Product Quality Deficiencies
Severity: majorSpecific product quality deficiencies were identified, but details are withheld as confidential commercial information (b4 (CCI/TS)). These issues prevent approval in the current form.
Recommended response: Address all specific product quality deficiencies as detailed in the withheld sections of the letter. This likely involves further data submission, process improvements, or analytical method validation to ensure product quality and consistency.
Outstanding Facility Inspection
Severity: criticalAn inspection of a manufacturing facility (FEI #) is required before this application can be approved. Due to the timing of incorporation of the site into the license application, the FDA was unable to conduct an inspection during the current review cycle.
Recommended response: Coordinate immediately with the FDA to schedule and successfully complete the required facility inspection. Ensure the facility is fully prepared and compliant with current Good Manufacturing Practices (CGMP).
Inadequate Prescribing Information (Labeling)
Severity: majorSubmit draft labeling responsive to the electronic communication dated July 14, 2023. Correct formatting errors using the SRPI checklist and submit updated content of labeling in structured product labeling (SPL) format as described at FDA.gov, conforming to 21 CFR 601.14(b). The proposed Prescribing Information (PI) must also conform to the content and format regulations found at 21 CFR 201.56(a) and (d) and 201.57.
Recommended response: Revise the Prescribing Information (PI) and submit in SPL format, ensuring full compliance with all cited regulations and guidance documents. Utilize the SRPI checklist for formatting and provide both marked-up and clean Word versions to facilitate review.
Cited: 21 CFR 601.14(b), 21 CFR 201.56(a), 21 CFR 201.56(d), 21 CFR 201.57
Incomplete Safety Update
Severity: majorInclude a comprehensive safety update as described at 21 CFR 314.50(d)(5)(vi)(b) when responding to deficiencies. This update must detail significant changes in the safety profile, present new safety data from studies/trials, provide retabulations of adverse events, include case report forms and narrative summaries for deaths or discontinuations due to adverse events, and provide updated exposure information.
Recommended response: Compile and submit a comprehensive safety update, including all requested data and analyses, ensuring full compliance with 21 CFR 314.50(d)(5)(vi)(b) and addressing all specific data presentation requirements for clinical and nonclinical safety information.
Cited: 21 CFR 314.50(d)(5)(vi)(b)
Proprietary Name Resubmission
Severity: minorThe proposed proprietary name, Lymphir, was found acceptable pending approval of the application in the current review cycle. Please resubmit the proposed proprietary name when you respond to the application deficiencies.
Recommended response: Include the previously accepted proprietary name in the resubmission package as part of the administrative updates.