• where experts go to learn about FDA
  • Deborah L. Livornese

    • Gene Therapy Company Sues FDA After Being Placed on Clinical HoldNovember 11th, 2019

      On November 7, 2019, gene therapy company Regenxbio Inc., filed suit in U.S. District Court in Washington, D.C. against FDA asking the court to set aside a partial clinical hold on one clinical trial and a full clinical trial for another.  The complaint also seeks …

    • New California Requirement for Some CosmeticsOctober 14th, 2019

      On September 20, 2019, the governor of California approved AB 647 which expands the obligations of manufacturers and importers of cosmetics (and disinfectants) containing hazardous substances.  Beginning on July 1, 2020, these manufacturers and importers are required to not only provide safety data sheets (“SDSs”) …

    • Not Dead Yet – Far from It: OTC Monograph Reform Back on Congress’ RadarJune 27th, 2019

      We knew it would be back. It was never dead, though perhaps forgotten by some (never us), but OTC Monograph Reform is back in the public eye again.  Lawmakers appear to be taking to heart CDER Director Janet Woodcock’s remarks last week in which she urged …

    • Ain’t No Sunscreens When It’s Done (Almost): FDA Issues Proposed Monograph on Sunscreens with Only the Oldies but Goodies Categorized as GRASEFebruary 27th, 2019

      Back in 2014, The Sunscreen Innovation Act (“SIA”) amended the Federal Food, Drug, and Cosmetic Act with the goal of accelerating the review of sunscreen ingredients that had been proposed for addition to the sunscreen monograph.  Although the original focus of the SIA was on …

    • Vanda Has A Bone to Pick with FDA: Dog StudiesFebruary 22nd, 2019

      As avowed dog-lovers and FDA law enthusiasts, a recent Complaint filed in the District Court of D.C. caught our attention.  Vanda Pharmaceuticals filed a Complaint on February 6, 2019 alleging that FDA’s insistence that Vanda perform a 9-month dog study with its drug candidate tradipitant …

    • FDA’s Tenth Annual Report to Congress on 505(q) Citizen Petitions: New Numbers and the Same MessageFebruary 12th, 2019

      FDA released its annual Report to Congress on 505(q) Citizen Petitions last week – the Tenth Annual Report to Congress on Delays in Approvals of Applications Related to Citizen Petitions and Petitions for Stay of Agency Action for Fiscal Year 2017.  The Report, which is …

    • Coming Soon for Expanded Access PoliciesJanuary 4th, 2019

      Many companies with investigational drugs have posted an expanded access policy on their websites as required, but more than a few still have this task left over from the 2018 to-do list.  As the time for New Year’s resolutions and new to-do lists is upon …

    • FDA Takes First Step on Path to Monograph for Antiseptics for Food HandlersDecember 10th, 2018

      On Dec. 6, FDA announced that it is formally seeking data, comments and information related to the assessment of safety and effectiveness of food handler antiseptic drug products (rubs and washes) for over-the-counter (OTC) use. Although this is a positive development, judging from the questions …

    • Putting the “Complete” Back into Complete Response LettersOctober 25th, 2018

      A biotech company facing a complete response letter (CRL) action on its NDA/BLA has no greater goal than to quickly and fully understand the deficiencies that FDA has identified in the application.  Such an understanding is critical to addressing the review division’s findings through additional …