Bringing Drugs to Market

Investigational New Drug Application (IND
Clinical Trials
1.Phase 1         Small Number (20-80 subjects) - Pharmacological Effects, Safety
2. Phase 2        Several Hundred Patients - Effectiveness, Risks and Side effects<
3. Phase 3        Several Thousand Patients Clinical Trials
4. Phase 4 Post Marketing Surveillance

 

ANDA

 

SNDA

 

Marketing New Drugs

Patent Protection – 17 years

 

NDC Codes 10 digits
1234    5678    90

 

GMP’S (good manufacturing practices)

Regulations that apply to manufacturers

Adulteration and Misbranding
Adulteration – The Kansas City pharmacist, expired drugs in Ohio, or just plain old contaminated drugs.

Misbranding – Something is missing, something is incorrect, etc

 

Labels versus Labeling

Labels are on the products.

Labeling includes labels and all other printed and promotional materials. Have to be approved by FDA.

 

Package Inserts. (Labeling) 13 Categories of information in package inserts.

 

Identification of solid dosage forms.

Every tablet and capsule must be imprinted in some way.

 

Pregnancy Warning Categories.

 

Unapproved Use of Approved Drugs

This is considered off-label use.

It is permitted if there is a rationale basis for it.

Cannot be promoted by manufacturer.

 

Drug Recalls

Class I Most Serious

Class II Less Serious

Class III No Problem

 

Difference between a drug recall and FDA seizure. Can the FDA order a recall?

 

Expiration Dating vs. Beyond Use Dating

Expiration date applies to Manufacturer.

Beyond Use Dating applies to pharmacist.

 

Poison Prevention Packaging Act (PPPA)

This means childproof containers.

Applies to all oral solid dosage forms.

How can patients waive the childproof containers?

How does this affect refill processing? Can containers be used over?

Are any drugs exempted from the PPPA?

 

Patient Package Inserts

Only required for certain drugs.

Written Documents in lay terms that explain the drug’s uses, side effects, dangers etc.

Must accompany every dispensing.

Institutional patients – every thirty days.

 

Drug Product Substitution

Orange book. What are “A” rated drugs and “B” rated drugs?

 

Treatment of Narcotic Dependence

Detoxification Treatment –

Maintenance Treatment –

 

Methadone Maintenance-

Must be given to the patient in oral liquid form.

Prescriptions cannot be written for methadone for maintenance treatment.

 

Short Term Detoxification Treatment

Long Term Detoxification Treatment

 

Over the Counter (OTC) drugs.

Labeling Requirements. – Seven Point: Label.

New regulations now require “Drug Facts”.

 

Switching from Prescription Status to OTC status.

1.         NDA

2.         FDA grants exemption

3.         Supplemental NDA

4.         Nonprescription Drug Advisory Committee advises that an ingredient is safe for OTC use.

 

Dietary Supplements

Dietary Supplement Health Education Act. (DSHEA).

This law exempts health foods, supplements, and herbal products from FDA controls for OTC and prescription drugs.

 

No efficacy requirement

No safety requirement.

Products do not have be manufactured under GMP’S.

Labeling CANNOT claim to cure, treat, or prevent disease.

Claims to affect bodily function are permitted.

So “for the prostate” is OK. But “This drug will cure an enlarged prostate.” Is not acceptable.

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