
post-approval changes.
For the committee it was too early in the process to determine
whether plans and efforts for the implementation of QbD were adequate or
not. Committee members suggested to keep track of the implemented
programmes. With regard to the FDA's query about the development of a
specific QbD pilot programme supporting biotechnology the group
recommended to consider it.
The summary minutes for the meeting are available at the following
address:
http://www.fda.gov/ohrms/dockets/ac/06/minutes/2006-4241m1.pdf
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