Unsatisfactory Manufacturing Facility Inspection
Severity: criticalDuring a recent inspection of Sun Pharmaceutical Industries Limited, Halol-Baroda 389350, Gujarat, India, our field investigator conveyed deficiencies to the representative of the facility. Satisfactory resolution of these deficiencies is required before this application may be approved.
Recommended response: Address all deficiencies identified during the facility inspection and ensure satisfactory resolution with the agency.
Labeling Review Pending
Severity: majorThe agency reserves comment on the proposed labeling until the application is otherwise adequate. The applicant is encouraged to review PLR Requirements for Prescribing Information, Pregnancy and Lactation Labeling Final Rule, and the Selected Requirements for Prescribing Information (SRPI) checklist. Any revised labeling must conform to format items in regulations and guidances and include updated content of labeling in structured product labeling (SPL) format.
Recommended response: Revise labeling according to PLR requirements, Pregnancy and Lactation Labeling Final Rule, and SRPI checklist. Submit updated content in SPL format.
Cited: 21 CFR 314.50(l)(1)(i)
Proprietary Name Resubmission Required
Severity: minorThe proposed proprietary name, Ezallor, was found acceptable pending approval of the application in the current review cycle. The applicant must resubmit the proposed proprietary name when responding to the application deficiencies.
Recommended response: Resubmit the proposed proprietary name 'Ezallor' with the complete response.
Comprehensive Safety Update Required
Severity: majorA comprehensive safety update is required as described at 21 CFR 314.50(d)(5)(vi)(b). This update must include data from all nonclinical and clinical studies/trials, regardless of indication, dosage form, or dose level. Specific requirements include: describing significant changes in safety profile; presenting new safety data from studies/clinical trials for the proposed indication; presenting tabulations of new safety data combined with original NDA data; including tables comparing frequencies of adverse events; providing separate tables for adverse events in clinical trials for other indications; retabulating reasons for premature trial discontinuation; providing case report forms and narrative summaries for patient deaths or discontinuations due to adverse events, and for serious adverse events; describing information suggesting substantial change in incidence of common, less serious adverse events; providing updated exposure information for clinical studies/trials; providing a summary of worldwide experience on drug safety, including updated estimate of use for marketed drugs in other countries; and providing English translations of current approved foreign labeling not previously submitted.
Recommended response: Compile and submit a comprehensive safety update as per 21 CFR 314.50(d)(5)(vi)(b), including all requested clinical and nonclinical data, worldwide experience, and foreign labeling translations.
Cited: 21 CFR 314.50(d)(5)(vi)(b)