Handbook of Pharmaceutical Generic Development Vol 12 Part 2

SEMISOLID
TOPICAL DOSAGE FORM
HANDBOOK
OF
PHARMACEUTICAL
GENERIC DEVELOPMENT
S E M I S OLIDS
VOLUME XII Part Two
Generic Development Topical Dosage Forms
HANDBOOK OF PHARMACEUTICAL GENERIC DEVELOPMENT Handbook of Pharmaceutical Generic Development 24 Volume Series
Handbook of Pharmaceutical
handbooks@locumusa.com http://www.l o c u m u s a . c o m
Generic Development
SEMISOLID
TOPICAL DOSAGE FORM
Handbook of Pharmaceutical Generic Development Series

Compiled by :
J. D. BLOCK
BSc. MPS. D/PHARM. Research Director Generic & Innovative Drug Development Division, Locum International Group. Science Editor - International Journal of Generic Drugs & International Journal of Drug Development School of Pharmacy University of the Witwatersrand and Witwatersrand Technikon Johannesburg RSA.
Edited: IAGIM Scientific Committee Review Process : Generic & Innovative Drug Development Division Research Center
Locum International Research
Handbook of Pharmaceutical Generic Development

Part I (Development) & Part II (Model ANDA or EU Dossier)
Vol. 1 - Tablets Vol. 2 - Capsules Vol. 3 - Semisolids Vol. 4 - Liquids Vol. 5 - SG Capsules Vol. 6 - e-SOPs / SOPs. Vol. 7 - Suspensions Vol. 8 - Eye & Nose Vol. 9 - Aerosols MDI Vol. 10 -Tablets CR/MR Vol. 11 -Capsules ER Vol. 12 - Tablets Oral DR Vol. 13 - Analytical
(Top 50 Generic Assay Methods)










Handbook of Pharmaceutical Generic Development Handbook of Pharmaceutical Generic Development

Part I (Method Validation) & Part II (Analytical Methods 1994-2003)
Handbook of Pharmaceutical Innovative Development Handbook of Pharmaceutical Innovative Development Handbook of Pharmaceutical Innovative Development Handbook of Pharmaceutical Drug Development (1-5)
(Master Formula & Manufacturing Instructions Parts 1 - 5)
Vol. 14 - Tablets Oral Vol. 15 - Capsules Oral Vol. 16 - Suspensions Oral Vol. 17 - MF and MMI Vol. 18 - MF and MMI Vol. 19 - SOPs/PAI-Checklist Vol. 20 - Sterile Injections
Handbook of Pharmaceutical Drug Development (6-10)

(Master Formula & Manufacturing Instructions Parts 6 - 10)
Handbook of Pharmaceutical Innovative Development

Part I, Part II & Part III. (Development, Manufacturing & Engineering)
Handbook of Pharmaceutical Drug Development

p p ppp
Handbook of Pharmaceutical handbooks@locumusa.com http://www.l o c u m u s a . c o m
Available either on Online, CD ROM or via electronic mail attachment. Additional Drug Specific Volumes in Preparation. An on-going electronic and print series
Generic Development
SEMISOLID
TOPICAL DOSAGE FORM
Electronic < Handbook Series of Pharmaceutical Generic Development

ISSN 0793 8667 - Electronic Version Handbook Development 24 Volume Series ISSN Series Number 0793 761X - Electronic Version

Vol. 1 - Tablets Vol. 2 - Capsules Vol. 3 - Semisolids Vol. 4 - Liquids Vol. 5 - SG Capsules Vol. 6 - e-SOPs / SOPs. Vol. 7 - Suspensions Vol. 8 - Eye & Nose Vol. 9 - Aerosols MDI Vol. 10 -Tablets CR/MR Vol. 11 -Capsules ER Vol. 12 - Semisolids Vol. 13 - Analytical
(Top 50 Generic Assay Methods)










Handbook of Pharmaceutical Innovative Development Handbook of Pharmaceutical Generic Development

Part I (Method Validation) & Part II (Analytical Methods 1994-2003)
Handbook of Pharmaceutical Innovative Development Handbook of Pharmaceutical Innovative Development
Vol. 14 - Tablets Oral DR Vol. 15 - Suspensions Oral Vol. 16 - Capsules Oral Vol. 17 - Master Formula Vol. 18 - Master processes Vol. 19 - SOPs/PAI-Checklist
Handbook of Pharmaceutical Innovative Development Handbook of Pharmaceutical Innovative Development Handbook of Pharmaceutical Innovative Development Handbook of Pharmaceutical Innovative Development
Part I, Part II & Part III. (Development, Manufacturing & Engineering)
Available either on Online, CD ROM or via electronic mail attachment. Additional Drug Specific Volumes in Preparation An on-going electronic and print series
p p ppp
Generic Development
SEMISOLID
TOPICAL DOSAGE FORM
HANDBOOK OF PHARMACEUTICAL
GENERIC DEVELOPMENT
TOPICAL DOSAGE FORM

VOLUME XII
SEMISOLID
Semisolid
Part TWO
F O R M DOSAGE
Jeremy D. Block
B.Sc. MPS. D/Pharm.
International Euro Edition.

L O C U M P U B L I S H I N G H O U S E
handbooks@locumUSA.com / handbooks@locumEURO.com Locum Publishing House - Israel Locum Pharmaceutical Publishers - USA Locum International Publishers - Cape Town
Generic Development
SEMISOLID
TOPICAL DOSAGE FORM
Innovative Series
Handbook of Pharmaceutical G e n e r i c Development
Part
Two
Semi
ANDA Development
s olids
Copyright 1994-00 - Locum Publishing
House Inc. All Rights Reserved.
Neither this book nor any part may be

reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying, microfilming and recording, or by any information storage and retrieval system, without the permission of the publishers.
Locum International Publishers
L o c u m
H o u s e
P u b l i c a t i o n
Generic Development
SEMISOLID
TOPICAL DOSAGE FORM
HPGD Series
Semisolid Dosage Forms
First and Second International Edition - 01/02. First and Second edition published and distributed in UK, US, EU, RSA, Israel and Japan in November 1996-9: by Locum International Publishing House (Houston, Israel, South Africa). Third International Edition - 03 (First Print). Second printing published and distributed in UK, US, EU, Israel, Asia, and Japan in February 2000 by Locum International Publishing House (Houston, Israel, South Africa) in Hard Cover; Soft and Spiral Cover; Electronic Diskette; and e-mail attachment versions. All print and electronic versions identical in content and format. Copyright 1995 - 2000, Handbook of Pharmaceutical Generic Development. Text Copyright 1995 - 2000, Handbook of Pharmaceutical Generic Development. Illustration copyright 1995 - 2000, Handbook of Pharmaceutical Generic Development. Locum International Publishing House PO Box 874, 50 Gilad Street Kochav Yair 44864 Israel. - All right reserved.
ISBN 0793 873X ISBN 0793 8748 - Electronic Version (Diskette, CD ROM, and Online version) Handbook Development 24 volume series. General ISSN Series number 0793 7407 General ISSN Series number 0793 7792 - Electronic Issue (Diskette, CD ROM and Online version are identical in size and content to the printed hard or soft cover version.) Duplication: No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, microfilming, recording or otherwise, without the prior written permission of the copyright owner or subject to the following conditions: Authorization to photocopy items for internal or personal use or internal or personal use of specific company personnel, is granted by Locum International Publishing House, provided that the base fee of $3 per page is paid directly to the Copyright Clearance Center (CCC) 222 Rosewood Drive, Danvers, MA 01923 USA. For organizations that have been granted a photocopy license by CCC, a separate system of payment has been arranged. For additional information, contact the Publications Department Locum International Publishing House; PO Box 874, 50 Gilad Street, Kochav Yair, 44864 Israel.
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Generic Development
SEMISOLID
TOPICAL DOSAGE FORM
EDITORIAL PREFACE
Handbook of Generic Drug Development - Semisolid Dosage Forms his handbook represents the third International Edition for Europe of the ongoing 24 volume series of Generic Drug Development and appears under the cumulative title of the Handbook series of Generic Drug Development. The ongoing series is updated annually at the end of each year. This is an ongoing process as new data, specifications and process techniques are added on a continual and expanding basis. This handbook is fact, never fully complete, as each new annual edition brings an enlarged and extended profile in the drug development process, as well as new agency rules, guidelines and guidance to industry which continue to be added year by year as the global product data base expands. Currently over 150 scientific publications and drug development conferences are annually referenced in the 24 volume Handbook series of Generic Drug Development. This mammoth task presents a continual ongoing commitment by the scientific review committee to the improvement of the technical databases and the product specific drug development requirements and know-how technology accessed through the world wide IAGIM joint ventures and know-how projects currently active in over 15 countries. The Handbook is available in electronic format (Online and CD ROM) and the eformat is up-dated annually to association members of IAGIM.
This third international edition of the Handbook has been redesigned and updated
to meet the January 1999 Guidance for Industry - Organization of an Abbreviated New Drug Application and an Abbreviated Antibiotic Application as well as all current approved and draft FDA guideline requirements of the Center of Drug Evaluation and Research (CDER). Editor-in-Chief.
ISSN 0793 873X
An on-going series Additional Volumes in Preparation
General Series ISSN 0793 7407 Electronic Series ISSN 0793 7792
0793 7407 International Print Edition
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LOCUM
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Generic Development
SEMISOLID
TOPICAL DOSAGE FORM
Acknowledgments
I.A.G.I.M. (R&D) Foundation.
I.A.G.I.M. Members (1994 - 2000).

Contributions - Generic & Research Firms Associate Universities, Technicons and Consultants.
Handbook Series Coordinating Committee. International Journal of Drug Development. Journal of Pharmaceutical Development. International Journal of Generic Drugs. I.A.G.I.M. Drug Development Archives Locum International Archives. FDA/OGD/CDER Maryland Guides and Guidelines Library of Congress. AIC Conferences. Editorial Board. Pharm. Eur. USP/NF. USPC. BP.
To Doribelle
for her years of support and help to Sean for his expert knowledge on computerization to David and Ari for running the project's computers and lastly to Pat for his inestimable contribution.
Third International Edition. 2000
L O C U M
P U B L I S H I N G
H O U S E
Generic Development
HANDBOOK OF GENERIC DRUG DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1
Application/ Table of Contents
TABLE OF CONTENTS
(Overall ANDA Guideline Requirements for this Section).
1.1 Cover Letter - basis for submission of an abbreviated application. 1.2 Signed Application Form (Form FDA 356h or 3439) with original ink signature. 1.3 Executive Summary - Introductory Outline on the organization of this ANDA1 1.4 Table of Contents - to CDER Guide to Industry Format, (February 1999). Note: Cover Letter: Cover letter should be on the letterhead of the Applicant or the Applicant Agent and should state: Indicate Type:-
Purpose of Submission Type of Submission

(Original ANDA) (Supplement) (Amendment) (Annual Report) (Re-submission)
Change being Effected Expedited review requested Preapproval Supplement SUPAC Supplement
Compare OLD & NEW Data

SUPAC Changes: Describe Change Reference Exact SUPAC Guidance & Guidance Section Cover letter Header "This Submission is based on a SUPAC DOCUMENT"
Name of Applicant Title of Applicant Signature of Applicant (original ink) Proprietary name (if any) Generic name of Drug Number of volumes submitted.
Methods Validation Post Approval Commitment . Electronic Format Statement (portion or whole submission). Sterility Assurance Data Statement (Indicate that submission contains SAD) - NEW 1999/2000 Requirements
24 Volume V Drug Development Series
Sect: 1.1
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

'This Submission is based on a SUPAC Document'
COVER LETTER
Date: ______________
Office of Generic Drugs CDER, Food and Drug Administration Document Control Room - No. 150 Metro Park North II 7500 Standish Place ROCKVILLE MD 20855-2773.
Letter Header
For SUPAC submissions only.
(Place on envelop as well)
Clear Brief
Introductory Statement
ORIGINAL ABBREVIATED NEW DRUG APPLICATION

[Generic name] Specific Oral Dosage Form [USP] Dear Sir, We submit herewith an ABBREVIATED NEW DRUG APPLICATION for the drug product q [Generic name] Semisolid [USP] qcream qOintment qGel [000.0] mg/5g. (delete where appropriate) Enclosed are the archival and review copies in accordance with the Office of Generic Drugs Guidance for Industry dated February 1999. These copies are presented in a total of nine (9) volumes, FOUR [4] for the archival and FIVE [5] for the review copy. We furthermore commit to fully resolve any appropriate post approval issue identified in the methods validation process. The Application contains a full report of a topical Bioequivalence study. The Study compares q [Generic name] Semisolid [USP] qcream qOintment qGel [000.0] mg/5g manufactured by [Generic Manufacturing Co. Inc./ Ltd.] to the reference listed drug under protocol conditions. This section is submitted in PRINT and the prescribed ELECTRONIC format. The Application does/does not contain Sterility Assurance Data in section XXII We look forward to your review and comment. Yours Sincerely. Specify - Type of Bioequivalence Our Best Wishes, Results of Study Signature Results of Multiple Dose Study Name of Responsible Person. Dated __________________ Dissolution Data Regulatory Affairs Director - Waiver Request Enclosures - Nine files
24 Volume V Drug Development Series Sect: 1.2
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1
TABLE OF CONTENTS
SECTIONS I
1.1 .2 .3 .4 Cover Letter - basis for submission of an abbreviated application. Signed Application Form (Form FDA 356h or 3439) with original ink signature. Table of Contents - to CDER Guide to Industry Format, (April 1997). Executive Summary - Introductory Outline on the organization of this ANDA1 TABLE OF CONTENTS IS A REGULATORY REQUIREMENT (CFR 314(50)b.)
SECTIONS II
2.1 .2 Section Page (with Color Section TAG) and brief descriptor of the section. Basis for ANDA Submission
SECTIONS III
3.1 .2 .3 .4 .5 Section Page (with TAG) and brief descriptor of the section. Patent Certification statement - (Paragraph I, II, III or IV) Little VIII Patent statement - i.e. no labeling claims on a new indication. Exclusivity Statement with reference to the RLD. Certification Pursuant to the Generic Drug Enforcement Act of 1992.
SECTIONS IV - Generic vs. RLD Comparison

4.1 .2 .3 .4 .5 .6 .7 .8 Section Page (with TAG) and brief descriptor of the section. Comparison between Generic and Reference Listed Drug (RLD). Tabulate to show proposed product is the same as listed product namely: Use; Active Ingredients; inactive ingredients: Route: Dosage Form; Strength Rx or OTC Marketing Statement for proposed Generic Product. Side-by-side comparison of insert.2 Side-by-side comparison of label. 2 Certification that proposed labeling is the same as listed drug. Innovators labeling - (obtain latest insert from FDA FOI).
Sect: 1.3
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

TABLE OF CONTENTS
SECTIONS V - LABELING
5.1 .2 .3 .4 .5 .6 Section Page and cover statement Innovators labeling - (obtain latest insert from FDA FOI). Proposed Generic labeling Side-by-side comparison of insert. Side-by-side comparison of label. Certification that proposed labeling is the same as listed drug.
1Strongly recommended - but not a legal or statutory requirement 2Strongly recommended to repeat sections 5.4 & 5.5 in section 4 as 4.5 & 4.6 (new reg.)
SECTIONS VI - BIOAVAILABILITY / BIOEQUIVALENCE STUDY

6.1 .2 .3 .4 .5 .6 .7 .8 .9 .10 .11 .12 Title Page and brief summary statement of what this section contains. Formula Composition of GENERIC product Percent Composition of Formula Comparative Ingredients List between Innovator & Generic Certificates of Analysis of Generic Drug Product - (all strengths) Certificates of Analysis for Innovators Product - (all strengths) Comparative Diffusion Profile using 6 dosage units each - (all strengths) Comparative Diffusion Profile (CDP study results, statistics, tables and graphs) Request for Waiver for Biostudy for other strengths (multiple strength application) Outline of packaging container closures - proposed marketing packs. Schematic Trail of all packed units Topical Bioequivalence protocol and study reports conducted on pivotal batch *(Biostudy = Bioavailability / Bioequivalence Study required in selected cases)
Sect: 1.4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

TABLE OF CONTENTS
SECTIONS VII - Components and Composition
7.1 .2 .3 .4 .5 Title Page (with TAG) and brief narrative statement of what this section contains. List of Components - in order of manufacture (name & grade). Formula Composition of Generic Product Percent Composition of Generic Product. Comparative composition summary by batch size (qualitative & quantitative)
SECTIONS VIII - RAW MATERIAL CONTROL
Active ingredients & Chromatographs

8.1 .2 .3 .4 .5 .6 .7 Title Page (with TAG) and brief narrative statement of what this section contains. Outlines of SOP for handling Raw Materials including Retest Procedure/Period VENDORS Certificates of Analysis (CofA) ; Specifications and Test Results GENERIC FIRM'S Certificates of Analysis (CofA) ; Specifications and Test Results Disclosure of Active ingredients Source. (Type II DMF Authorization Letter) DMF of Manufacturer via Letter of Access from Active Manufacturer. Active Material Monograph, Spectra and Chromatographs for REFERENCE & TEST Samples supplied by GENERIC FIRM'S QC laboratory
SECTIONS VIII - RAW MATERIAL CONTROL Inactive ingredients

8.8 .9 Title Page and brief summary statement of what this section contains. CoA from Generic Firms QC laboratory, plus supporting: - Identification IR or UV spectra of Active - HPLC chromatograms (Assay - Impurities) - label peaks - Photocopy of TLC chromatograms (Assay - Impurities)
Sect: 1.5
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

TABLE OF CONTENTS
SECTIONS VIII - CONTINUED SECTIONS VIII - RAW MATERIAL CONTROL Inactive ingredients
.10 CoA from Active Manufacturer, - plus supporting: - Identification IR or UV spectra of Active - HPLC chromatograms (Assay - Impurities) - label peaks - Photocopy of TLC chromatograms (Assay - Impurities) .11 IR Identification Spectra of Reference Standard (Pharmacopoeial). Physical Specifications from Active Manufacturer: - Bulk Density - Particle Size (note: water insoluble material) .12 .13 .14 .15 .16 .17 .18 .19 .20 .21 .22 .23 .24 Physical and analytical test methods. Material Data Safety Sheet - source of data for manufacturing cautions. Monographs of each non-active from Generic QC lab Coating Colors and Dyes - US Source with Batch Certification - Composition of Approved Pigments and Dyes CoA from Generic QC lab (Applicants Release Certificate) CoA from Approved Manufacturer (Suppliers Release Certificate)
Routine Testing Protocol and Frequency of tests for Active Material Routine Testing Protocol and Frequency of tests for Inactive Material Statement that other suppliers may be used subject to meeting pharmacopoeial standards. SOP Outline of vendor qualification requirements (outlines are unsigned) SOP Outline of retesting procedures and schedule (micro. NMT 12 months) SOP Outline of RM environmental storage temperatures (15o-25 o (30o C).
Sect: 1.6
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

TABLE OF CONTENTS
SECTIONS IX - Description of Manufacturing Facility
9.1 .2 .3 .4 .5 .6 .7 .8 Title Page (with TAG) and brief narrative statement of what this section contains. Statement of commercial Statement of commercial Statement of commercial - Site address of Manufacture(s). - Packaging & Labeling - site address. - Site of Distribution - site address.
Address of Facility for QC and Stability Testing. Brief description of facilities for MNF testing equipment and stability equipment and key personnel (no personnel CVs). Statement on the GMP Certification of Compliance for the generic mfg. site Generic Manufacturing Site - Central File No (CFN)
SECTIONS X Outside Firms & Contract Testing Laboratory

10.1 .2 .3 .4 .5 .6 Title Page (with TAG) and brief narrative statement of what this section contains. Name and Site Address of all Contract Laboratories. Registration No. of each Contract Laboratory. List of Test(s) or FUNCTIONS to be Performed by Contract Laboratory. Certification letter of GMP/GLP Compliance of Contract Laboratory. Statement on the cGMP Status and Certification of Compliance re: - a contract manufacturing site - a contract labeler or packaging site. - environmental assessment or a claim for categorical exclusion
SECTIONS XI Proposed Manufacturing and Processing Instructions

11.1 .2 .3 .4 .5 .6 Title Page (with TAG) and brief narrative statement of what this section contains. Outlines of Manufacturing, equipment listing and Packaging SOP. Summary of In-process controls and reprocessing statement. Flow Chart of Manufacturing Procedure. Blank forms for Intended Production runs for LARGEST commercial batch size with processing equipment specified (Note 1:10 pivotal ratio).
Blank forms should include the full manufacturing process such as:
Blank forms - Master Formula (Commercial batch size) Blank forms - Manufacturing Procedures (English translations) Blank forms - In-process specifications sheet for final blend. Blank forms - In-process control sheets (English translations). Blank production forms for in-process weight controls Blank forms for production yields and weighing print-outs attachments
Sect: 1.7
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

TABLE OF CONTENTS
11.7 .8 .9 .10 .10 Finished Product Release Specifications. Outline Packaging Operations and packaging equipment listing Blank Packaging Records. Side-by-side comparison of Pivotal & Production Batches Equipment, QC, Production Operating Personnel, SOPs). Reprocessing statement. (Formulation,
SECTIONS XII Pivotal Manufacturing and In-Process Controls

12.1 .2 .3 .4 .5 .6 .7 .8 .9 .10 .11 .12 .13 .14 .15 .16 .17 .18 .19 .20 .21 .22 Title Page (with TAG) and brief narrative statement of what this section contains. Outline of In-process SOPs. In Process Controls and sampling plan summary. Executed Manufacturing Procedure Flow Chart. Pivotal Batch Title page Pivotal Batch Records.
Executed Batch with signatures

Master Formula for pivotal size Executed forms - Master Formula (Commercial batch size). Executed forms - Manufacturing Procedures (English translations.) Executed forms - In-process control sheets (English translations). Documentation for manufacturing procedures, including production yields). - Executed forms - In-process manufacturing specifications for bulk material. - Executed forms - In-process product specifications for bulk material. - Executed forms - In-process test result sheet of the bulk material - Certificate of Batch Homogeneity (showing test results.) - Executed forms - In-process specifications. - Executed forms - In-process test results sheet. - FILL weight Verification study and results - Executed forms for production yields and weighing print-outs attachments. Executed forms production forms for in-process weight controls (translations) Finished Product Release Specifications Manufacturing (Mnf's) Deviation Reports (MDRs) - (translations)
Sect: 1.8
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

TABLE OF CONTENTS
12.23 .24 .25 .26 .27 .28 .29 Executed forms production forms for in-process weight controls (translations) Finished Product Release Specifications Manufacturing (Mnf's) Deviation Reports (MDRs) Production Packaging Work Sheets Production Packaging Control Forms - (translations) - (translations) - (translations)
Distribution of Pivotal lot into various container-closures systems (Packaging) Pivotal Batch Packaging Trail - (overall disposition of UNITS i.e. net yield, QC sampling, reserve samples, stability samples, Biostudy, Packaging formats.)
SECTION XIII
Description & Characteristics of Packaging Components Packaging and labeling Procedures
13.0 .1 .2 Title Page (with TAG) and brief narrative statement of what this section contains. Outlines for Packaging and Labeling Procedures Blank Packaging Forms and Packaging reconciliation. Summary of Container-closure-liner system used for each strength. CONTAINERS, GLASS OR THERMOPLASTIC (REQUIREMENTS FOR EACH CONTAINER.) .3 .4 .5 .6 Description of Packaging Components - pack sizes for each strength. i. LoA from manufacturer referencing their container DMF #. ii. LoA from resin mnf. referencing their resin DMF # used in container - (Obtain separate letters for each resin type used in plastic containers.) Manufacturer's Container Specifications or Certificate of Conformance, including; - drawings/diagrams and dimensions - test protocol and Certificates meeting USP and 21 CFR requirements - DSC thermal analysis (for thermoplastic containers only) - Manufacturers Container CoA .7 .8 .9 Testing Specifications / protocol and test results (CoA) of Generic packaging Lab. CoAs of Containers from Generic packaging Lab. Batch Compliance Results
Sect: 1.9
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

TABLE OF CONTENTS
METAL CAPS AND THERMOPLASTIC CLOSURES (PER EACH CLOSURE.)
13.09 .10 .11 LoA from closure manufacturer referencing DMF # of cap (+ GMP statement.) LoA from resin manufacturer referencing thermoplastic resin DMF #. (Obtain separate letters for each resin type used in thermoplastic closures) Mnf's Closure Specifications or Certificate of Conformance, including; - drawings/diagrams and dimensions - test protocol and certificates meeting all USP and 21 CFR requirements - DSC thermal analysis (only for thermoplastic closures) - Manufacturers CoA .12 .13 Testing Specifications / protocol and test results (CoA) of Generic packaging Lab. Batch Compliance Results. INNER CLOSURE LINER: 13.14 .15 .16 .17 .18 .19 Item description and use - meets current CFR and USP requirements. LoA from manufacturer to applicant referencing their DMF # of inner liner. Inner liner Specifications or Certificate of Conformance from manufacturers. Testing Specifications / protocol of Generic packaging Lab. CoA or test results of inner liner from Generic packaging Lab. Batch Compliance Statement.
FOAM SEALS, PRESSURE SENSITIVE, TAMPER RESISTANT, ADHESIVE, INNER SEALS: 13.20 .21 .22 .23 .24 .25 Item description and use - meets current CFR and USP requirements. LoA from manufacturer to applicant referencing their DMF # of foam seal. Foam seal Specifications or Certificate of Conformance from manufacturers Testing Specifications / protocol of Generic packaging Lab. CoA or test results of Foam seal from Generic packaging Lab. Batch Compliance Statement.
Sect: 1.10
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

TABLE OF CONTENTS
TUBES AND NOZZLES/APPLICATORS 13.26 .27 .28 .29 .30 .31 Item description and use - USP requirements. LoA from manufacturer to applicant referencing their DMF # Specifications or Certificate of Conformance from manufacturers. Testing Specifications / protocol of Generic packaging Lab. CoA or test results from Generic packaging Lab. Batch Compliance Statement of incoming packaging materials.
Section XIV - Controls for the Finished Dosage Form

14.1 .2 Title Page (with TAG) and brief narrative statement of what this section contains. State if drug product is: - Compendial and test methods used are USP - Non-Compendial and test methods in-house and validated. - Non-Compendial and test methods based on and validated. 14.3 Certificate of Analysis of Pivotal Batch(es), including - HPLC, TLC, GC, UV chromatograms and spectra e.g.: - CoA for _______ [product] USP [Strength #1] mg + HPLC chromatograms - CoA for _______ [product] USP [Strength #2] mg + HPLC chromatograms - CoA for _______ [product] USP [Strength #3] mg + HPLC chromatograms - CoA for _______ [product] USP [Strength #4] mg + HPLC chromatograms
Stability Indicating Assay; Impurity Limit Tests; Dissolution Assay USPC Inc. Pharmacopeial Forum, FDA
Sect: 1.11
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

TABLE OF CONTENTS
Section XV - Analytical Methods
15.1 Title Page (with TAG) and brief narrative statement of what this section contains. State if drug substance and drug product is: - Compendial and test methods used are USP - Non-Compendial and test methods in-house and validated. - Non-Compendial and test methods based on and validated.
Active material
.2 .3 Active Ingredient Test Method Active Ingredient Test Method Validation
In-process Material
.4 Final Blend Test Methods (especially Uniformity of Content)
Finished Product
.5 Finished Product Test Methods - physical tests - chemical tests - microbiological tests .6 Finished Product Test Methods - (Stability Check) - stability Indicating Test Methods. - impurity limit tests. - Preservative Efficacy Test Method (Validation and stability Studies). .7 Finished Product Analytical Validation methodology - stability Indicating Assay. - impurity limits or specific impurity quantitation and detection levels (LQ & LD). - microbiological limit tests (QC Release
Sect: 1.12
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1

TABLE OF CONTENTS
Section XVI
Stability of Finished Dosage Form

16.1 .2 .3 .4 .5 .6 .7 Title Page (with TAG) and brief narrative statement of what this section contains. Stability Protocol for Post Approval Production Batches (ANDA commitment). Package Configuration/sizes (largest and smallest) used in stability studies. Expiration Dating Period Statement. Stability Protocol used for Pivotal lot. Stability Reports Results of Pivotal Lot from 3 months accelerated and controlled room temperature studies. Stability Data Summary Report (graphs).
Section XVII
Reserved
17.0 17.1 Title Page (with TAG) and brief statement that section is reserved. Reserved
RESERVED SECTION NOT FOR CURRENT USE
Section XVIII
Samples of the drug and articles used as components

18.1 .2 .3 .4 .5 Title Page (with TAG) and brief narrative statement of what this section contains. Statement on Sample Submission Procedures to FDA on request on - Submission of Drug Substance - Submission of Drug Product / Finished Dosage Form - Submission of Appropriate Reference Standards (where required)
Sect: 1.13
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1
Application/Table of Contents
TABLE OF CONTENTS.
Section XIX
ENVIRONMENTAL IMPACT ANALYSIS REPORTS
19.1 19.2 Title Page (with TAG) and brief narrative statement of what this section contains. Environmental Exclusion Assessment - Development Site - Manufacturing Site Applicable Environmental Laws (National / State / Local /Foreign): - Development Site - Manufacturing Site - Contract Manufacturers Site Environmental Certification: - Development Site - Manufacturing Site - Contract Manufacturers Statement on Environmental Compliance: - Development Site - Manufacturing Site - Contract Manufacturers Commercial Plant Manager and QA Director Signatures.
19.3
19.4
19.5
Section XX
ADDITIONAL INFORMATION
20.0 20.1 20.2 Title Page (with TAG) and brief narrative statement of what this section contains. Certification Pursuant to the Generic Drug Enforcement Act of 1992. US Agents Letter of Authorization
Section XXI
ADDITIONAL INFORMATION
21.1 21.2 21.3 21.4 21.5 21.6 21.7
1
Title Page (with TAG) and brief narrative statement of what this section contains. Reference to previously submitted Information Original Data / Literature Publication where English translation is submitted Outline of manufacturing re-work study. Table of DMF Numbers (with LOA dates). Letters of Authorization (LOA) - TWO PHOTOCOPIES1 Field Copy Certification
TWO PHOTOCOPIES OF LETTERS OF AUTHORIZATION WITH RECENT DATES (i.e. where possible in the same year as the ANDA submission.)
Sect: 1.14
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION I
SECTION 1
FDA FORM 3439

or
FDA FORM 356h [REVISED]

Jan 8, 1998
(The FDA revised Form 365h - Federal Register July 8, 1997) The revised "all purpose" form was official from January 8, 1998.
(NOTE: All DMF numbers stated on this form to be exactly the same as shown in Section 21 )
Correct pagination between text and Table of Contents is essential. (Page numbers in the actual application must be placed at bottom center of each page and run consecutively to the end of the submission i.e. up to Section 21)
Sect: 1.15
ANDA DEVELOPMENT
ANDA DEVELOPMENT
NOTES
Sect: 1.16
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION II
SECTION 2
Basis for ANDA Submission
TABLE OF CONTENTS
2.O Section Page and Title. The information in this section summarizes the four critical structures supporting the legal basis for this abbreviated new drug application 2.1.0 2.1.1 Basis for ANDA Submission is submitted as follows and is; Based on an Abbreviated New Drug Application
or
2.1.2 Based on an approved ANDA Suitability Petition
and
3.0 Based on Active Ingredient (same as RLD) and current approved labeling
and
4.0 Based on Route of Administration, Dosage Form and Strength
and
5.0 Based on Bioequivalency Data submitted (Applicant Generic Drug vs. RLD)
NOTE:MODEL Letters are provided in Section IV highlighting each of four critical structures and supporting documentation stating the legal basis for this abbreviated new drug application
4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION II
SECTION 2

BASIS FOR ABBREVIATED NEW DRUG APPLICATION
[a] Listed Drug. This applications refers to the Reference Listed Drug [NAME] qSemisolid qTablet / qCapsule manufactured by [RLD Company Name Inc. / Ltd.] (delete where necessary).
The basis for [Applicant Company Name Inc. / Ltd.] proposed ANDA for Full Generic Drug Name is the approved reference listed drug as above, the subject of ANDA [#00 0000] held by [RLD Company Name Inc. / Ltd.]. and containing [000.0 / 000.0 / 000.0mg] of [Generic Drug Name]. According to the FDA listed information published in the list of approved Drug Products known as the Orange Book 20th (2000) Edition the listing is enclosed herewith.
[b] Exclusivity.
Furthermore
according to the FDA listed information published in the list of Approved Drug Products [Orange Book] 20th (2000) Edition the RLD is entitled to a period of marketing exclusivity (under section 505j[4][D] of the Act as a New Chemical Entity until the NCE's expiration period of MM/DD/YY
or
Furthermore
according to the FDA listed information published in the list of Approved Drug Products [Orange Book] 20th (2000) Edition, no exclusivitys for the listed the RLD applies.
[c] According to the information published in the 20th Edition List (2000), the reference listed drug is covered by [one / two] use patent which is addressed in Section III of this application. [d] APPROVED ANDA SUITABILITY PETITION
The basis for [Applicant Company Name Inc. / Ltd.] proposed ANDA is further based on the approval of the suitability petition pursuant to the 21 Code Federal Register (CFR) # 505[j][2][c] and 21 CFR 314.93 that requested a change from the above listed drug in subparagraph 1[a] as above. Docket No [00000] The basis of this ANDA SUITABILITY PETITION is held and was submitted under Docket No [00000] and approved on MM/DD/YY. A copy of the FDA letter approving the ANDA SUITABILITY PETITION is attached in section II of this application (page [00])
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION II
SECTION 2

BASIS FOR ABBREVIATED NEW DRUG APPLICATION (continued)
ACTIVE INGREDIENT [00000]

21 CFR 314.94 [A][5][i]
he active ingredient of [Applicant Company Name Inc. / Ltd.] Generic q Semisolid / qTablet / qCapsule (delete where necessary) is the same as that of the RLD brand name We refer the reviewer to [Applicant Company Name Inc. / Ltd.] annotated labeling and the current approved labeling of the RLD as shown in Section IV-05 of this ANDA (Refer pages [00] to [00])
ROUTE OF ADMINISTRATION DOSAGE FORM AND STRENGTH
21 CFR 314.94 [A][5][i] he Route of Administration, Dosage Form and Strength [Applicant Company's Name Inc. / Ltd.] of Generic q Semisolid / qTablet / qCapsule (delete where necessary) is the same as for [RLD brand name] Again we refer the reviewer to [Applicant Company Name Inc. / Ltd.] annotated labeling and the current approved labeling of the RLD as shown in Section IV-05 of this ANDA (Refer pages [00] to [00])
BIOEQUIVALENCY DATA [00000]

21 CFR 314.94 [A][7][i] [Applicant Company Name Inc. / Ltd.] bioequivalent study on [Generic q Semisolid / qTablet / q Capsule Name] (delete where necessary) was successfully conducted in terms of current approval parameters by Clinical Research Laboratories [Name and Address] The Full Bioequivalence Report is attached to Section VI of this ANDA (Refer pages [000] to [000])
[Signature of Responsible Person] -----------------------------------------------[Name of Responsible Person]
----------------------------------------Date
Regulatory Affairs Director
[Applicant Company Name Inc. / Ltd.]

[Signature of Responsible Person]
[Two typical examples of this section are given below]
Sect: 2.3
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION II
SECTION 2

EXAMPLE 1:
Listed Drug. This applications refers to the Reference Listed Drug [RLD] Miconazole1 / Miconazole USP2 Generic q Semisolid qTablet / qCapsule (delete 3 where necessary) manufactured by [RLD Company Name Inc. / Ltd.] . A copy of the Orange Book 20th (2000) Edition listing is enclosed herewith. According to the information published in the 20th Edition List, the reference listed drug is covered by [ no / one / two] use patent which is addressed in Section III of this application. Exclusivity. There are [ONE] / [two] / [no] exclusivitys for the listed drug.
I-184 - expires Sept 24, 2000 I-185 - expires Sept 24, 2000
[Name of Responsible Person]
[Signature of Responsible Person] ------------------------------------------------
----------------------------------------Date
----------------------------------------Date

1 2
INNOVATOR NAME COUNTRY US or EU USA RLD 375 / 500 mg - Application Number 000000 3 INNOVATOR
Sect: 2.4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION II
SECTION 2

EXAMPLE 2:
Listed Drug. This applications refers to the Reference Listed Drug [RLD] Miconazole1 / Miconazole USP2 q Semisolid / qTablet / qCapsule manufactured by [RLD Innovator Company Name Inc. / Ltd.]3. (delete where appropriate) A copy of the Orange Book 20th (2000) Edition listing is enclosed herewith. According to the information published in the 20th Edition List (2000), the reference listed drug [RLD] is covered by [ no / one /two] use patent(s) which is addressed in Section III of this application. Exclusivity. According to the information published in the 20th Edition of the Orange Guide (2000), there are [one] / [two] / [no] exclusivitys for the listed drug.
I-000 - expires MM DD, 2000 I-000 - expires MM DD, 2000
[Signature of Responsible Person] -----------------------------------------------[Name of Responsible Person] ----------------------------------------Date

[Applicant Company Name Inc. / Ltd.] 1 INNOVATOR 2 USA RLD IS REGISTERED AS STRENGTH 0 mg +00 mg INNOVATOR Application Number [00000] 3 INNOVATOR
Sect: 2.5
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION II
SECTION 2

ANDA SUITABILITY PETITION APPROVAL LETTER
Date: Office of Generic Drugs CDER, Food and Drug Administration Document Control Room - No. 150 Metro Park North II 7500 Standish Place ROCKVILLE MD 20855-2773.
ORIGINAL ABBREVIATED NEW DRUG APPLICATION

[Generic name] Dosage Form Dear Sir,
We submit herewith the ANDA SUITABILITY PETITION APPROVAL LETTER for the drug product [Generic name q Semisolid / qTablet / qCapsule [000 / 000] mg. (delete where necessary)
----------------------------------------Date
[ANDA SUITABILITY PETITION APPROVAL LETTER attached in Section XXII]
4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
End of Section 2.
Sect: 2.7
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION III
SECTION 3
Patent Certification / Exclusivity

TABLE OF CONTENTS
ection Page (with Color Section TAG) and brief narrative of the section. Enclosed in this sections is a statement of patent certification for [Applicant Company Name Inc. / Ltd.]new drug application [Drug Name]. Also enclosed (if applicable) are the statements concerning the required notices to the patent owners and NDA holder. These statements are in accord with the FD&C Act as amended September 24, 1984 and with the final regulations effective November 2 1994. 3.1 Patent Certification statement State Paragraph I State Paragraph II State Paragraph III State Paragraph IV 3.2 3.3 3.4 Little VIII Patent Statement - i.e. no labeling claims on a new indication. Exclusivity Statement with reference to the RLD. Certification Pursuant to the Generic Drug Enforcement Act of 1992.
Sect: 3.1
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION III
SECTION 3
Patent Certification Statement

Paragraph I Certification
[21 CFR 314.94(a)(12)(i)]
n accord with the Food, Drug and Cosmetic Act as amended September 24, 1984 and with the final regulations effective November 2 1994 Patent certification is hereby provided for our Abbreviated New Drug Application for [Generic Drug Name].
W T
e the undersigned hereby certify to the best of our knowledge and in [Generic Company Name Inc./Ltd.]s opinion patent information has not been submitted to the FDA on Patent No [00-0000-00] which claims the reference listed drug [RLD] DRUG Name [USP] [000.0] mg. NDA # 00-000
his certification is made in accordance with Section 505 (j)(2)(A)(vii)(I) of Title I the Food, Drug and Cosmetic Act, as amended September 24, 1984 and pursuant to 21 CFR 314.94 (a)(12)(i)(A)(1).
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Sect: 3.2
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION III
SECTION 3

Paragraph II Certification
n accord with the Food, Drug and Cosmetic Act as amended September 24, 1984 and with the final regulations effective November 2 1994 Patent certification is hereby provided for our Abbreviated New Drug Application for [Generic Drug Name].
e the undersigned hereby certify that to the best of our knowledge and in [Generic Company Name Inc./Ltd.]s opinion US Patent No [00-0000-00] held by [Innovator/RLD Company Name Inc./Ltd.] which claimed the reference listed drug [RLD] DRUG Name[USP] [000.0] mg. NDA # 00-000 expired on 31 December 1999 his certification is made in accordance with Section 505 (j)(2)(A)(vii)(I) of Title I the Food, Drug and Cosmetic Act, as amended September 24, 1984 and pursuant to 21 CFR 314.94 (a)(12)(i)(A)(1). US. Patent No. 0-0000-0000 expiring Dec 31, 1999 US. Patent No. 0-0000-0000 expiring Dec 31, 1999
W T
----------------------------------------Date
[Applicant Company Name Inc./Ltd.]
Sect: 3.3
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION III
SECTION 3

Paragraph III Certification
n accord with the Food, Drug and Cosmetic Act as amended September 24, 1984 and with the final regulations effective November 2 1994 Patent certification is hereby provided for our Abbreviated New Drug Application for [Generic Drug Name]. e the undersigned hereby certify that to the best of our knowledge and in [Generic Company Name Inc./Ltd.]s opinion US Patent No [00-0000-00] held by [Innovator/RLD Company Name Inc./Ltd.] which claimed the reference listed drug [RLD] DRUG Name [USP] [000.0] mg. NDA # 00-000 will expire on [31 December 1999.] US. Patent No. 0-0000-0000 expiring MM DD, YYYY US. Patent No. 0-0000-0000 expiring MM DD, YYYY n accordance with Section 505 (j)(2)(A)(vii)(III) of the Food, Drug and Cosmetic Act, as amended [Generic Company Name Inc./Ltd.] certifies that the Company will not engage in the commercial manufacture, use or sale of the drug Product until this aforementioned patent has expired.
----------------------------------------Date
Note the Bolar amendment allows the sale of the bulk active material and the development manufacture testing of the developed generic product SOLELY for the purposes and under the condition of getting it approved as an ANDA
Sect: 3.4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION III
SECTION 3

Alternative Certification

Paragraph III Certification
he undersigned hereby certifies to the best of our knowledge and in [Generic Company Name Inc./Ltd.]s opinion there is [one] patent which claims the listed drug [RLD] DRUG Name [USP] [000.0] mg. NDA # 00-000.
US. Patent No. 0-0000-0000 expiring MM DD, YYYY US. Patent No. 0-0000-0000 expiring MM DD, YYYY
n accordance with Section 505 (j)(2)(A)(vii)(III) of the Food, Drug and Cosmetic
Act, as amended [Generic Company Name Inc./Ltd.] certifies that the Company will not engage in the commercial manufacture, use or sale of the drug Product until this aforementioned patent has expired .
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Attached: Page Number: [00] The Prescription Drug Product List of the APPROVED DRUG PRODUCTS WITH THERAPEUTIC EQUIVALENCE EVALUATIONS EDITION 20th - 2000 US Department of Health and Human Sciences.
Sect: 3.5
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION III
SECTION 3

Paragraph IV Certification
n accord with the Food, Drug and Cosmetic Act as amended September 24, 1984 and with the final regulations effective November 2 1994 Patent certification is hereby provided for our Abbreviated New Drug Application for [Generic Drug Name]. e the undersigned hereby certify that to the best of our knowledge and in [Generic Company Name Inc./Ltd.]s opinion US Patent No [00-0000-00] issued on MM DD, YYYY and will expire on 31 December 2004 [will not be infringed] / [ is invalid] / [is unenforceable]1 by the manufacturer [Generic Company Name Inc./Ltd.] upon the manufacture use and sale by [Generic] DRUG Name [USP] [000.0]mg. for which this application is submitted NO INFRINGEMENT STATUS of the following patents. US. Patent No. 0-0000-0000 expiring MM DD, YYYY US. Patent No. 0-0000-0000 expiring MM DD, YYYY
[Signature of Responsible Person] -----------------------------------------------[Name of Responsible Person] Regulatory Affairs Director [Applicant Company Name Inc./Ltd.] ----------------------------------------Date
[the patent will not be infringed] [the patent is invalid] [the patent is unenforceable] or [ANDA applicant hold a licensing agreement for the Patent Holder]1
Special Note of Notification:
1Select the appropriate language that constitutes the basis of the patent challenge namely:
If the owner of the patent, subject to a paragraph IV Certification, is a person or entity other
than the registered NDA holder, then the applicant, is required to notify, under separate cover, both parties - namely the Patent Holder and the NDA Holder. (Certified mail return receipt cards often get damaged in the mail - thus avoid use, as system is ineffective. Where Fedex , UPS or DHL etc. is used to advise of a notification it is essential to obtain the recipient approval to use Fedex , UPS or DHL couriers PRIOR to notification).
1Where
the generic applicant has an patent holder / innovator Agency Agreement, include the correspondence of the agency licensing agreement, from the RLD Company, as an attachment. (meeting requirement of 21 CFR 314.94(a)(12)(v) (November 2, 1994).
Sect: 3.6
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION III
SECTION 3
Patent Holder & NDA Holder
Statement Concerning Notice

To Patent Holder and NDA Holder
21 CFR 314.94(a)(12)(1)(A)(iv) & 21 CFR 314.95
n accordance with Section 505 (j)(2)(B) of the Food, Drug and Cosmetic Act, as amended and 21 CFR 314.94(a)(12)(1)(A)(iv) & 21 CFR 314.95 certifies that [Generic Company Name Inc./Ltd.] hereby states that our firm, upon receipt from the FDA of an acknowledgment letter stating that this ANDA is sufficiently complete to permit a substantive review, will give the notice required by Section 505 (j)(2)(B) of the Food, Drug and Cosmetic Act, as amended, and 21 CFR 314.95 to [RLD Company Name Inc./Ltd.] the holder of the approved application for the Branded Product, [RLD] DRUG Name [USP] [000.0]mg and the owner of US Patent Number [5-0000-00] issued on MM DD, YY. The notice to the Branded Product [RLD] DRUG Name] shall be sent certified mail, return receipt requested and shall meet the requirements of 21 CFR 314.95 (a) and 21 CFR 314.95 (c) with mailing the notice to the [RLD Company Name Inc./Ltd.] the pertaining to the Branded Product - [RLD] DRUG Name] the [Generic Company Name Inc./Ltd.] will as required by 21 CFR 314.95(b) amend it ANDA for [Generic] DRUG Name [USP] [000.0]mg to include a certification that the notice has been provided to each person identified under CFR 314.95(a) and that the notice met the contents of CFR 314.95(c).
Concurrently
----------------------------------------Date
It has become standard practice for the large RLD (Innovative) Companies to delay for as long as
possible, by means of costly litigation action, the newly applied Generic registration, if submitted under a Paragraph IV certification, whether or not there is any legal basis for the litigation suite. The spirit and intention of the Act and law to provide suitable cheaper generic drugs for the general public is overridden by the Innovative Companies desire to look for continued extra-legal patent protection even thought the innovator has indeed received its fair and proper share of protection under the law during its full marketing period. The branded RLD Company simply immediately sues the generic applicant as a matter of routine practice, using its huge financial leverage to suppress the potentially lesser generic company. (Quote Brussels Conference on Patent Certification Oct. 1999: "if they don't sue - they're brain dead"). In truth, branded RLD Company need to honestly address the overall ethics question of this [now] standard litigation action which is based purely on the profit and greed motive and is designed to evade, side-step and elude the spirit and intention of the law for the benefit of the general public at large - Editor-in-Chief.
Sect: 3.7
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION III
SECTION 3
' No relevant Patent ' Statement

21 CFR 314.94(a)(12)(ii)
n accord with the Food, Drug and Cosmetic Act as amended September 24, 1984 and with the final regulations effective November 2, 1994. Patent certification clarification is hereby provided for our submitted Abbreviated New Drug Application for [Generic Drug Name].
his certification is made in accordance with Section 505 (j)(2)(A)(vii)(I) of Title I the Food, Drug and Cosmetic Act, as amended, September 24, 1984 and November 2, 1994 and pursuant to 21 CFR 314.94 (a)(12)(ii).
e the undersigned hereby certify to the best of our knowledge and in [Generic Company Name Inc./Ltd.]s opinion there are no patent[s] which claim[s] the Reference Listed Drug [RLD] DRUG Name [USP] [000.0]mg. NDA #[00-000-00] referred to in this application or that claims a use of the Reference Listed Drug.
----------------------------------------Date

Background This specification is not specifically described under the FD&C Act but appears in the FDA final regulations dated Nov 2, 1994. The purpose of the "No relevant Patents Statement " appears to be designed to aid and help the internal FDA OGD reviewers to assure them that your firm's omission to include a patent certification is a deliberate action and not simply a regulatory oversight.
Note: The intention of the regulations and the preamble to the regulations is to provide a positive
statement that the submitted ANDA should not contain any of the FOUR Patent Certification Statements (i.e. No Paragraph I ; II ; III or IV statement) - Thus, it is necessary to submit a "No relevant Patents Statement " if and only if, no patent(s) exist that should be the subject of a Patent Certification - i.e. stating the negative condition and thus eradicating the element of an regulatory oversight.
Sect: 3.8
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION III
SECTION 3
Method of Use Patent Statement

21 CFR 314.94(a)(12)(iii)
his certification is made in accordance with Section 505 (j)(2)(A)(vii)(I) of Title I the Food, Drug and Cosmetic Act, as amended September 24, 1984 and pursuant to 21 CFR 314.94 (a)(12)(i)(A)(1).
T
I
Method of Use Patent

n accord with the Section 505 (j)(2)(A)(viii) of Title I the Food, Drug and Cosmetic Act, as amended September 24, 1984, [Generic Company Name Inc./Ltd.] hereby states, with respect to method of Use Patent, US Patent No [000-000-00], submitted by [RLD Company Name Inc./Ltd.] for listing in respect to [RLD Branded Drug Name], that of Use Patent No [000-000-00] does not claim a use for which [Generic Company Name Inc./Ltd.] is seeking approval for [Generic Drug Name]
e the undersigned hereby certify to the best of our knowledge that of Use Patent No [000-000-00] is limited to the following claim (specific therapeutic use), the use for which [Generic Company Name Inc./Ltd.] now seeks approval in this ANDA, as evident by the attached proposed labeling (Refer to Page [00]), is for use indication _________, which is beyond the reach of claims of Patent No [000000-00] .
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Sect: 3.9
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION III
SECTION 3
Patent Certification / Exclusivity Exclusivity Statement

21 CFR 314.94(a)(3)(ii)
[RLD] CAPSULES [000.0] mg. NDA # 00-000
he undersigned hereby certifies to the best of our knowledge and in [Generic Company Name Inc./Ltd.] opinion the listed drug [RLD] DRUG Name [USP] [000.0] mg. NDA # 00-000 is not covered by any exclusivity.
OR
The following statement is made if market exclusivity exists under the Waxman-Hatch Act relative to the Reference Listed Drug - Attach the relevant page of the Orange Book
ccording to the information as published in the 'Orange Book' [Approved Drug Products with Therapeutic Equivalence Evaluations Edition #20 (2000), US Department of Health and Human Sciences], the listed drug [RLD] DRUG Name [USP] [000.0mg] is entitled to a three year period of market exclusivity under 505 (j)(4)(D) of the F.D.& C Act as a new product which does not expire until Dec 31 2002. [Generic Company Name Inc./Ltd.] does not intend to introduce its drug product subject to this ANDA, prior to the expiration of this exclusive marketing period.
Attached: Page Number: [00] The Prescription and OTC Drug Product Patent and Exclusivity Data of the APPROVED DRUG PRODUCTS WITH THERAPEUTIC EQUIVALENCE EVALUATIONS EDITION 20 (2000) - US Department of Health and Human Sciences.
4
End Section III
Sect: 3.10
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION IV
SECTION 4
Generic and RLD Comparison

TABLE OF CONTENTS
(Overall ANDA Guideline Requirements for this Section). 4.1 4.2 Section Page (with Color Section TAG) and brief narrative of the section. Comparison between Generic and Reference Listed Drug (RLD) / Innovator Tabulate to show proposed product is the same as listed product namely: Conditions of Use Active Ingredients Inactive ingredients (OGD Interim Inactive ingredient Policy - 'Q&Q' policy of Nov 17 1994 - does not apply to oral dosage forms i.e. tablets capsules and suspensions) Route of Administration & Dosage Form Strength Inactive Ingredients with supporting data Labeling Comparison (Add section V data) Rx or OTC Marketing Statement for proposed Generic Product.
4.3
FDA's Published January 1999 ANDA Guideline requirements Section IV. Comparison between Generic Drug and Reference Listed Drug (505(j)(2)(A)) 1. Conditions of Use ( 3l4.94(a)(4)) 2. Active ingredient(s) and supporting information ( 3l4.94(a)(5)) 3. Inactive ingredients as appropriate ( 314.94(a)(9)) 4. Route of administration, dosage form, and strength ( 3l4.94(a)(6)) Note:
Until the issue of the FDA Guideline in February 1999 'Guidance for Industry Organization of an ANDA' it was appropriate to place the side-by-side labeling comparison in section V on the ANDA. The new February 1999 'Guide' indicates that the side-by-side labeling comparison should appear in Section IV-5. Applicants may place the comparison in both section IV-5 and V until the FDA are conversant with the new guideline
4
24 Volume Drug Development Series Sect: 4.1
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION IV
SECTION 4
Generic and RLD Comparison

Information required under 314.94 (a)(4) through (6) of the ANDA Regulations final rule issued April 28 1992 and February 1999 Guidance to Industry.
[RLD] SEMISOLID [RLD Company Name] Conditions of Use The conditions of use prescribed or recommended or suggested for [RLD] SEMISOLIDS [USP] may be found in the package insert (see section V).
[Generic name] SEMISOLID [Generic Co. Name]. The conditions of use prescribed, recommended or suggested for [Generic name] SEMISOLIDS [USP]] are the same for [RLD] SEMISOLIDS [USP] and may be found in the package insert (see Section V).
Active Ingredient
[Active Material]
[Active Material]
Dosage Form
SEMISOLIDS [USP] (Topical dosage form)
SEMISOLIDS [USP] (Topical dosage form)
Administration
Topical
000.0 mg 000.0 mg 000.0 mg 000.0 mg
Topical
000.0 mg 000.0 mg 000.0 mg 000.0 mg
Strengths Number of Strengths
Labeling: The labeling proposed for the [Generic Company Name Inc. / Ltd.] drug product is the same as the labeling for the listed drug product except for: 1) Changes required because the drugs are produced and distributed by different manufacturers and distributors. 2) Product are packed in different size containers.
24 Volume Drug Development Series
Sect: 4.2
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION IV
SECTION 4
Rx / OTC Statement
[Generic name] SEMISOLID [USP] [All strengths]
Prescription Drug (Rx)
This drug is limited in its labeling and by this application to use under the professional supervision of a practitioner licensed by law to administer the prescription drug.
or
Over-the-Counter (OTC) Drug
This drug is limited in its prescribed labeling and by this application for use as an Over-the-Counter (OTC) Drug.
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Sect: 4.3
Topical SEMISOLID
ANDA DEVELOPMENT
NOTES
Sect: 4.4
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION V
SECTION 5
Labeling
TABLE OF CONTENTS
1. Section Page and cover statement 2. Proposed Generic container panel labeling for each strength & pack size. 3. Proposed Generic Insert / Outsert 4. Innovators Insert / Outsert - (obtain latest insert from FDA FOI). 5. Innovators container panel labeling for each strength & pack size 6. Side-by-side comparison of package leaflet (insert or Outsert.) 7. Side-by-side comparison of label for each strength & pack size 8. Certification that proposed labeling is the same as listed drug (RLD).
Sect: 5.1
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION V
SECTION 5
Labeling
PROPOSED GENERIC CONTAINER PANEL LABELING
000 g [Name] SEMISOLID [USP] Main Panel NDC [0000-0000-00]
[Generic Name] Semisolid [USP]
000 mg per g
_________________________ Contains: [Active Material] 000 mg per g Caution: Federal law prohibits dispensing without prescription
000 g Semisolid [USP]

[Applicant Company Name Inc. / Ltd.] Side Panel Usual dosage : Apply four times a day. See package for full prescribing information. KEEP OUT OF REACH OF CHILDREN Keep tightly closed. Store at controlled room temperature 15 30 C (59 - 86 F). Protest from exposure to temperatures above 40 C (104 F) and moisture.
KEEP THIS AND ALL MEDICATIONS OUT OF REACH OF CHILDREN 6/YY. MANUFACTURED BY [Generic Company Name Inc. / Ltd.] [Address]
Distributed By: [Distributing Company Name Inc. / Ltd.] [Address]
Sect: 5.2
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION V
SECTION 5
Labeling
PROPOSED GENERIC CONTAINER PANEL LABELING
000 g [Name] SEMISOLID [USP] Main Panel NDC [0000-0000-00]
[Generic Name] Semisolid [USP]
000 mg per gram

_________________________ Contains: [Active Material] 000 mg / g Caution: Federal law prohibits dispensing without prescription
000 g [Name] Semisolid [USP]

[Applicant Company Name Inc. / Ltd.] Side Panel Usual dosage : Apply four times a day. See package for full prescribing information. KEEP OUT OF REACH OF CHILDREN Keep tightly closed. Store at controlled room temperature 15 30 C (59 - 86 F). Protest from exposure to temperatures above 40 C (104 F) and moisture.
KEEP THIS AND ALL MEDICATIONS OUT OF REACH OF CHILDREN 6/YY.
MANUFACTURED BY [Manufacturing Company Name Inc. / Ltd.]. [Short Address] Lot No Mfg. Date: Use Before: Distributed By: [Distributing Company Name Inc. / Ltd.] [Short Address]
Sect: 5.3
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION V
SECTION 5
Labeling
PROPOSED GENERIC PACKAGE INSERT LABELING
SIDE-BY-SIDE COMPARISON
GENERIC PACKAGE INSERT INNOVATIVE PACKAGE INSERT
Present full Generic package insert identical to innovators (caution restrictions on indications still on patent - these may not be included )
Present full Innovative package insert of innovators (restrictions on indications still on patent are included and shown as a difference ) - latest edition of package insert must be used - obtain from FOI services Use point size 7 and highlight the differences in the INNOVATIVE PACKAGE INSERT - use line side bars where differences appear.
Use point size 7 and highlight the differences in the GENERIC PACKAGE INSERT - use line side bars where differences appear as shown:
NOTE:The differences in the package insert should be restricted to Generic product name and different addresses for Applicant Manufacturer, Distributor and Product reference Numbers.
NOTE:The differences in the package insert should be restricted to Innovative product name and different addresses for Applicant Manufacturer, Distributor and Product reference Numbers
NOTE: Examine innovators labeling carefully and reproduce wording meeting all regulatory requirements. Note: the FDA provide a significant number of the latest package inserts for Generics - on the Internet - See FDA Website
Sect: 5.4
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION V
SECTION 5
Labeling
PROPOSED GENERIC CONTAINER LABEL LABELING
SIDE-BY-SIDE COMPARISON
GENERIC CONTAINER LABEL
INNOVATIVE CONTAINER LABEL
Present full Generic CONTAINER LABEL identical to innovators (caution restrictions on indications still on patent - these may not be included )
Present full CONTAINER LABEL of innovators (restrictions on indications still on patent are included and shown as a difference ) - latest edition of package CONTAINER LABEL must be used - obtain from FOI services Use point size 12 and highlight the differences in the INNOVATIVE CONTAINER LABEL - use line side bars where differences appear.
Use point size 12 and highlight the differences in the GENERIC PACKAGE CONTAINER LABEL - use line side bars where differences appear as shown:
NOTE:The differences in the CONTAINER LABEL should be restricted to Generic product name and different addresses for Applicant Manufacturer, Distributor and Product reference Numbers.
NOTE:The differences in the CONTAINER LABEL should be restricted to Innovative product name and different addresses for Applicant Manufacturer, Distributor and Product reference Numbers
NOTE: Examine innovators labeling carefully and reproduce wording meeting all regulatory requirements
Sect: 5.5
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION V
SECTION 5
Labeling
PROPOSED GENERIC CONTAINER ADHESIVE LABELING
000 g [GENERIC Name] Semisolid [USP]

(Show ALL dosage and fill sizes)
NDC [0000-0000-00]
[GENERIC Name] Semisolid [USP]

000 mg per g.
Each gram contains: [Active Material] [000] mg Caution: Federal law prohibits dispensing without prescription
000g [GENERIC Name] Semisolid [USP]

Keep tightly closed. Store at controlled room temperature 15 - 30 C (59 - 86 F). Protest from exposure to temperatures above 40 C (104 F) and moisture. KEEP THIS MEDICATION OUT OF REACH OF CHILDREN.
[Applicant Company Name Inc. / Ltd.] Distributed By: [Distributing Company Name Inc. / Ltd.]
NOTE: Examine innovator's carton and container labeling carefully and reproduce instructions to meet all regulatory requirements. Obtain the latest printing of the innovator's product labeling.
Sect: 5.6
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION V
SECTION 5
Labeling
INNOVATIVE CONTAINER ADHESIVE LABELING
000 g [GENERIC Name] Semisolid [USP]

(Show ALL dosage and fill sizes)
NDC [0000-0000-00]
[INNOVATIVE Semisolid [USP]

000 mg per g
Each gram contains: [Active Material] [000] mg Caution: Federal law prohibits dispensing without prescription
000 g [RLD Name] Semisolid [USP]
Keep tightly closed. Store at controlled room temperature 15 - 30 C (59 - 86 F). Protest from exposure to temperatures above 40 C (104 F) and moisture. KEEP THIS MEDICATION OUT OF REACH OF CHILDREN.
[Innovative (RLD) Company Name Inc. / Ltd.]
NOTE: Examine innovators labeling carefully and reproduce meeting all regulatory requirements
Sect: 5.7
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION V
SECTION 5
Labeling Certification Statement

[GENERIC Name] Semisolid [USP]
[000] mg per g
Certification.
Generic Drug's proposed labeling same as Reference Listed Drug. The undersigned hereby certifies to the best of our knowledge and in [Generic Company Name Inc. / Ltd.]s opinion the proposed labeling is the same as listed drug [RLD] SEMISOLID [USP] - NDA # 00-000.
----------------------------------------Date
444
Sect: 5.8
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
Bioavailability / Bioequivalence
TABLE OF CONTENTS
Title Page and brief summary statement of what this section contains. Formula Composition of Generic product Percent Composition of Formula Comparative Ingredients List between Innovator & Generic (all strengths) Certificates of Analysis of Generic Drug Product - (all strengths) Certificates of Analysis for Innovators Product - (all strengths) Biostudy Waiver Request for other strengths (multiple strength applications). Outline of packaging container closures - proposed marketing packs. Packaging trail of all packed units. Biostudy protocol & Biostudy Study Reports1 (conducted on pivotal batch). 1 (Biostudy = Bioavailability / Bioequivalence/Topical Bioequivalence Study)
NOTE
Topical corticosteriods are a specific class of topical semisolids that have a
published FDA guidance procedure (June 1992) on in-vivo bioequivalence using a vasoconstrictor bioassay and include guidelines on a Franz cell diffusion test.
Sect: 6.1
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
HIS section contains the Biostudy reports of the Topical Bioequivalence study conducted against the selected RLD. The lot numbers of test product and reference product compared in this study are listed in Table 1:
Generic Product Chosen:

[Generic name] Semisolid [USP] [000.0] mg/g. Lot: 000 was manufactured at [Generic Company Name Inc./Ltd.] [Address] facility, utilizing the production area and incorporating standard production staff, procedures and equipment. The Batch size was: Batch size: 150 Kg equal to [150 000] one gram dosage applications of the Semisolid Dosage Form
Reference Product Chosen:

[RLD Company Name Inc./Ltd.], [RLD] Semisolid Dosage Form [USP] [000.0] mg/g Lot: AA000 Expiry Date: Month Year.
This Section contains:

Statement of composition of the Generic Product strengths - [Generic Name] Semisolid [USP] [000.0] mg/g Percent composition of the Generic Product [Generic Name] Semisolid [USP] [000.0] mg/g - (give all strengths where appropriate.) Qualitative comparative Ingredient List of the Reference Listed Product (RLD) and Generic Product - (give all strengths where appropriate.) Certificates of Analysis for both products used in the Topical Bioequivalence. Certificates of Analysis for both products requested in the waiver
Sect: 6.2
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
Products used in Topical Biostudy:
PRODUCT REFERENCE GENERIC
Table 1 Strength
[RLD] Semisolid [USP] [000.0] mg/g [Generic name] Semisolid [000.0] mg/g
Batch No:
Lot: AA000
C o A No:
R000
Lot: OO0
G000
Products in Study Waiver Request:

PRODUCT REFERENCE REFERENCE
Table 2 Strength
[RLD] Semisolid[USP] [000.0] mg/g [RLD] Semisolid[USP] [000.0] mg/g
Batch No:
Lot: AA000
C o A No:
R001
Lot: BB000
R002
GENERIC GENERIC
[Generic name] Semisolid [000.0] mg/g [Generic name] Semisolid [000.0] mg/g
Lot: OO0
G001
Lot: OO0
G002
ATTACHED The Packaging and Disbursement Summary for [Generic Company Name Inc./Ltd.] Topical Biostudy pivotal Lot: OO0.
Sect: 6.3
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
FORMULA COMPOSITION
Composition of the drug, stating the name and amount of each ingredient, whether active or not, contained in a stated quantity of the drug, in the form in which it is to be distributed.
PERCENT COMPOSITION OF THE PRODUCT

[Generic name] FORM [USP]
Table 3.
FORMULA INGREDIENTS
Amount in mg per gram

mg PURPOSE ACTIVE1 EMULGENT OIL BASE PRESERVE ANTIOXIDANT EMULGENT CHEALATE AQ. PHASE
Miconazole USP Micronized Pegoxol 7 Stearate [Tefose 63] Heavy Mineral OIL NF Benzoic Acid USP Butylated Hydroxyanizole Peglico 5 Oleate
[LABRAFIL M 1944]
20.00 180.00 44.80 2.00 000.05 30.00 1.50 721.65 1000.00
Edetate Disodium USP Purified Water USP TOTAL

1
The weight of the ACTIVE may alter according to the potency of active raw material
Sect: 6.4
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
QUALITATIVE COMPARATIVE
INGREDIENTS LIST
Table 4.
[Generic name] Form [USP]
[Active Material] [Generic Company Name Inc. / Ltd.]
[RLD] Form [USP]

[Active Material] [RLD Company Name Inc. / Ltd.]*
[LABRAFIL M 1944]
Miconazole USP Pegoxol 7 Stearate [Tefose 63] Heavy Mineral OIL NF Benzoic Acid USP Butylated Hydroxyanizole Peglico 5 Oleate Edetate Disodium USP Purified Water USP
Edetate Disodium USP Purified Water USP
* Reference Source
PDR 1998/1999
Note: Qualitative comparative ingredients list are identical for all dosage strengths.
Sect: 6.5
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
CERTIFICATES OF ANALYSIS
REPRESENTING THE DRUG PRODUCTS USED IN BIOEQUIVALENCY STUDY
The analytical results of the Certificates of Analysis for [Generic Company Name Inc. / Ltd.] and [RLD Company Name Inc. / Ltd.] Drug Product lots were obtained from the Analytical Research Laboratories at [Generic Company Name Inc. / Ltd. & Address].
Generic Product: Attached Certificate of Analyses in support of waiver: (3 Batches for antibiotics)
Certificate of Analysis Certificate of Analysis Certificate of Analysis Certificate of Analysis Certificate of Analysis Certificate of Analysis No: No: No: No: No: No: A01 A02 B01 B02 C01 C02 Lot: A00 [000.0] mg/g Lot: A00 [000.0] mg/g Lot: B00 [000.0] mg/g Lot: B00 [000.0] mg/g Lot: C00 [000.0] mg/g Lot: C00 [000.0] mg/g Date: MM DD YY Date: MM DD YY Date: MM DD YY Date: MM DD YY Date: MM DD YY Date: MM DD YY
Innovative Product (1 Batch) Certificate of Analyses

Certificate of Analysis Certificate of Analysis No:AA01 No:AA01 Lot: AA02 Lot: AA02 [000.0] mg/g [000.0] mg/g Date: MM DD YY Date: MM DD YY
FDA GUIDELINE NOTE: The evidence available at this time for the in vitro-in vivo correlation of release tests for semisolid dosage forms is not as convincing as that for in vitro dissolution as a surrogate for in vivo bioavailability of solid oral dosage forms. Therefore, the FDA's current position concerning in vitro release testing is as follows:
In vitro release testing is a useful test to assess product sameness under certain scale-up and post-approval changes for semisolid products. The development and validation of an in-vitro release test is not required for approval of an NDA, ANDA or AADA nor is the in vitro release test required as a routine batch-to-batch quality control test. bioequivalence.
In vitro release testing, alone, is not a surrogate test for in vivo bioavailability or The in vitro release rate should not be used for comparing different formulations
across manufacturers.
Sect: 6.6
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
Bioavailability / Bioequivalence CERTIFICATE OF ANALYSIS

Chromatogram part only. RLD: Lot No: Exp. Date: Analysis Date: Fill Size Standard Chromatogram
Barr spec.15 14/2/98 12:03 Assay Innovator 000mg Sample D-3400 method SI- 00-00 Tabs. Tag 44 CH: 1 Vial :
File 15 RT 3.63 7.61 14.63 15.93 Total Calc-Method: AREA 445 5553456 645 445 AREA HEIGHT 56 588456 66 96 HEIGHT Conc. 0.0008 99.995 0.0011 0.0008 Conc. BC BB BB BB BB
8
BC No: 1 2 3 4 No:
Lab book Ref.
GENERIC:
Lot No:
Exp. Date:
Analysis Date:
Fill Size
Standard Chromatogram
Barr spec.16 Assay Generic Sample D-3400 method SI- 00-00 14/2/98 13:43 000mg
Tabs Tag 45 CH: 1 Vial :

HEIGHT Conc. 0.0008 99.995 0.0008 0.0008 BC BB BB BB BB Conc. No: 1 2 3 4
11
BC No:
File 15 Calc-Method: AREA RT AREA HEIGHT 3.63 445 56 7.62 5553456 588456 14.63 445 66 15.93 445 96
Lab book Ref.
Sect: 6.7
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
REQUEST FOR WAIVER OF IN-VIVO BIOAVAILABILITY STUDIES STATUS OF EACH STRENGTH:
[Generic Product] Semisolid 000 mg/g - Bioequivalence Study Submitted in this ANDA. [Generic Product] Semisolid 000 mg/g [Generic Product] Semisolid 000 mg/g [Generic Product] Semisolid 000 mg/g - Waiver hereby being requested. - Waiver hereby being requested. - Waiver hereby being requested.
WAIVER REQUEST
[Generic Firm] hereby request a waiver of evidence for a topical bioequivalency with respect to [Generic Product] Semisolid 000 mg/g USP as listed in Table 2. A topical bioequivalency study was conducted on [Generic Product] Semisolid 000 mg/g (Table 1) and a full report of the biostudy is included in Section VI of this ANDA. The [Generic Product] Semisolid 000 mg/g which is the subject of this application, has the same geometric proportional formulation as the [Generic Product] Semisolid mg strengths per gram given in Table 3. MULTI-STRENGTH PREPARATIONS The milligrams per gram Semisolid and comparative percent compositions of the [one/two/three] strengths are shown for purposes of similarity in Table 5 (not shown).
Sect: 6.8
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
Biostudy Section of Packaging and Disbursement Summary for Pivotal Lot: 000
Product: [Generic name] SEMISOLID [USP] [000] mg/g - Batch No: 000
60g HDPE Collapsible Tube with cap/nozzle [00 mm]

200 units x 60 g Packaging date: M onth DD, 1999
Nov.28, 1996
55 units x 60 g Release & Stability Testing
5 units x 60 g QC Testing
BIOSTUDY
80 units 60 g Balance stored in Pivotal Warehouse
M onth DD, 1999
M onth DD, 1999

60 units 60 g Biostudy (European Market)
M onth DD, 1999

Nov.28, 1996
10 units x 30 g QC Testing & Reserve units
200 units x 30 g
BIOSTUDY
Balance stored in Pivotal Warehouse
M onth DD, 1999
M onth DD, 1999
65 units x 30 g Biostudy & Retained Samples
M onth DD, 1999
Refer to Section 12 for complete Packaging and Disbursement summary of Pivotal Lot: 000
Sect: 6.9
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
FINAL TOPICAL BIOEQUIVALENCE REPORT
(Summary Report Here)
FULL BIOEQUIVALENCE PRESENTED IN SEPARATE BINDINGS AS STAND ALONE VOLUME(S) USING FDA BIO JACKET COVERS (RED).
Sect: 6.10
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
Bioavailability/ Bioequivalence
FINAL REPORT
TITLE
BIOEQUIVALENCE Evaluation of two Topical [Active Material] Preparations in [00] Healthy Volunteers
SPONSOR [Applicant Company Name Inc. / Ltd.] [Address] [CRO Company Name Inc. / Ltd.] [Address] [CRO Testing Lab Name Inc. / Ltd.] [Address]
INVESTIGATION SITE
ANALYTICAL CENTER(S)
BIOMETRICAL CENTER
[CRO Biometrics Center Name Inc./Ltd.] [Address] [Name of Principal Investigator]

[Principal Investigator Qualifications]
PRINCIPAL INVESTIGATOR CLINICAL STUDY DATES Start Date Completion date DATE OF COMPLETION OF FINAL REPORT Report Code No
Month DD, 200Y Month DD, 200Y Month DD, 200Y
S00000
Sect: 6.11
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
TABLE OF CONTENTS
VOLUME ONE
1. 2. 3. 4. Section Section Section Section : : : : : : : : : : : Project Summary Rationale for [topical] study. Summary of Statistical Analysis Study protocol, Protocol amendments, Informed Consent, IRB Approval, and Clinical Report. Summary of Bioequivalent Data. Individual Linear and Semi-log graphs Statistical report on [Active Material] Analytical Report for[Active Material] Results of [Active Material] Statistical Data of Standards and Quality Control Samples for [Active Material] Chromatograms of [Active Material]
5. Section 6. Section 7. Section 8. Section 9. Section 10. Section 11. Section
VOLUME TWO
1. 2. 3. 4. 5. Appendix : Appendix : Appendix : Appendix : Appendix : Validation of [Active Material] Validation Report for [Active Material] Chromatograms of [Active Material] Statistical Data of Standards and Quality Control Samples Short description of Testing Facilities Testing Facilities in US Testing Facilities in Europe BIOMETRICAL Center in US
VOLUME THREE
1. Appendix : Case Records Forms.
Sect: 6.12
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
STATEMENT OF STUDY FACILITY

STATEMENT ON STUDY FACILITY
This report is respectfully submitted to [Applicant Company Name Inc. / Ltd.] [Address] The signature below attests to the content and accuracy of the clinical part of this final report based on the aspects of the investigation performed at the facilities of [Testing Facilities Inc. in US] situated [Address].
Month DD, 1999
[Signature of Responsible Person] [Name of Principal Investigator] Principal Investigator
----------------------------------------Date
Sect: 6.13
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
Bioavailability/ Bioequivalence STATEMENT OF TESTING FACILITY

STATEMENT ON STUDY FACILITY STATUS
The undersigned hereby conforms that our testing facility in [Address] operates in compliance with all regulatory requirements of the US Food and Drug Administration. [CRO Testing Facilities in US] [Address] guarantees that at the time of the analysis of biological samples performed in the Study No [0000] the [Testing Facilities in US] had no current outstanding deficiencies as cited by the FDA or other government agency and that the facility fully met the performance requirements for current Good Laboratory Practice (cGLP) of the US Food and Drug Administration and US Code 21 Federal Register.
[Signature of Responsible Person] -----------------------------------------------[Name of CEO / President]
--------------------------------Date
CEO / President
Sect: 6.14
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
STATEMENT OF BIOMETRICAL FACILITY
This report is respectfully submitted to [Applicant Company Name Inc. / Ltd.] [Address] The signature below attests to the content and accuracy of the biometrics part of this final report based on the aspects of the investigation performed at the facilities of [Testing Facilities in US] [Address].
Month DD, 1999
[Name of Principal Investigator] Principal Pharmacokeneticist
----------------------------------------Date
Sect: 6.15
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
PROJECT SUMMARY
This report is respectfully submitted to [Applicant Company Name Inc. / Ltd.] [Address]. The objective to determine the bioequivalence of [Generic name] Semisolids [USP] [000.0] mg/g in comparison to a registered preparation of [Innovator name] Semisolids [USP] marketed by [Innovator] in [Country] This project was designed as a randomized, single application, two way, crossover comparative study for evaluating topical bioequivalence / pharmacokinetics of the following test preparations: [Generic name] Semisolid [000.0] mg / g Lot: 000 versus the [RLD] Semisolid [000.0] mg /g. Lot: AA000 THE Study was performed in [00] healthy volunteers who received a [000] mg single application of [Active Material] under controlled study conditions. DETERMINATION of [Active Material] were performed according to SOP 00 on the samples collected, following application of the topical forms. [Active Material] concentration was determined by a validated [GC-MS] / [HPLC] method. BASED on the results of the study the test product is comparable in rate and extent of absorption for the reference product for [Active Material] THE clinical observations were unremarkable. No significant or unexpected changes in vital signs, ECGs, physical examinations or clinical laboratory tests were observed. Only one subject showed a mild adverse reaction.
[Signature of Responsible Person] ----------------------------------------[Name of Principal Investigator] Principal Investigator Date
Sect: 6.16
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
TITLE
BIOEQUIVALENCE Evaluation of two Topical [Active Material] Preparations in [00] Healthy Volunteers
Volume One
STUDY DATA
VOLUME ONE 1. Section 2. Section 3. Section 4. Section 5. Section 6. Section 7. Section 8. Section 9. Section 10. Section 11. Section 12. Section : Project Summary : Rationale for [topical] study according to FDA Guidelines. : Summary of Statistical Analysis : Study protocol, Protocol amendments, Informed Consent, IRB Approval, and Clinical Report. : Summary of Bioequivalent Data. : Individual Linear and Semi-log graphs : Statistical report on the [Active Material] : Analytical Method Report for [Active Material] : Analytical Method Validation for the [Active Material] : Test Results of [Active Material] : Analytical Chromatograms of the [Active Material] : Statistical Data of Standards and Quality Control Samples for the [Active Material]
Sect: 6.17
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
TITLE
BIOEQUIVALENCE Evaluation of two TOPICAL [Active Material] Preparations in [00] Healthy Volunteers
Volume Two
APPENDIXES
1. Appendix : Validation of [Active Material] 2. Appendix : Validation Report for [Active Material]a 3. Appendix : Chromatograms of [Active Material] in Plasma 4. Appendix : Statistical Data of Standards and Quality Control Samples 5. Appendix : Short description of Testing Facilities Testing Facilities in US [Address] Testing Facilities in Europe [Address] BIOMETRICAL Center in US [Address]
Sect: 6.18
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
TITLE
BIOEQUIVALENCE Evaluation of two TOPICAL [Active Material] Preparations in [00] Healthy Volunteers
Volume Three
Case Records Forms
1. Appendix : Case Records Forms (format - electronic on disk).
(Consideration as to presenting the Case Records Forms for review via an electronic format - i.e. Digital or Scanned Case Records Forms, where possible)
Sect: 6.19
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
BRIEF OVERVIEW
TYPES OF BIOEQUIVALENT STUDIES FOR SEMISOLIDS

IN VIVO BIOEQUIVALENCE STUDIES
The design of in vivo bioequivalence studies for semisolid dosage forms varies depending on the pharmacological activity of the drug and dosage form. A brief general discussion of such tests follows.
Objective:
To document the bioequivalence of the drug product for which the manufacture has been changed, is defined in SUPAC-SS, compared to the drug product manufactured prior to the change or compared to the reference listed drug (RLD).
Design:
The study design is dependent on the nature of the active drug. The bioequivalence study can be a comparative skin blanching study as in:
Glucocorticoids (FDA, Topical Dermatological Corticosteroids: In Vivo

Bioequivalence, June 2, 1995.)
Comparative clinical trial or any other appropriate validated

bioequivalence study (e.g., dermatopharmacokinetic study) for the topical dermatological drug product.
Analytical Method:
The assay methodology selected should ensure the following Specificity Accuracy Inter-day precision (ruggedness) Intra-day precision (ruggedness) Linearity of standard curves Adequate sensitivity Recovery Stability of the samples under the storage and handling conditions associated with the analytical method.
Sect: 6
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VI
SECTION 6
NOTES
Sect: 6
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VII
SECTION 7
Components and Composition TABLE OF CONTENTS

7.1 Section Page (with Color Section TAG) and brief descriptor of the section. A complete statement of components and composition is provided in this section. A comparison 7.2 List of Components - in order of manufacture (name & grade) 7.3 Formula Composition of Generic Product 7.4 Percent Composition of Generic Product
This section contains: List of components Formula Composition Percent Composition
FDA's Published January 1999 ANDA Guideline requirements

1. Components and Composition Statement
Sect: 7.1
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VII
SECTION 7
Components and Composition LIST OF COMPONENTS

Following is a full list of the articles used as components of the drug product:
SEMISOLIDS [USP] [000.0] mg per g

(equivalent to [000.0] mg [Active Material]
1. Miconazole USP Micronized 2. Pegoxol 7 Stearate [Tefose 63] 3. Heavy Mineral OIL NF 4. Benzoic Acid USP 5. Butylated Hydroxyanizole 6. Peglico 5 Oleate [LABRAFIL M 1944] 7. Edetate Disodium USP 8. Purified Water USP
Sect: 7.2
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VII
SECTION 7
Components and Composition

FORMULA COMPOSITION
Composition of the drug, stating the name and amount of each ingredient, whether active or not, contained in a stated quantity of the drug in the form in which it is to be distributed.
[Generic name] Semisolids [USP] FORMULA INGREDIENTS

MATERIALS
mg
Amount in mg per gram

PURPOSE
ACTIVE EMULGENT OIL BASE PRESERVE ANTIOXIDANT EMULGENT CHEALATE AQ. PHASE
[LABRAFIL M 1944]
20.00 180.00 44.80 2.00 000.05 30.00 1.50 721.65 1000.00
Edetate Disodium USP Purified Water USP TOTAL
* The weight of the ACTIVE may alter according to the potency of active raw material
Sect: 7.3
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VII
SECTION 7
Components and Composition

PERCENT COMPOSITION OF THE PRODUCT
[Generic Name] Semisolids [USP]
Formula Ingredients Miconazole USP Micronized [Pegoxol 7 Stearate Tefose 63] Heavy Mineral OIL NF Benzoic Acid USP Butylated Hydroxyanizole Peglico 5 Oleate [LABRAFIL M 1944] Edetate Disodium USP Purified Water USP
Amount in % per gram 2.000 18.000 4.480 0.200 0.005 3.000 0.150 72.165 100.000 %
TOTAL
Sect: 7.4
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8
Raw Material Control TABLE OF CONTENTS

Active Ingredient(s) 8.1 Title Page and brief summary statement of what this section contains 8.2 Outlines of SOPs for handling Raw Materials (Retest procedure max. 12 months) - Outlines of SOP for Qualification of Vendors - Outlines of SOP for Acceptance Criteria - Outlines of SOP for Retesting Schedules - Outlines of SOP for Raw Materials storage 8.3 Disclosure of Active ingredients Source 8.4 DMF of Manufacturer via Letter of Access from Active Manufacturer (Type II) 8.5 Active Monograph supplied by QC laboratory 8.6 CoA from Generic Firms QC laboratory, plus supporting - Identification IR or UV spectra of Active - HPLC chromatograms (Assay - Impurities) - label peaks - Photocopy of TLC chromatograms (Assay - Impurities) 8.7 CoA from Active Manufacturer, - plus supporting - Identification IR or UV spectra of Active - HPLC chromatograms (Assay - Impurities) - label peaks - Photocopy of TLC chromatograms (Assay - Impurities) 8.8 IR Identification Spectra of Reference Standard (Pharmacopoeial) 8.10 Physical Specifications from Active Manufacturer - Bulk Density, - Particle Size (note: water insoluble material) - Physical and analytical test methods 8.11 Outline of Material Data Safety Sheet (MDSS) (source of data for manufacturing instructions precautions). Inactive Ingredients Testing Specifications (ID and characterization) Suppliers Certificate of Analysis (Specifications and Test Results)
8.12 8.13
Sect: 8.1
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8
Raw Material Control

This section contains:
Outline of the Standard Operating Procedures for Raw Materials Summary of Lot Numbers of Active and Inactive Ingredients Disclosure of Active Ingredient Source (approved supplier) Active Ingredient DMF Authorization Letter Active Ingredient Certificates of Analysis Active Ingredient Supporting Data (Spectra) Outline of Material Data Safety Sheet (MDSS) Inactive Ingredient Testing Monographs & Test Procedures Inactive Ingredient Certificates of Analysis Routine Testing Protocols - retest schedules
FDA's Published January 1999 ANDA Guideline requirements:Section VIII. Raw Materials 1. Active ingredient(s). a. Synthesis listing manufacturer/supplier (Type II DMF authorization letters) b. Certificates of analysis specifications and test results from drug substance manufacturers c. Testing specifications and data from drug product manufacturer(s) d. Spectra and chromatograms for reference standards and test samples e. Retesting period 2. Inactive ingredients ( 3l4.94(a)(9)) a. Testing specifications (including identification and characterization) b. Suppliers' certificates of analysis (specifications and test results) c. Retest schedule
Sect: 8.2
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8

OUTLINE OF STANDARD OPERATING PROCEDURES FOR HANDLING RAW MATERIALS AND PACKAGING MATERIALS
1. Vendors Approval All chemical raw materials used in the manufacturing of commercial products and primary stability batches, must be supplied by approved vendors. The approval of vendors is a shared responsibility of the QA Department of the plant and the Purchasing Department. For pilot batches, the R&D Department is responsible. The Purchasing Dept. submits an application to approve a vendor to the QA Department, specifying the full details of the vendor and samples identified by the manufacturer, including the Certificates of Analysis of the manufacturer. The manufacturer must have a DMF (Drug Master File) submitted to the FDA. The QC Laboratory tests must confirm that the Certificate of Analysis, which must accompany the raw material, meets the raw material requirements. In the absence of a pharmacopoeia monograph, compliance to an approved inhouse monograph is required. The in-house monograph forms part of the requirements. The use of an alternative active raw material from a new vendor, not stated in the ANDA, is subject to the prior approval of the FDA. After obtaining satisfactory results, and if required the approval of the appropriate health authority, the QA Unit approves the new vendor. 2. Acceptance Criteria All raw materials are quarantined after receipt at the firms warehouse, pending tests and analysis. With the arrival of raw materials, the existence of a purchase order is checked, including the line number of the order. The status of the vendor and the condition in which the goods arrived is full examined. All lots are sampled. Each lot must have a manufacturers Certificate of Analysis for the QC department review. The initial batches of an approved vendor are tested according to the full monograph. When the reliability of the vendors Certificate of Analysis is established and the vendor is approved, the use of an abbreviated monograph is evaluated. A full compendial monograph is performed every 6 months on all incoming raw material lots. On receipt, each sample undergoes at least one (1) identification test. Further routine tests are performed as required by the respective testing program.
Sect: 8.3
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8

Rejected Batches:
Raw materials samples not approved for use by the laboratory will be marked by a laboratory issued red Rejected label, affixed to the sample by a quality assurance unit, and transferred to the Rejected area of the warehouse. Rejected materials will remain in the Rejected area until a final decision is reached whether to return them to the supplier or to destroy them. 3. Retest Schedule Each lot of raw material remaining in the inventory is retested based on the previous date of analysis. Retest period for highly sensitive materials (actives and excipients) and materials requiring microbiological testing, is 12 months. All other active and excipient materials are retested after 24 months, or as stipulated in the laboratory documents. [Active Material] (Approved Supplier) will be retested after 12 months. 4. Storage Quarantine Storage 1. Raw materials shall be stored in controlled environmental areas under monitored environmental storage temperatures, held between 15o to 25oC. 2. Raw materials received shall be marked with identification labels QUARANTINE Do Not Use! Materials shall be sampled and then transferred, for holding in the quarantine area, pending QC release. 3. The quarantine for raw materials requiring cooling or freezing shall be stored in controlled and routinely monitored refrigerators or deep freezers, capable of maintaining the correct temperature conditions for the appropriate raw material. 4. The raw materials shall be stored, off the floor, on a shelf, on a palette, in cages or in appropriate refrigerated units. 5. The raw materials shall remain in the quarantine area throughout the QC Analytical Laboratory material acceptance testing. Release from Quarantine 1. Raw materials released by the QC laboratory for use in production, shall receive a green Released label. The label is printed by the QC Lab computer and attached over the orange part of the label marked QUARANTINE - Do Not Use!. 2. The expiration dates for the released raw materials are printed on the labels by the QC lab computer. Materials having a green Released label will be transferred to the released materials storage area. 3
Sect: 8.4
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8

Summary of Batch Numbers of Active & Inactive Raw Materials Used in the Executed (Pivotal) Batch - Lot: 000
Raw Material Raw Material Batch Numbers Used for MNF of Lot:
Lot: 1002
Representative Certificate of Analysis(a) CoA # CoA # CoA # CoA # CoA # CoA # CoA # CoA #
Miconazole USP [micronized Lot # material] Pegoxol 7 Stearate [Tefose 63] Butylated Hydroxyanizole Benzoic Acid USP Peglico 5 Oleate [LABRAFIL M 1944] Heavy Mineral OIL NF Edetate Disodium USP Purified Water USP
(a)
Lot # Lot # Lot # Lot # Lot # Lot # Lot #
A Certificates of Analysis is provided for each ingredient lot used in the manufacture of the Executed Pivotal batch - Lot: 002. In cases where full monograph testing has not been performed on the specified lot used in the pivotal batch, a representative Certificate of Analysis (that is, within a six month period from date of batch manufacture) is provided to confirm full monograph testing results. A Letter of Authorization to reference the DMF and Certificates of Analysis are enclosed. Each lot received by THE COMPANY will be fully tested in accordance with the methods and limits stated in this application. Any batch lot of ACTIVE MATERIAL remaining in warehouse stock for a period exceeding 12 months shall be fully re-tested to a full monograph prior to manufacture.
Sect: 8.5
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8
Active Material Control

The manufacturer and approved supplier of the active ingredient
[Active Material] (Approved Supplier) is:
Approved Supplier: [Name] Pharmaceutical and Chemical Company

Address: [Name] Pharmaceutical and Chemical Company Street Town Country State Zip Code
A Letter of Authorization to DMF and Certificates of Analysis are attached.
Commitment to Compendial Requirement Testing

THE COMPANY commits to perform future pharmacopoeial analyses in accordance with all compendial testing (or otherwise approved testing) at the time the active material are used in the manufacture of [Generic name] SEMISOLIDS [USP] [000.0] mg per g containing the [Active Material] from (Approved Supplier name.) Any batch lot of [Active Material] which remains in stock for a year will be fully retested prior to use.3
Sect: 8.6
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8

Physical Specifications of Active Materials
TEST METHODS PHYSICAL SPECIFICATIONS
[ACTIVE MATERIAL]
SPECIFICATIONS TEST RESULTS Complies Complies TEST METHOD
Bulk Density Suppliers CoA - C0000 Particle Size Suppliers CoA - C0000 Bulk Density In-house CoA - C0000 Particle Size In-house CoA - C0000
06-07g/cc d90 < 250
SI-A076-01 SI-A076-02
06-07g/cc d90 < 250
Complies Complies
SI-A076-01 SI-A076-02
Notes: Active Material Full Monograph from QC laboratory indicating all chemical, Physical and microbiological tests is attached. CERTIFICATE OF ANALYSIS Included (ref. page [00-00]) are the drug substance manufacturers certificate of analysis, specifications and test results including identification and assay IR and HPLC specta and chromatograms as used in Lot # [00-0000] used by the applicant to manufacture the ANDA batch used in the bioequivalent study supporting this ANDA. LETTER OF AUTHORIZATION A letter of authorization to access DMF# [00-00] for the active material is attached to section XXI (ref. page [00). Please refer to DMF for the complete description of the drug substance including physical, chemical ,microbiological and stability parameters, where appropriate.
Sect: 8.7
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8

Certificate of Analysis and Spectra of Active and Reference Materials
Active Material Document Certificate of Analysis and Spectra Numbers. Material Supplied by:
Approved Supplier Approved Supplier
Certificate number # [C076-98] # [C076-98]
Remarks In-house CoA Suppliers CoA In-house Ref. Material In-house I R Suppliers I R In-house Ref. material In-house HPLC Suppliers HPLC In-house HPLC
[Active Material]
CoA
[Active Material]
CoA
[Active Material]
CoA
[Active Material]
I R Spectra (or UV)
Approved Supplier Approved Supplier Approved Supplier Approved Supplier Approved Supplier
# [C076-98] # [C076-98] Ref. F
[Active Material]
I R Spectra (or UV)
[Active Material]
I R Spectra (or UV)
[Active Material]
Typical HPLC Spectra
# [C076-98] # [C076-98] Ref. G
[Active Material]
[Active Material]
In-house Ref. material

Approved Supplier Approved Supplier
[Active Material]
Typical TLC Photocopy
# [C076-98] # [C076-98] Ref. G
In-house TLC Suppliers TLC In-house TLC
[Active Material]
[Active Material]
In-house Ref. material
Sect: 8.8
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8
Attachments.
Page No. ___ to Page No: ___ . Active Ingredients:
CoA and supporting Graphs/Spectra

Three (3) active material Certificates of Analysis attached as per table. Three (3) active material Three (3) active material Three (3) active material Three (3) active material I R Spectra Typical UV Spectra Typical HPLC Spectra Typical TLC Spectra
- as per table.
-
as per table. as per table. as per table.
(Presented in the order of tabulation).
Supporting Documentation
Active Ingredient DMF Authorization Letter Active Material Full Monograph from QC laboratory. Bulk Density and Particle Size test methods Outline of Material Data Safety Sheet (MDSS)
Sect: 8.9
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8

BULK MANUFACTURERS STATEMENT OF GMP
[Active Material Company Name Inc. / Ltd.]
[Active Material Company Name Inc. / Ltd.] certifies that the methods used in, and the facilities and controls used for, the manufacture, processing, packaging and storage of drugs at our [Active Material Company Name Inc./Ltd.] manufacturing plant conform to Current Good Manufacturing Practice in accord with 21 CFR Parts 210 and 211. Central File Numbers (CFN) for all facilities used in the manufacture, processing, labeling and packaging and quality control are CFN [00-0000-00] Last inspection date was MM/DD/YYY
and/or
[Active Material Company Name Inc. / Ltd.] certifies that the methods used in, and the facilities and controls used for, the manufacture, processing, packaging and storage of actives/intermediates at [Third Party Company Name Inc. / Ltd.] plant conform to Current Good Manufacturing Practice in accord with 21 CFR Parts 210 and 211. Central File Numbers (CFN) for all facilities used in the manufacture, processing, labeling and packaging and quality control are CFN [00-0000-00] Last inspection date was MM/DD/YYY
Plant General Manager Pharmaceutical Manufacturing Division [Active Material Company Name Inc. / Ltd.]
----------------------------------------Date
QA Manager Pharmaceutical Manufacturing Division [Active Material Company Name Inc. / Ltd.]
(Signed GMP statement required for all processing, warehousing and testing sites.)
Sect: 8.10
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8
Raw Material Control Non active Ingredients CERTIFICATES OF ANALYSIS
he following section contains Certificates of Analysis for the lots of inactive ingredients used to produce the pivotal batch. In the case where the lot used in manufacture was not tested to a full monograph (refer to list of routine tests in this section) the Certificates of Analysis for the most recent full monograph tested lot of the ingredient is provided as a representative CoA.
Hence, in some cases there are more than one set of THE COMPANYS
Certificates of Analysis for the same raw material ingredient. The first column in the table (below) represents the routine testing procedure CoA and the second column represents the full compendial or in-house monograph CoA.
The attached raw material testing procedures, in some instances, the Authorization
date may post-date the Certificates of Analysis supplied. These raw material testing procedures are updated to agree with subsequent compendial monographs.
Commitment to Compendial Requirement Testing
THE COMPANY commits to perform future analyses in accordance with all

compendial testing or otherwise approved testing at the time such raw materials are used in the manufacture of [Generic name] SEMISOLID [USP] [000.0] mg per g.
THE COMPANY may use other raw material suppliers subject to meeting in-house
approved supplier requirements and pharmacopoeial standards.
Sect: 8.11
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8

Summary of Certificate of Analysis Numbers of Non-active Raw Materials Used in the Executed (Pivotal) Batch. RAW MATERIAL Certificate of Analysis (CoA) Numbers. Approved Suppliers
1. Pegoxol 7 Stearate [Tefose 63] 2. Butylated Hydroxyanizole 3. Benzoic Acid USP 4. Peglico 5 Oleate [LABRAFIL M 1944] 5. Heavy Mineral OIL NF 6. Edetate Disodium USP 7. Purified Water USP [COMPANY] Used in MNF. Lot: [ICA00-00] [CA0326-98] [CA0526-98] [CA0136-98] [CA0325-98] [CA0024-98] [CA0076-98] [CA0126-98]
Representative C of As
[CA388-98] [CA237-98] [CA0637-98] [CA0224-98] [CA0572-98] [CA0637-98]
Note: Where excipients manufacturers have more than one plant the name of the approved excipient is followed by the country in which the plant is situated. Representative Certificates of Analysis are FULL monograph Certificates tested within a six (6) months period of the actual pivotal manufacturing date. Date Checks - all Representative Certificates of Analysis in date -
Yes q No. all Routine Certificates of Analysis precede pivotal MNF date Yes q No.
Note : Approved NON ACTIVE Suppliers are not an FDA OGD requirements at the time of publishing (December 1999), but is strongly recommended. NON ACTIVE SUPPLIERS List non-active suppliers only
Sect: 8.12
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8
Raw Material Control Non active Ingredients

Attachments.
CoAs Seven (7) Certificates of Analysis attached as per table. (Presented in the order of tabulation). Supporting Documentation Seven (7) Testing Monographs of non-active materials Seven (7) Routine Testing Protocols (List of Routine tests Performed on non-active materials)
Page References:
CoAs Testing Monographs Routine Testing Protocols
Page No. ___ to Page No: ___ . Page No. ___ to Page No: ___ . Page No. ___ to Page No: ___ .
Special Note:
Where inactive ingredient testing methods are non-compendial AND do not appear on the FDA Inactive Ingredient List (IIG) - the applicant is required to submit a 505 B2 Application. Thus all inactive ingredients should appear on the FDA's IIG.
Sect: 8.13
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION VIII
SECTION 8
Raw Material Control - Non active Ingredients

ROUTINE TESTING
Routine testing performed on each batch of inactive ingredients.
PEGOXOL 7 STEARATE
(Trade Name)
Description Identification Test Viscosity Microbial Limits BUTYLATED HYDROXYANIZOLE

(Trade Name)
Description Identification Test BENZOIC ACID USP Description Identification Test PEGLICO 5 OLEATE
(Trade Name)
Description Identification Test Viscosity Microbial Limits HEAVY MINERAL OIL NF Description Identification Test Viscosity Microbial Limits EDETATE DISODIUM USP
(Trade Name)
LIBRARY OF USP XXIII TESTS Description Solubility Identification Test Assay Impurities Related substances Ash value USP < > Loss on Drying USP < > K-Value USP < > Microbial Limits USP < > Microbial Testing USP < > Preservative efficacy USP < > pH USP < > Organic volatile Imp. USP < > Residual Solvents USP < > Viscosity USP < > USP Monograph (Full) USP < > Apparent Viscosity USP < > Water (KF) USP < >
CONTINUE LIBRARY OF USP XXIII / NF TESTS RELEVANT TO THIS APPLICATION Where absent from USP / NF add BP or Pharm Eur. Tests
Description Identification Test PURIFIED WATER USP Per week - Microbial Testing Per month - Full USP Monograph
Sect: 8.14
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION IX
SECTION 9
Description of Manufacturing Facility
TABLE OF CONTENTS
Section Page (with Color Section TAG) and brief descriptor of the section. The manufacturer of the final dosage form of the new drug for which this application is submitted is [Generic Company Name Inc. / Ltd.]. The applicant performs all of the manufacturing, packaging, testing and stability test functions of the submitted drug product. [Generic Company Name Inc. / Ltd.] does not manufacturer the active drug substance, the excipients or the container closure system used in the manufacturing and packing operations for the finished dosage forms. Details concerning the bulk active drug substance appears in section VIII as those of the excipients while details for the container closure system appear in section XIII. No / [One / Two] contract firms are involved in the finished [product testing], [packaging components] or [stability testing] requirements as filed in this ANDA
(Delete where required)
9.1 9.2 9.3 9.4
Statement of commercial site address of Manufacture(s) Statement of commercial packaging & Labeling site address Statement of commercial site of Distribution site address Address of Facility for QC and Stability Testing
9.5 Brief description of facilities for MNF, testing and stability (no personnel CVs). 9.6 Statement on the GMP Certification of Compliance Central File Number (CFNs) at manufacturing site.
FDA's Published January 1999 ANDA Guideline requirements Section IX. Description of Manufacturing Facility 1. Full address(es) of the facility(ies) for the manufacturing process, testing, and stability testing 2. Brief description of the facility. 3. For description of the facility sterile products, see Section XIV. 4. CGMP certification 5. Central File Number (CFNs)
4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION IX
SECTION 9

This section contains:Addresses of RESEARCH Facilities
[Generic Company Name Inc. / Ltd.] Description of Facility Responsible Personnel (Key Staff) List of Production Equipment Blueprint of Facility GMP Certification Statement
Addresses of Scale-up Facilities

[Generic Company Name Inc. / Ltd.] Description of Facility Responsible Personnel (Key Staff) List of Production Equipment Blueprint of Facility
Addresses of Manufacturing Facilities

[Generic Company Name Inc. / Ltd.] List of Responsible Personnel (Key Staff) Blueprint of Facilities GMP Certification Statement Drug Establishment Registration No [#00-00-00-00] NOTE: Applicant facilities with more than one site who perform special functions at the specific site (such as analytical or stability testing) need to describe these facilities in section VIII and X. A separate GMP certificate for that specific site needs to be included in the application.
Sect: 9.2
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION IX
SECTION 9
Description of Research Facility

Research & Scale-up Facilities
LIST OF RESPONSIBLE PERSONNEL (A) List of research facilities key personnel in the situation where the ANDA research site is geographically separated from the proposed manufacturing site (i.e. in another city, state or country.)
List of Small Scale Manufacturing Equipment

(B) List of research and small scale facilities equipment in the situation where the pivotal batch was manufactured at a site other than the proposed manufacturing site (e.g. Another city, state or country).
Blueprint of Research & Scale-up Facilities.

Note: The first three commercial batch lots manufactured at the proposed manufacturing site are required to be validated. [In addition - to the above OGD's requirements, lot validation may be initialized at the remote or foreign site].
Process Qualification Batch and/or Pivotal Batch
Sect: 9.3
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION IX
SECTION 9

LIST OF RESPONSIBLE PERSONNEL
1. 2. 3. 4. 5. 6. 7. 8. 9. Management Validation Unit Stability Unit Packaging Materials Lab. Physical Lab. Microbiology Lab. QC Lab. / QA Lab. Development (R&D) Lab. Warehousing 11. Weighing Center 12. Granulation Department 13. Drying Department 14. Milling Department 15. Sieving Department 16. Blending Department 17. Slugging Department 18. Compression 19. Coating Department 20. Other Departments
10. Housekeeping
LIST OF PRODUCTION EQUIPMENT

+ [Type of Equipment] 1. 2. 3. 4. 5. 6. 7. 8. 9. [Equipment ID. Number] [Equipment Document No.]
Scale-up Department Validation Unit Stability Unit Packaging Materials Lab. Physical Lab. Microbiology Lab. QC Lab. / QA Lab. Development (R&D) Lab. Warehousing
11. Weighing Center 12. Granulation Department 13. Drying Department 14. Milling Department 15. Sieving Department 16. Blending Department 17. Slugging Department 18. Compression 19. Coating Department 20. Packaging Department
10. Housekeeping
Sect: 9.4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION IX
SECTION 9

BLUEPRINT OF MNF FACILITY
Manufacturing, Testing and Storage Areas blueprints - showing facilities layout.
ADDRESSES OF FACILITIES
Manufacturing, processing, bulk packaging, bulk labeling, handling and storage of the bulk [Generic name] DRUG [USP] [000.0] mg. will take place at the pharmaceutical manufacturing facility identified below: [Generic Company Name Inc. / Ltd.] Pharmaceutical Manufacturing Division Industrial Area [Street] [Town] [State] [Zip Code] [Country].
and/or
Unit packaging, labeling and handling of all packed [Generic name] DRUG[USP] [000.0] mg. will take place at the manufacturing and packaging facility identified below: [Generic Company Name Inc. / Ltd.] Pharmaceutical Packaging Division Industrial Area [Street] [Town] [State] [Zip Code] [Country]. The packaged and labeled product will be distributed through the [Address] warehouse located at: [Generic Company Name Inc. / Ltd.] Pharmaceutical Warehouse Division Industrial Area [Street] [Town] [State] [Zip Code] [Country]. Finished product release testing and annual stability testing is performed by [Generic Company Name Inc./Ltd.] Analytical Research / QC Laboratories in accord with the Division of Generic Drugs Policy and Procedure Guide at: [Generic Company Name Inc. / Ltd.] Analytical Research / QC Laboratories Industrial Area [Street] [Town] [State] [Zip Code] [Country]. (Additional information on these sites is provided herein.)
Sect: 9.5
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION IX
SECTION 9
STATEMENT OF GMP
[Generic Company Name Inc. / Ltd.]
[Generic Company Name Inc. / Ltd.] certifies that the methods used in, and the facilities and controls used for, the manufacture, processing, packaging and storage of drugs at our [Generic Company Name Inc./Ltd.] manufacturing plant conform to Current Good Manufacturing Practice in accord with 21 CFR Parts 210 and 211. Central File Numbers (CFN) for all facilities used in the manufacture, processing, labeling and packaging and quality control are CFN [00-0000-00]
and/or
[Third Party Company Name Inc. / Ltd.] certifies that the methods used in, and the facilities and controls used for, the manufacture, processing, packaging and storage of drugs at our [Third Party Company Name Inc. / Ltd.] plant conform to Current Good Manufacturing Practice in accord with 21 CFR Parts 210 and 211. Central File Numbers (CFN) for all facilities used in the manufacture, processing, labeling and packaging and quality control are CFN [00-0000-00]
Plant General Manager Pharmaceutical Manufacturing Division [Generic Company Name Inc. / Ltd.]
QA Manager Pharmaceutical Manufacturing Division [Generic Company Name Inc. / Ltd.] (Signed GMP statement required for all processing, warehousing and testing sites.)
Sect: 9.6
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION X
SECTION 10
Outside firms and Contract Facilities
TABLE OF CONTENTS
10.1 10.2 10.3 10.4 10.5 10.6 Title Page and statement Name and Site Address of all Contract Laboratories Registration No. of each Contract Laboratory List of Test(s) or functions to be Performed by Contract Laboratory Certification letter of GMP/GLP Compliance of Contract Laboratory Statement on the cGMP Status and Certification of Compliance w.r.t - a contract manufacturing site - a contract labeler or packaging site. 10.7 Statement on the PAC-ALTS (Post-approval Changes - Analytical testing Laboratory Sites)
FDA's Published January 1999 ANDA Guideline requirements:Section X. Outside Firms, Including Contract Testing Laboratories 1. Full address 2. Functions 3. CGMP certification/GLP
Sect: 10.1
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION X
SECTION 10

Contract Facilities
[Generic Company Name Inc./Ltd.] does not intend the use of any outside manufacturing contract facilities at the prevailing time. If a contract outside facility is desired in the future, the appropriate documentation will be submitted to this ANDA.
(and / or)
Contract Testing Laboratories

[Generic Company Name Inc./Ltd.] does not intend the use of any contract testing laboratories facilities at the prevailing time. If a contract laboratory or outside laboratory is required in the future, the appropriate CBE documentation according to PAC-ALTS (Post-approval Changes - Analytical testing Laboratory Sites, April 1998) will be submitted to this ANDA.
----------------------------------------Date
QA Manager Pharmaceutical Quality Assurance Unit [Generic Company Name Inc./Ltd.]
----------------------------------------Date
Production Manager Pharmaceutical Manufacturing Division [Generic Company Name Inc./Ltd.]
4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION X
SECTION 10

(or where used)
Contract Testing Laboratories

The following contract testing laboratory was used during the development of [Drug Product] [00] mg & [00] mg: [Contract Laboratory Name Inc./Ltd.] [Address] The above laboratory developed and validated the analytical method for testing [Organic Volatile Impurities.] This method was transferred to [Generic Company Name Inc. Ltd.] and the active raw material for the pivotal batches was tested according to this method. Future commercial production batches will be tested also according to this method in [Generic Company Name Inc. Ltd.]. Enclosed [Contract Laboratory Name Inc./Ltd.] annual registration of drug establishment for the year 200Y.
----------------------------------------Date
QA Manager
Pharmaceutical Manufacturing Division [Generic Company Name Inc./Ltd.]
----------------------------------------Date
Production Manager
Pharmaceutical Manufacturing Division [Generic Company Name Inc./Ltd.]
Sect: 10.3
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION X
SECTION 10

ADDRESSES OF FACILITIES
Manufacturing, processing, bulk packaging, bulk labeling, handling and storage of the bulk [Generic name] Drug [000.0]mg [USP]. will take place at the pharmaceutical manufacturing facility identified below: [Third Parties Company Name Inc. / Ltd.] Pharmaceutical Manufacturing Division Industrial Area [Street] [Town] [State] [Zip Code] [Country] (and / or) Unit packaging, Labeling and handling of all packed [Generic name] Drug [USP] [000.0] mg. will take place at the manufacturing and packaging facility identified below: [Third Parties Company Name Inc. / Ltd.] Pharmaceutical Packaging Division Industrial Area [Street] [Town] [State] [Zip Code] [Country]
(and / or) The packaged and labeled product will be distributed through the [Address] warehouse located at: [Third Parties Company Name Inc. / Ltd.] Pharmaceutical Warehouse Division Industrial Area [Street] [Town] [State] [Zip Code] [Country] Finished product release testing and annual stability testing is performed by [Generic Company Name Inc./Ltd.] Analytical Research / QC Laboratories in accord with the Division of Generic Drugs Policy and current Procedure Guides [Third Parties Company Name Inc. / Ltd.] Analytical Research / QC Laboratories Industrial Area [Street] [Town] [State] [Zip Code] [Country]
Sect: 10.4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION X
SECTION 10
STATEMENT OF GMP OF
[Third Parties Company Name Inc. / Ltd.]
[Third Parties Company Name Inc. / Ltd.] certifies that the methods used in,
and the facilities and controls used for, the manufacture, processing, packaging and storage of drugs at our [Third Parties Company Name Inc. / Ltd.] plant conform to Current Good Manufacturing Practice in accord with 21 CFR Parts 210 and 211.
----------------------------------------Date
General Manager Pharmaceutical Division [Third Parties Company Name Inc. / Ltd.]
----------------------------------------Date
QA Manager Pharmaceutical Division [Third Parties Company Name Inc. / Ltd.]
Note: Current cGMP or if applicable CGLP certification statement(s) are required for EACH of the third party firms (outside firms) listed in this section
Sect: 10.5
ANDA DEVELOPMENT
ANDA DEVELOPMENT
Generic Drug Enforcement Act - 1992
Third Party Letterhead
STATEMENT
Where Company has NO previous convictions AND does not use a debarred person in connection with the ANDA
Certification Made Pursuant

to the Generic Drug Enforcement Act of 1992.
n behalf of [3rd Party Company Name Inc. / Ltd.], we hereby certify, pursuant to Section 2(k) Generic Drug Enforcement Act of 1992, 21 USC 335a (k), that the the undersigned firm has not used, is not using and will not in the future use in any capacity the services of any person who has been debarred pursuant to Section 2 (a) and or Section 2 (b) Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), in connection with this application.
We further certify that there have been no conviction of applicant for any of the
types of crimes set forth in Section 2(a) and Section 2(b) of the Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), within the five years prior to the date of this certification, nor has any person affiliated with our contracting firm, who is responsible in whole or in part, for the development or the submission of this application been convicted of any crime of the type listed in Section 2(a) and Section 2(b) of the Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), within the five years prior to the date of this certification.
[Signature of Responsible Person] ------------------------------------------------[Name of Responsible Person] --------------------------------------Date
[3rd Party Company Name Inc. / Ltd.]

__________________________
______________________
Date
Director Quality Assurance Unit Pharmaceutical Manufacturing Division
Sect: 10.6
ANDA DEVELOPMENT
ANDA DEVELOPMENT
Third Party Letterhead
STATEMENT
Where Company has a previous conviction but does not use a debarred person in connection with the ANDA

n behalf of [3rd Party Company Name Inc. / Ltd.], we hereby certify, pursuant to Section 2(k) Generic Drug Enforcement Act of 1992, 21 USC 335a (k), that the undersigned firm has not used, is not using and will not in the future use in any capacity the services of any person who has been debarred pursuant to Section 2 (a) and or Section 2 (b) Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), in connection with this application.
Wet further certify that during the previous five years our firm has sustained the
following conviction for the types of offenses as set forth in Section 2(a) and Section 2(b) of the Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), Date of Conviction MM/DD/YY Nature of Conviction Conviction on two counts of fraudulent documentation pertaining to analytical reports To the best of [3rd Party Company Name Inc. / Ltd.], knowledge no person affiliated with the applicant, who is responsible in whole or in part, for the development or the submission of this application has been convicted of any offense of the type listed in Section 2(a) and Section 2(b) of the Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), within the five years prior to the date of this certification.
[Signature of Responsible Person] ------------------------------------------------[Name of Responsible Person]
--------------------------------------Date
4
End of Section 10.
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION X
SECTION 10
STATEMENT OF PAC-ATLS
[Generic Company Name Inc. Ltd.]
[Generic Company Name Inc. Ltd.] certifies that when submitting a change in an analytical testing laboratory site the applicant will confirm in a written statement why a PAC-ALTS CBE supplement is appropriate. If the proposed change in the analytical testing laboratory site does not fall within the scope of PAC-ALTS, the change will be filed in a prior approval (PA) supplement.
----------------------------------------Date
QA Manager
Pharmaceutical Manufacturing Division
[Generic Company Name Inc./Ltd.]
----------------------------------------Date
Production Manager
Sect: 10.8
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XI
SECTION 11
Proposed Manufacturing Instructions
TABLE OF CONTENTS
(Current ANDA Guideline Requirements for this Section.)
Description of Manufacturing Process Manufacturing Procedure Flow Chart Blank Master Production Batch Records (largest intended commercial production lots.) Blank Packaging Records (largest intended commercial production lots.) Formula comparison (compares pivotal batch parameters with intended commercial production) Equipment Comparison (compares pivotal batch parameters with intended commercial production) Description of Intended Commercial Packaging Operation
Reprocessing Statement (if reprocessing step is undertaken full data, process validation rework specifications and stability must be shown in Section 21)
FDA's ANDA Guideline Requirements:(as Published January 1999)
Section XI.
Manufacturing and Processing Instructions
1. Description of the manufacturing process (including microbiological verification in Section XIV, as appropriate) 2. Blank batch records (for largest intended commercial production runs with equipment specified) 3. Reprocessing statement.
Sect:11. 1
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XI
SECTION 11

Section contents:
Outlines of process and controls Description of Manufacturing Process Manufacturing Procedure Flow Chart Blank Master Production Batch Records for intended production lots Blank Packaging Records for intended production lots Formula comparison between pivotal and intended commercial lots Equipment Comparison pivotal and intended commercial lots Description of Packaging Operation Reprocessing Statement(s)
Sect:11. 2
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XI
SECTION 11

OUTLINE OF STANDARD OPERATING PROCEDURES FOR : MANUFACTURING AND PROCESSING
1. 2. 3.
4.
5.
6.
7. 8. 9. 10. 11. 12. 13. 14.
Production Office - Prepares a production order file for each production batch according to the production schedule. Production Office - Assigns batch numbers, according to the existing code procedure, and enters these numbers in the batch numbers log. Production Office - A photocopy of the master formula record and manufacturing instructions is prepared with the specific manufacturing batch number. Production Office - Prepares all forms needed in the manufacturing process which are placed in the product order file. The file is then transferred to the Weighing Center/Dispensing Area. Dispensing Area - Weighs all raw material components according to the master formula record. For each weighing, the raw material receiving logbook number is entered on the master formula record. All materials belonging to one manufacturing batch of the product is placed on a separate pallet and covered with a pallet cover or clear shrink-wrap. As per production schedule the pre-weighed raw material on pallets are transferred to productions, by production personnel, under the responsibility of the department head. Production Depts. - During manufacturing, the product test results are recorded on the control forms which are attached to the master formula and manufacturing instructions batch record. Production Office - forwards a Standard Packaging Sheet with the computerized order to the packaging department. Packaging Department - forwards the Standard Packaging Sheet and the computer order to the packaging materials warehouse. Packaging Department - Authorizes packaging startup, in-process compliance, on the Packaging Work Sheet. After packaging, the packaged goods are transferred to the warehouse/holding area under a quarantine status, pending QC release. The product is tested by the QC analytical laboratory. Production records and test results are analyzed by QA Department and on release the product is moved to the warehouse ready for shipment. The batch records are archived by the Quality Assurance Department. Shipping Department - maintains a complete and traceability record of the dispatches of each product batch number and its final destination.
Sect:11. 3
Topical SEMISOLID
ANDA DEVELOPMENT
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SECTION 11

OUTLINE OF STANDARD OPERATING PROCEDURES FOR:
IN-PROCESS CONTROLS
1. At all stages of manufacturing, processing, time limitations and packaging appropriate control procedures are employed in conformity with current good manufacturing practice. 2. Appropriate in-process controls include material testing by quality control and quality assurance personnel. These test cover:
Physical specifications of the bulk material (Uniformity of Content) Fill Weights
3. In-process material testing is performed by Qualified Personnel. 4. The Quality Assurance Department reviews the batch test results and evaluates the acceptance or rejection of each batch lot.
Sect:11. 4
Topical SEMISOLID
ANDA DEVELOPMENT
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SECTION 11

IN-PROCESS CONTROLS DURING SEMISOLID FILLING
In-process testing is conducted independently by both production and quality control trained personnel. The tests specified in the underlying tables are performed in accord with the in-process product specifications. When, a test is not required, according to the written specifications, it will not be performed. Production personnel test the physical specifications of random samples
according to the individual product specifications: A minimum sampling frequency is tabulated for each eight hour (shift) period.
Production In-process
Testing Schedule:
TEST PERFORMED
Bulk Description
Sample Size
Frequency per shift (min)

(1)
Acceptance Criteria (2)

Within written specifications. NMT 2 Containers from of the 20 tested may deviate from product spec. No deviation permitted from Double Limits(3) specification. No deviation from product specifications is permitted.
At start.
Fill Weight (Active)
10
At 30 min. intervals. At 30 min. intervals.

KEY:
Cap Torque
The testing frequency is performed twice when the overall filling time is less than four hours.
Deviations from specifications and acceptance criteria, arising during the in-process controls, shall determine the corrective action to be performed on the filling machinery during the filling stage.
Sect:11. 5
Topical SEMISOLID
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SECTION 11
uality Control personnel test the physical specifications of random samples according to the individual product specifications sheets: A minimum sampling frequency is tabulated for each eight hour (shift) period.
Quality Control
In-process Testing Schedule:
TEST PERFORMED
Material Description
Sample Size
1 (1)
Frequency per shift (min.)

Once at start
(1)

No deviation from product specification is allowed. NMT 2 Containers from of the 20 tested may deviate from product spec. No deviation permitted from Double Limits(3) specification. No deviation from product specification is allowed
Individual Fill Weight
20 (1)
60 min
CAP TORQUE
6 (1)
60 min
KEY:
1
Samples are taken, independently by QC personnel for batch release purposes, at least once per hour throughout the FILL run, producing a total representative sample quantity of 20 - 40 Containers . This representative sample lot is for QC batch release purposes .
2
3
Double Limits for the Individual Fill Weight test are defined as the double value from the minimum or maximum limit in relation to the nominal Fill value (i.e. target weight value).
Sect:11. 6
Topical SEMISOLID
ANDA DEVELOPMENT
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BATCH RECORDS FOR POST-APPROVAL PRODUCTION BATCHES
nclosed are the production batch records (master, packaging and labeling) for Post-Approval production batch.
Translation Policy - for Non English Speaking Areas: Certain manufacturing and process and control documents may be written in [English and the National Foreign language] with some information in English only. Where information is provided in [English and a Foreign language], an authorized English translation is provided preceding the document in [English and the Foreign language]. Where only English is used on a page, no translation is provided.
Sect:11. 7
Topical SEMISOLID
ANDA DEVELOPMENT
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MANUFACTURING INSTRUCTIONS FOR COMMERCIAL PRODUCTION
Product name: Batch Number: Department: Precautions: Caution: Cat./Formula No: Based on PQ:
[Generic name] SEMISOLID USP [000.0] mg per g.
000
______________

# F0000 Batch # PQ-000
Change Control for this document:

Changes made: - none
Batch Size: 0000 Kg/units Sub-lot No: 1 2 3 Manufacture Date: Month DD, YY SEMISOLID PIVOTAL BATCH Validation Lot Commercial Lot Original - No Change : Change
KEY: Precautions:
Wear Mask and Gloves Wear disposable overalls Use air stream face visor with AIR filter Use Mask, Gloves and Safety glasses Avoid exposure to light / Protect form light Store in well closed containers Potential danger to pregnant women Pregnant women prohibited in this area Do not heat above 00C
Room humidity below 30%
Caution:
Note: (A modern real life manufacturing process for a SEMISOLID is provided as an example of how to prepare the manufacturing instructions. This specific set of manufacturing instructions was chosen as it represents the most complex example).
Sect:11. 8
Topical SEMISOLID
ANDA DEVELOPMENT
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MANUFACTURING INSTRUCTION COMMERCIAL PRODUCTION
[Generic name] SEMISOLID [USP] [000.0] mg/g Lot: 000
Miconazole Cream USP [20.0] mg/gram Batch No:
Mg Per gram
% Exc ess
Weighing Date :
Page 1 of 2 pages
Raw Material Names PART I - OIL PHASE
per [150] kg
Kg g
000 780 300 7 087 000 500 225 440 500
665
Sign weigh. Dept.
mg
mL
180.00 25.20 2.00 0.05 207.252
Pegoxol 7 Stearate [Tefose 63] Heavy Mineral OIL NF Benzoic Acid USP Butylated Hydroxyanizole
27 3
500 500
Theoretical End Weight. PART II

[Miconazole USP Micronized Peglico 5 Oleate [LABRAFIL M 1944] Edetate Disodium USP st Heavy Mineral OIL (1 Rinsing) nd Heavy Mineral OIL (2 Rinsing) Theoretical End Weight.
31 3 4
20.00 30.00 1.50 9.60 10.00
1 1
10
PART III - AQUEOUS PHASE

721.650 721.650
Purified Water USP Theoretical End Weight.
108 108
247 247
500 500
PART: IV MIXING STAGE

1000.0 1000.0
Edition Number: 01 Ed. Status: New
Combined Phases - [1+2] + 3 Theoretical End Weight.

Effective Date: DD/MM/YY
150 150
000 000
APPROVED
_____________ Department __________ R &D _______________ RA _________/________ QC / QA
Sect:11. 9
Topical SEMISOLID
ANDA DEVELOPMENT
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SECTION 11

Mg Per gram
% Exc ess
Weighing Date :
Page 2 of 2 pages
per [300] kg
Kg g
000 560 600 15 175 000 000 450 880 000
330
Sign weigh. Dept.
mg
mL
180.00 25.20 2.00 0.05 207.252
54 7
000

[Miconazole USP Micronized Peglico 5 Oleate [LABRAFIL M 1944] Edetate Disodium USP st Heavy Mineral OIL (1 Rinsing) Heavy Mineral OIL (2nd Rinsing) Theoretical End Weight.
62 6 9
20.00 30.00 1.50 9.60 10.00
2 3
21

721.650 721.650
216 216
495 495

1000.0 1000.0

300 300
000 000
APPROVED
Sect:11. 10
Topical SEMISOLID
ANDA DEVELOPMENT
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SECTION 11


Batch No: Weighing Date:
Page 1 of 4 pages
MANUFACTURING INSTRUCTIONS
Step 1. IDENTIFY the equipment and verify the cleanliness prior to use.
Machine
Sign A+B
Date
PART ONE - OIL PHASE

Step 2. LOAD into kettle No [ ] fitted with [Mixer # [ ]-Type & No) the ingredients in the following order: Pegoxol 7 Stearate [Tefose 63] Heavy Mineral OIL NF Benzoic Acid USP Butylated Hydroxyanizole and mix for [20] minutes at mixer setting speed II Step 3. HEAT while mixing to NMT [45] C (Target: [42] C). Time of adding [ ] min. Total Mixing Time [ ] min.
PART TWO Active OILY PHASE

Step 4. LOAD into a [Small Mixer-Type & No) the ingredients in the following order: Miconazole USP - Micronized Peglico 5 Oleate - [LABRAFIL M 1944] Edetate Disodium USP Mix for [20] minutes at mixer speed [II] until mix is fully micronized material is suspended and homogeneous. Step 5. HEAT while mixing to NMT [45] C (Target: [42] C). Target Temperature [ ] C START of mixing [ ] END of mixing [ ] Total Mixing Time [ ] min
Edition Number: 01 Ed. Status New Effective Date: DD/MM/YY
APPROVED
_____________ Department __________ R &D _______________ RA _______/________ QC / QA
Sect:11. 11
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Page 2 of 4 pages
PART THREE AQUEOUS PHASE
Step 6. Heating the Water Phase (i) WEIGH or MEASURE 000.0 Kg [PURIFIED WATER USP] into a stainless steel mixing kettle fitted with a high speed variable mixer. (#0) (ii) Operate the mixer while HEATING to NMT [95] C (Target: [95] C). (iii) Hold the heated Water at the target temperature for NLT60 minutes Target Temperature Time of Heating Total Process Time [ ] C). [ ] [ ] min
Machine
Sign A+B
Date
Step 7. Cooling the Water Phase COVER and Cool Step 6 [PURIFIED WATER USP] to a target temperature while slowly stirring - Target Temperature 280C [20C] Target Temperature Start of Cooling Time End of Cooling Time Total of Cooling Time NMT [ [ [ [ ] C ] ] ] min
PART FOUR - ADDITION OF OILY PHASE

Step 8. Add the Active Oily Phase STEP 4 to the Bulk Oil Phase STEP 2 and mix at speed [III] until homogeneous. RINSE active material twice with heavy mineral oil. Drain container fully after each RINSE procedure. Start of Mixing [ ] End of Mixing [ ] Total of Mixing Time [ ] min Step 9. Check that the oil phase after the mixing period is a homogeneously dispersed oily suspension - if necessary mix for an additional 20 minutes Start of Mixing [ ] End of Mixing [ ] Additional Mixing Time [ ] min
APPROVED
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ANDA DEVELOPMENT
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Page 3 of 4 pages
ADDITION OF AQUEOUS PHASE
Step 10. RECORD the Aqueous and Oil Phase temperatures. Temperature of AQUEOUS Phase NMT [30] C (Target: 280C [20C]) Temperature of OIL Phase NMT [30] C (Target: 280C [20C]) Step 11. ADD the aqueous phase to STEP 8 while continuously mixing at mixer speed III. Start of Mixing [ ] End of Mixing [ ] Total Mixing Time [ ] min Step 12. ATTACH the mixing kettle temperature graphs (Type & No) to the manufacturing instructions. Add the batch number to the temperature graph and Immediately date and sign it..
Machine
Sign A+B
Date
COOLING OF COMBINED PHASES

Step 13. COOL Step 11 to a target temperature while slowly stirring [Set I]. Target Temperature 250C [20C] Record Temperature ______0C Step 14. PASS the SEMISOLID through an HOMOGENIZER (Type & No) fitted with a [0.0 mm] screen into an ultra clean holding bin. Step 15. CHECK pH [25] C of a sample of the homogenized SEMISOLID). Record pH Result: _________ [Units] DETERMINE the viscosity using (Type & No) Brookfield Viscometer; Spindle No [3] RPM [5] Temperature [25] C Record First result: __________ [Cp] Cp Limits: [4000 to 6000] Step 16. If necessary, continue to Homogenize the bulk material (recirculate) under the same conditions as STEP 14, until the viscosity is close to the midpoint of the given range limits and check viscosity again. Record Second result: __________ [Cp] Step 17. PUMP the semisolid into (Type & No) [000] liter container. Pumping Stop Time: _________ Step 18. WEIGH the bulk material ______Kg. Step 19. Immediately ADD the batch number to the scale print-out, and attach to the manufacturing instructions, date and sign the print-out.
APPROVED
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Page 4 of 4 pages
YIELD CALCULATION
Step 20. Theoretical Weight [00.0] Kg. Yield ___________ % (Yield Limits: NLT 95% of Theoretical Weight.) No of Bins ______ Step 21. COLLECT 10 samples, each equivalent to the approximate weight of 10 g in labeled sample containers. Collect samples from upper, middle and lower part of the container. Send the samples to the QC laboratory for Content Uniformity Testing. Step 22. WEIGH the final material Actual weight: [00.0] Kg. Theoretical Weight [00.0] Kg. Yield __________ % No. of containers _____ . (Yield Limits: NLT 98% of total actual weight
Machine
Sign A+B
Date
PART FIVE - FILLING PROCEDURE

Step 23. IDENTIFY and verify the cleanliness of the filling equipment in use. FILL the material according to the written specifications into air blown tubes WITHIN 24 hours after manufacture. CAUTION: (Do not leave standing over weekends/holidays.) Check filling weight every 15 minutes. Check end-crimp every 30 minutes. Check Lot No and Expiration Date over stamping at start and end of run. Check Lot No and Expiration Date after reset or replacing type. Air Blowing machine: (Type & No). Filling machine: (Type & No). Machine Speed _______ Tubes per minute. Limit of output NLT _______ units; NMT _______ units. Step 24. COUNT the total units produced: Actual production count: [00.0] Units. Weight of Samples taken: [00.0] Units. Vacuum and rejects number: [00.0] Units. Total Units [00.0] Units Theoretical Weight [00.0] Kg. Yield _________ % (Yield Limits: NMT 3% unexplained loss compared to the final bulk weight from STEP 20.
Edition Number: 01 Ed. Status: New Effective Date DD/MM/YY
APPROVED
Sect:11. 14
Topical SEMISOLID
ANDA DEVELOPMENT
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SECTION 11

FLOW CHART
Chart One
Water Phase Heating
Purified Water USP Water Soluble Excipients Nitrogen blanket Solvent NF Antioxidant NF Active USP MIXER
Water USP Purified Water Lipophyllic Emulgent
88 -92 C
Water Phase Cooling 600-620C
1st RINSE
2nd RINSE 3rd RINSE (microgram Actives )
Nitrogen blanket
OIL PHASE MIXER (S/S
Mixing vessel)
Inlet temp. up to 62C (target 60C)
Oily Solvent Lipophobic Emulgent Emulsifier (Ross mixer)
IPQC Testing pH Viscosity Content Uniformity Microbial limits
Viscosity Agent
(Specify Type) 0 at controlled temp - T C
Cool to 280C
DE-AERATOR Homogeneous Semisolid
Target Temp. 500-520C
Ultra-clean FILLING
HOLDING TANK Under Nitrogen Fill tubes according to specifications
YIELDS Overall Production Yields 24 Volume V Drug Development Series

Sect:11. 15 Topical SEMISOLID
ANDA DEVELOPMENT
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SECTION 11

ATTACHMENTS: THE FOLLOWING ATTACHMENTS ARE PLACED HERE:
Process
Attachment # 1 Attachment # 2 In-process Attachment # 3 Attachment # 4 Final Bulk pH Print-Outs of Bulk. Viscosity Print-Out of Bulk material. Weight Print-Outs of the raw material / solvents. Temperature Print-Outs of manufacturing process stage .
Mixing Process.
Attachment # 5 Attachment # 6 Mixing time Print-Out(s) of the Final Bulk. Weight Print-Out of the Final Bulk.
Weight Control
Filling Process.
Attachment # 7 In-process weight Print-Outs of the filled material
NOTE: Where automatic print-outs are not available, Statistical Data Work Sheets are filled out, during the filling process. Suitable Semisolid Filling machines are highlighted below. Filling process: [ALL-FILL \ KING]
Sect:11. 16
Topical SEMISOLID
ANDA DEVELOPMENT
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SECTION 11

IN-PROCESS CONTROL SPECIFICATION BULK MATERIAL
SUMMARY
Product: [Generic name] SEMISOLID [USP] [000.0] mg / g Lot No: 000 Quantity 000000 Yields Bulk Yield Total Final Yield MNF Date: Month DD, 1998 / 9
Limit: NLT 98.0% Limit: NLT 98.0% (based on actual quantities processed). NLT 95.0%
Overall Production Yield
Target Fill Weight Limits 5.0%
____________ g. NLT 00.000g - NMT 00.000g
Target Cap Torque (jars) Cap Torque Check (jars)
____________ Kg ____________ Kg
Recorded on Statistical Data Work Sheets.
Sect:11. 17
Topical SEMISOLID
ANDA DEVELOPMENT
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IN-PROCESS CONTROL SPECIFICATIONS
SUMMARY
PRODUCT: [GENERIC NAME] SEMISOLID [000.0] mg. Labeled Amount: EACH gram contains [000.0] mg [Active Material] In-process Specifications
Description Opaque uniform homogeneous Semisolid with a [type] color and [type] odor.
Active Fill Weight (5.0%) pH (1.0 / 0.5 unit) Viscosity

Brookfield, Spindle #[ 0] After [ 0] rpm
Target 000 Target 0.0 Target 0000
Limit: 000 - 000 mL Limit: 0.0 - 0.0 Limit: 0000 - 0000 cp.
In-Process Semisolid Content Uniformity Particle Size (microns) Yields Actual Bulk Weight Calculated Filling Yield Actual Filling Yield Overall Filling Yield
Limit: 94.0 - 106.0% of labeled amount RSD 6.0% (as per attached specifications) Median 000 Limit: 000 - 000
Limit: NLT 98.0% (based on actual quantities processed) Limit: NLT 100.0% (based on bulk weight/ target fill weight). NMT 2.0% unexplained loss from the previous final blend step NLT 95.0%
Note: Exact Decimal points have been set for each specification
Sect:11. 18
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ANDA DEVELOPMENT
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IN-PROCESS CONTROL SPECIFICATION
SUMMARY
Product: [Generic name] SEMISOLID [USP] [000.0] mg / g Quantity 000000 Weight Controls Target Fill weight 000.0 (g) Weight of 10 Containers #1 (g) Weight of 10 Containers #2 (g) Weight of 10 Containers #3 (g) Weight of 10 Containers #4 (g) Weight of 10 Containers #5 (g) Weight of 10 Containers #6 (g) Weight of 10 Containers #7 (g) Weight of 10 Containers #8 (g) In-Process Yields Yield after filling vs. bulk material Yield after filling to theoretical Semisolid Yield 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 MNF Date: Lowest Lot No: 000 Mean Highest Month DD, 1998 / 9
00.0 % 00.0 % NMT 2.0% unexplained loss from the previous step
Recorded on Statistical Data Semisolid Filling Work Sheets.
Sect:11. 19
Topical SEMISOLID
ANDA DEVELOPMENT
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RELEASE SPECIFICATION FOR SEMISOLID [USP]
SUMMARY
Product: [Generic name] Semisolid [000.0] mg / g Labeled Amount: Each gram contains [000.0] mg [Active Material]
Description [Opaque] uniform homogeneous Semisolid with a [type] color and [type] odor. The Infra Red Absorption Spectrum conforms to the Reference Standard The Chromatogram of the sample solution exhibits a peak with the same retention time as the standard solution.
Identification A: Identification B:
Fill Volume (5.0%)

pH (0.5 / 1.0 unit) Viscosity
Target 000
Target 0.0 Target 0000
Limit: 000 - 000 mL

Limit: 0.0 - 0.0 Limit: 0000 - 0000 cp.
Uniformity of Dosage Units: Content Uniformity Total Microbial Count Total Aerobic Count
Objectionable Organisms
Conforms to the current USP NMT 100 NMT 100 CFU / g CFU / g
Absent: S aureus; E coli; P aerugenosa; Salmonella species; Indicator orgs
Impurities /Degradation Products determination - Each Individual: - Any other Individual: - Total: Assay (Preservative)
(Where Appropriate)
NMT 0.5% of the labeled amount NMT 0.5% of the labeled amount NMT 2.0% of the labeled amount
Limit: 50.0 - 105.0% of labeled amount [00.0] - [000.0] mg / g Limit: 90.0 - 110.0% of labeled amount [00.0] - [000.0] mg / g
Assay (Active)
Sect:11. 20
Topical SEMISOLID
ANDA DEVELOPMENT
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SECTION 11

OUTLINE of IN-HOUSE ANALYTICAL SOP

Content Uniformity
The requirements for content Uniformity are met if the amount of the active ingredient in each of the 10 samples, as determined from the Content Uniformity Analytical Method, lies within the range of 90.0 - 110.0% of the labeled amount and the Relative Standard Deviation is less than or equal to 6.0%. If 1 sample is outside the range of 90.0 - 110.0% of labeled amount and no sample is outside the range of 80.0 - 120.0% of labeled amount, or if the Relative Standard Deviation is greater than 6.0%, or if both conditions prevail, test 20 additional samples. The requirements are met if not more than 1 sample of the 30 is outside the range of 90.0 110.0% of labeled amount and no sample is outside the range of 80.0 - 120.0% of labeled amount, the Relative Standard Deviation of the 30 samples does not exceed 7.8%.
Preservative Efficacy
Preservative Efficacy Testing (USP) is omitted as a routine QC test when fully qualified with justification during the formulation development, process qualification AND pivotal batch lot testing. Preservative Efficacy Test USP are evaluated on stability testing at time of manufacture, 12; 24; and 36 months for PQ, Pivotal and validation batches only.
Preservative Efficacy / Preservative Assay

Preservative Efficacy Testing (USP) and Assay is omitted as a routine QC test when fully qualified with justification during the formulation development, process qualification AND pivotal batch lot testing. Preservative Efficacy / Preservative Assay are evaluated on stability testing at time of manufacture, 12; 24; and 36 months for PQ, Pivotal and validation batches only.
Regulatory Requirements - Preservative Assay

In cases of regulatory requests or insistence Preservative Assays are performed on every 5th production batch or at least once per year where only one batch is made.
Sect:11. 21
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ANDA DEVELOPMENT
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COMPARISON OF EXECUTED (PIVOTAL) AND PRODUCTION FORMULAE Product: [Generic name] q [Semisolid] [000.0] mg per g. Lot: S-000
INGREDIENT
Amount per [0] mL (mg)
Executed Batch 0000 (Kg)
Production Batch 0000 (Kg)
Miconazole USP Micronized Pegoxol 7 Stearate [Tefose 63] Heavy Mineral OIL NF Benzoic Acid USP Butylated Hydroxyanizole Peglico 5 Oleate Edetate Disodium USP Purified Water USP
Total
00.00 00.00 00.00 00.00 00.00 00.00 00.00 00.00 00.00 00.00 000.000
00.00 00.00 00.00 00.00 00.00 00.00 00.00 00.00 00.00 00.00 000.000
00.00 00.00 00.00 00.00 00.00 00.00 00.00 00.00 00.00 00.00 000.000
Adjust where applicable (i.e. if moisture content of active is greater than 0.5-1.0%):
Sect:11. 22
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COMPARISON OF EQUIPMENT AND MANUFACTURING CONDITIONS BETWEEN EXECUTED AND PRODUCTION BATCHES
Product: [Generic name] q [Semisolid] [000.0] mg per g. Lot: S-000
Equipment and Manufacturing Conditions
Executed Batch 000 Kg
Production Batch 000 Kg
PROCESSING KETTLE MIXER I MIXER II KING AIR MACHINE JD / BB ZANASSI FILLING MACHINE LA-60 ALL FILL FILLING MACHINE SMR / 14 KING CAPPER C80 YAMATO CHECK WEIGHER Equipment Variation Manufacturing Area Staff SOP
Production Production Production Production Production Production Production Production NONE Production Production Production
Production Production Production Production Production Production Production Production NONE Production Production Production
Sect:11. 23
Topical SEMISOLID
ANDA DEVELOPMENT
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PACKAGING OPERATION DESCRIPTION
Product: [Generic name] q [Semisolid] [000.0] mg per g. Lot: S-000 Stage One. PACKAGING COMPONENTS: 1. Bulk Product 2. HDPE / Aluminum / Glass Containers 3. Package Outsert (Product Leaflets) 4. Container Label 5. Master Cartons 6. Carton Shipping Labels Stage Two PACKAGING PROCEDURE: HDPE Containers & Bulk Feed
Tube/Jar Cleaning Process (Air and Vacuum) Count & Fill
Capping (Tube/Jar)
Jar Closure Torque Test
Container Label
and Outsert Attachment
Packed in Master Shipping Cartons
Sect:11. 24
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ANDA DEVELOPMENT
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PACKAGING OPERATION - EQUIPMENT LISTING: Product: [Generic name] q [Semisolid] [000.0] mg per g. Lot: S-000
Machine Operation Manufacturer Supplier
1
Type
Serial #
Output CONTAINERS per min2 50 Low 100 High
Schenck
HDPE Bottle or Amber Glass Feeding
Schenck Process GMBH Darmstadt
1000-S AccuRate
No: 543123
King
Air Cleaning
C.E. King Ltd, UK SuperKleen
MK2994 L-333 FILLER(1) L-334
50 Low 100 High

Count
50 50* 100 100*
Cream Filling
ALLFILL KING
Capper
Capping
KING CAPPER
CAP 80
22322234
50 Low 100 High 50 Low 100 High 50 Low 100 High
Torque
Torque
H.G.Kalish Inc., Canada Groninger & Co KarlsHeim, Germany DFVK 3000
22349987 5664
6.
Groninger
Outserter
7.
Prestek
Labelling & Printing
Prestek Ltd Science Park Nottingham UK
SmartDate Intelligent Thermal Transfer Printer
53342
50 Low 100 High
(1)
Average figures for containers per minute output for Slow and High Speed. All indicated machine outputs are adjusted to the Filling rate.
(2)
Sect:11. 25
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BATCH RECORDS FOR EXECUTED BATCH
TYPE OF SEMISOLID Lot No Enclosed are the batch records of the executed batch labeling). (master, packaging and
Note: Translation Policy - (Foreign Manufacturing Plants): All documents provided are authenticated photocopies of the executed batch document. The documents are written in (local language) with parts of the data and information presented in English. Where information is provided in the (local language), a verified English translation is provided together with the original document in the local language. Where, only English is used in a document, the original copy document is provided. Executed batch of [Generic Name] SEMISOLID was manufactured on production equipment under actual production conditions.
ACTIVE MATERIAL The active material is manufactured by [BPC] Pharmaceutical and Chemical Manufacturing Company - [Address].
Sect:11. 26
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REPROCESSING STATEMENT
(Delete statement where appropriate)
The COMPANY is unable to anticipate what manufacturing qualifying factors, if any, may lead to the need for reprocessing at this time. If reprocessing of a batch is required once the product has been marketed, the reprocessing procedure as well as the relevant supporting data will be submitted, (according to the SUPAC guideline, where appropriate), for supplementary review and approval of the Office of Generic Drugs prior to implementation.
[Name of Responsible Person] Plant Manager
--------------------------------------Date
[Signature of Responsible Person] -----------------------------------------------[Name of Responsible Person] Director Quality Assurance Unit
---------------------------------------Date
[Name of Responsible Person] Director Pharmaceutical Research & Development Pharmaceutical Division
----------------------------------Date
Sect:11. 27
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REPROCESSING STATEMENT
(Delete statement where appropriate)
The following manufacturing stages have been reworked during the full size process Qualification batch (essentially similar to the pivotal batch shown) and the finished product specifications were evaluated. At time of manufacture (Time zero): No detectable change was recorded for the following test studies pH Viscosity Content Uniformity At 3 months stability station (40o C / 75% RH): The above parameters showed no detectable changes. The full re-work study is presented in the Product Development Report and a Summary outline is given in Section XXI. Conclusion: It is concluded that an additional 20 minute mixing (last stage) may be repeated once as shown, without affecting or impacting on the products physical parameters as shown in the in-process, release or stability (check) specifications.
[Signature of Responsible Person] -----------------------------------------------[Name of Responsible Person] Plant Manager -------------------------------------Date

[Signature of Responsible Person] -----------------------------------------------[Name of Responsible Person] Director Quality Assurance Unit
------------------------------------Date
Sect:11. 28
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12
Pivotal Manufacturing and Controls
TABLE OF CONTENTS.
(as stated in FDA Feb. 1999 Guidance for Industry).
12.1 Copy of the executed Pivotal batch manufacturing record with - equipment used - batch reconciliation 12.2 Copy of the executed Pivotal batch packaging record with - equipment used - label reconciliation
IN-PROCESS CONTROLS
12.3.1 Sampling plans and testing procedures 12.3.2 Specifications and data
FDA's ANDA Guideline Requirements:(as Published January 1999)
Section XII.. In-Process Information

1. Copy of executed batch record with equipment specified (including packaging records, and batch reconciliation) 2. In-process controls
Delete specific data or delete whole sections which are not applicable to this Section 12 of the ANDA The use of bold and square brackets e.g. [00] where actual names or figures are inserted.
Sect:12. 1
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XI
SECTION 12

Outlines of Standard Operating Procedure for In-Process Controls In-Process Control tabulation chart (Summary) Executed Manufacturing Procedure Flow Chart Executed Batch documents Batch Records Packaging Records and labeling reconciliation Summary of FILL WEIGHT Verification Summary of CONTENT UNIFORMITY Verification Packaging and Disbursement Summary
Sect:12. 2
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

OUTLINE OF STANDARD OPERATING PROCEDURES FOR:
IN-PROCESS CONTROLS
1. At all stages of processing, appropriate control procedures are employed in conformity with current good manufacturing practice. 2. Appropriate in-process controls include material testing by quality control and quality assurance personnel. These test are: Content uniformity of final blend. Physical specifications of the SEMISOLID bulk. Fill weight verification.
3. In-process material testing is performed by Qualified Personnel. 4. The Quality Assurance Department reviews the batch test results and evaluates the acceptance or rejection of each batch lot.
Sect:12. 3
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

IN-PROCESS CONTROLS DURING SEMISOLID FILLING
In-process testing is conducted independently by both production and quality control trained personnel. The tests specified in the underlying tables are performed in accord with the in-process product specifications. When, a test is not required, according to the written specifications, it will not be performed. Production personnel test the physical specifications of random samples
according to the individual product specifications: A minimum sampling frequency is tabulated for each eight hour (shift) period.
Production In-process Testing Schedule:

Test PERFORMED Sample Size Frequency per shift (1) (min)
At start.
Bulk Description
Within specifications. NMT 2 Containers from of the 20 tested may deviate from product spec. No deviation permitted from Double Limits(3) specification. No deviation from product specifications is permitted.
Fill Weight (Active)
10
At 30 min. intervals. At 30 min. intervals.

KEY:
Cap Torque (Jars)
The testing frequency is performed twice when the overall filling time is less than four hours.
Sect:12. 4
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12
uality Control personnel test the physical specifications of samples taken at random according to the individual product specifications sheets: A minimum sampling frequency is tabulated for each eight hour (shift) period.
Quality Control
In-process Testing Schedule:
TEST PERFORMED
Material Description Individual Fill Weight
Sample Size
1 (1) 20 (1)
Frequency per shift (1) (min.)

Once at start 60 min
ACCEPTANCE CRITERIA (2)

No deviation from product specification is allowed. NMT 2 Containers from of the 20 tested may deviate from product spec. No deviation permitted from Double Limits(3) specification. No deviation from product specification is allowed
CAP TORQUE (Jars)
6 (1)
60 min
KEY:
1
Samples are taken, independently by QC personnel for batch release purposes, at least once per hour throughout the FILL run, producing a total representative sample quantity of 20 - 40 Containers. This representative sampling is for the QC Unit batch release purposes
2
Deviations from specifications and acceptance criteria, that arise during the inprocess controls, determine the corrective action undertaken on the filling machinery during the line filling stage.
3
Double Limits for the Individual Fill Weight tests are defined as the double value from the minimum or maximum limit in relation to the nominal fill value (i.e. target fill weight value).
Sect:12. 5
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

OUTLINE OF STANDARD OPERATING PROCEDURES FOR: SAMPLING PLAN OF PIVOTAL LOTS FOR STABILITY AND BIOAVAILABILITY STUDIES.
tandard Operating Procedures are in place at the commercial manufacturing facility, that define the overall packaging procedures for the pivotal lot(s) and the representative sampling of the various pack sizes for the purpose of quality control, stability testing and bioavailability studies. These procedures are summarized below. The entire pivotal lot (i.e. 100%) is packaged in the commercial production packaging department, using routine production equipment, and operated by the standard production personnel. The smallest and largest pack size of each pack type is packaged, not less than 15 -20% of the pivotal batch is packed into each pack type. The number of each type of pack size sampled is calculated in order obtain approximately equal numbers of each presentation size. A sampling plan for each type of package, is determined on the basis of the total number of packages and the number of packages required for control, stability and topical bioavailability studies. The sampling plan is representative of the entire pivotal batch.
Sect:12. 6
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

EXECUTED PIVOTAL BATCH MANUFACTURING INSTRUCTIONS
Product name: Batch Number: Department: Precautions: Caution: Cat./Formula No: Based on PQ:
[Generic name] SEMISOLID [USP] [000.0] mg. 000 ______________ Batch Size: 150 Kg Sub-lot No: 1 2 3 Manufacture Date: Month DD, YY # F0000 SEMISOLID Batch # PQ000 PIVOTAL BATCH Validation Lot Commercial Lot
Original - No Change : Change
Change Control for this document:

Change made: - none
KEY: Precautions:
Wear Mask and Gloves Wear disposable overalls Use air stream face visor with AIR filter Use Mask, Gloves and Safety glasses Avoid exposure to light / Protect form light Store in well closed containers Potential danger to pregnant women Pregnant women prohibited in this area Do not heat above 00C
Room humidity below 30%
Caution:
Sect:12. 7
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

EXECUTED PIVOTAL BATCH MASTER FORMULA
Mg Per gram
% Exc ess
Weighing Date :
Page 1 of 1 pages
per [150] kg
Kg g
000 780 300 7 087 000 500 225 440 500
665
Sign weigh. Dept.
mg
mL
180.00 25.20 2.00 0.05 207.252
27 3
500 500

[Miconazole USP Micronized Peglico 5 Oleate [LABRAFIL M 1944] Edetate Disodium USP Heavy Mineral OIL (1st Rinsing) Heavy Mineral OIL (2nd Rinsing) Theoretical End Weight.
31 3 4
20.00 30.00 1.50 9.60 10.00
1 1
10

721.650 721.650
108 108
247 247
500 500

1000.0 1000.0

150 150
000 000
APPROVED
Sect:12. 8
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

EXECUTED PIVOTAL BATCH MASTER FORMULA
Batch No: Weighing Date:
Page 1 of 4 pages
Step 1. IDENTIFY the equipment and verify the cleanliness prior to use.
Machine
Sign A+B
Date
PART ONE - OIL PHASE

Step 2. LOAD into kettle No [ ] fitted with [Mixer # [ ]-Type & No) the ingredients in the following order: Pegoxol 7 Stearate [Tefose 63] Heavy Mineral OIL NF Benzoic Acid USP Butylated Hydroxyanizole and mix for [20] minutes at mixer setting speed II Step 3. HEAT while mixing to NMT [45] C (Target: [42] C). Time of adding [ ] min. Total Mixing Time [ ] min.
PART TWO Active OILY PHASE

Step 4. LOAD into a [Small Mixer-Type & No) the ingredients in the following order: Miconazole USP - Micronized Peglico 5 Oleate - [LABRAFIL M 1944] Edetate Disodium USP Mix for [20] minutes at mixer speed [II] until mix is fully micronized material is suspended and homogeneous. Step 5. HEAT while mixing to NMT [45] C (Target: [42] C). Target Temperature [ ] C START of mixing [ ] END of mixing [ ] Total Mixing Time [ ] min
APPROVED
_____________ Department __________ R &D _______________ RA _______/________ QC / QA
Sect:12. 9
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

Page 2 of 4 pages
PART THREE AQUEOUS PHASE
Step 6. Heating the Water Phase (i) WEIGH or MEASURE 000.0 Kg [PURIFIED WATER USP] into a stainless steel mixing kettle fitted with a high speed variable mixer. (#0) (ii) Operate the mixer while HEATING to NMT [95] C (Target: [95] C). (iii) Hold the heated Water at the target temperature for NLT60 minutes Target Temperature Time of Heating Total Process Time [ ] C). [ ] [ ] min
Machine
Sign A+B
Date
Step 7. Cooling the Water Phase COVER and Cool Step 6 [PURIFIED WATER USP] to a target temperature while slowly stirring - Target Temperature 280C [20C] Target Temperature Start of Cooling Time End of Cooling Time Total of Cooling Time NMT [ [ [ [ ] C ] ] ] min
PART FOUR - ADDITION OF OILY PHASE

Step 8. Add the Active Oily Phase STEP 4 to the Bulk Oil Phase STEP 2 and mix at speed [III] until homogeneous. RINSE active material twice with heavy mineral oil. Drain container fully after each RINSE procedure. Start of Mixing [ ] End of Mixing [ ] Total of Mixing Time [ ] min Step 9. Check that the oil phase after the mixing period is a homogeneously dispersed oily suspension - if necessary mix for an additional 20 minutes Start of Mixing [ ] End of Mixing [ ] Additional Mixing Time [ ] min
APPROVED
Sect:12. 10
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

Page 3 of 4 pages
ADDITION OF AQUEOUS PHASE
Step 10. RECORD the Aqueous and Oil Phase temperatures. Temperature of AQUEOUS Phase NMT [30] C (Target: 280C [20C]) Temperature of OIL Phase NMT [30] C (Target: 280C [20C]) Step 11. ADD the aqueous phase to STEP 8 while continuously mixing at mixer speed III. Start of Mixing [ ] End of Mixing [ ] Total Mixing Time [ ] min Step 12. ATTACH the mixing kettle temperature graphs (Type & No) to the manufacturing instructions. Add the batch number to the temperature graph and Immediately date and sign it..
Machine
Sign A+B
Date
COOLING OF COMBINED PHASES

Step 13. COOL Step 11 to a target temperature while slowly stirring [Set I]. Target Temperature 250C [20C] Record Temperature ______0C Step 14. PASS the SEMISOLID through an HOMOGENIZER (Type & No) fitted with a [0.0 mm] screen into an ultra clean holding bin. Step 15. CHECK pH [25] C of a sample of the homogenized SEMISOLID). Record pH Result: _________ [Units] DETERMINE the viscosity using (Type & No) Brookfield Viscometer; Spindle No [3] RPM [5] Temperature [25] C Record First result: __________ [Cp] Cp Limits: [4000 to 6000] Step 16. If necessary, continue to Homogenize the bulk material (recirculate) under the same conditions as STEP 14, until the viscosity is close to the midpoint of the given range limits and check viscosity again. Record Second result: __________ [Cp] Step 17. PUMP the semisolid into (Type & No) [000] liter container. Pumping Stop Time: _________ Step 18. WEIGH the bulk material ______Kg. Step 19. Immediately ADD the batch number to the scale print-out, and attach to the manufacturing instructions, date and sign the print-out.
APPROVED
Sect:12. 11
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

Page 4 of 4 pages
YIELD CALCULATION
Step 20. Theoretical Weight [00.0] Kg. Yield ___________ % (Yield Limits: NLT 95% of Theoretical Weight.) No of Bins ______ Step 21. COLLECT 10 samples, each equivalent to the approximate weight of 10 g in labeled sample containers. Collect samples from upper, middle and lower part of the container. Send the samples to the QC laboratory for Content Uniformity Testing. Step 22. WEIGH the final material Actual weight: [00.0] Kg. Theoretical Weight [00.0] Kg. Yield __________ % No. of containers _____ . (Yield Limits: NLT 98% of total actual weight
Machine
Sign A+B
Date
PART FIVE - FILLING PROCEDURE

Step 23. IDENTIFY and verify the cleanliness of the filling equipment in use. FILL the material according to the written specifications into air blown tubes WITHIN 24 hours after manufacture. CAUTION: (Do not leave standing over weekends/holidays.) Check filling weight every 15 minutes. Check end-crimp every 30 minutes. Check Lot No and Expiration Date over stamping at start and end of run. Check Lot No and Expiration Date after reset or replacing type. Air Blowing machine: (Type & No). Filling machine: (Type & No). Machine Speed _______ Tubes per minute. Limit of output NLT _______ units; NMT _______ units. Step 24. COUNT the total units produced: Actual production count: [00.0] Units. Weight of Samples taken: [00.0] Units. Vacuum and rejects number: [00.0] Units. Total Units [00.0] Units Theoretical Weight [00.0] Kg. Yield _________ % (Yield Limits: NMT 3% unexplained loss compared to the final bulk weight from STEP 20.
Edition Number: 01 Ed. Status: New Effective Date DD/MM/YY
APPROVED
Sect:12. 12
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

EXECUTED PIVOTAL BATCH MANUFACTURING INSTRUCTIONS FLOW CHART
Chart One
Water Phase Heating
Purified Water USP Water Soluble Excipients Nitrogen blanket Solvent NF Antioxidant NF Active USP MIXER
Water USP Purified Water Lipophyllic Emulgent
88 -92 C
Water Phase Cooling 0 0 60 -62 C
1st RINSE
2nd RINSE 3rd RINSE (microgram Actives )
Nitrogen blanket
OIL PHASE MIXER (S/S
Mixing vessel)
Inlet temp. up to 62C (target 60C)
Oily Solvent Lipophobic Emulgent Emulsifier (Ross mixer)
IPQC Testing pH Viscosity Content Uniformity Microbial limits
Viscosity Agent
(Specify Type) 0 at controlled temp - T C
Cool to 28 C
DE-AERATOR Homogeneous Semisolid
Target Temp. 0 0 50 -52 C HOLDING TANK Under Nitrogen Fill tubes according to specifications
Ultra-clean FILLING
Sect:12. 13
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

THE FOLLOWING ATTACHMENTS ARE PLACED HERE:
Process
Attachment # 1 Attachment # 2 In-process Attachment # 3 Attachment # 4 Final Bulk pH Print-Outs of Bulk. Viscosity Print-Out of Bulk material. Weight Print-Outs of the raw material / solvents. Temperature Print-Outs of manufacturing process stages .
Mixing Process.
Attachment # 5 Attachment # 6 Mixing time Print-Out(s) of the Final Bulk. Weight Print-Out of the Final Bulk.
Weight Control
Filling Process.
Attachment # 7 In-process weight Print-Outs of the filled material
NOTE: Where automatic print-outs are not available, Statistical Data Work Sheets are filled out, during the filling process. Suitable Semisolid Filling machines are highlighted below. Filling process: [ALL-FILL \ KING]
Sect:12. 14
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

IN-PROCESS CONTROL SPECIFICATION BULK MATERIAL
SUMMARY
PIVOTAL BATCH
Product: [Generic name] SEMISOLID [USP] [000.0] mg/g Quantity 000000 Yields Manufacturing Yield Total Final Bulk Yield MNF Date:
Lot No: 000
Month DD, 1998 / 9
Limit: NLT 98.0% Limit: NLT 98.0% (based on actual quantities processed).
Overall Production Yield
NLT 95.0%
1 2
Target Fill Weight Limits 5.0%
____________ g NLT 00.000g - NMT 00.000g
Target Cap Torque Cap Torque Check Cap Torque Limits
____________ Kg ____________ Kg Min____ Kg Max ____ Kg
Sect:12. 15
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

IN-PROCESS CONTROL SPECIFICATIONS
SUMMARY
PRODUCT: [GENERIC NAME] SEMISOLID [000.0] mg /g. Labeled Amount: EACH gram contains [000.0] mg [Active Material] In-process Specifications
Description [Opaque] uniform homogeneous Semisolid with a [type] color and [type] odor.
pH (1.0 / 0.5 unit) SG Viscosity

Target 0.0 Target 0.000 Target 0000
Limit: 0.0 - 0.0 Limit: 0.000 - 0.000 g/mL Limit: 0000 - 0000 cp.
In-Process Semisolid Content Uniformity (as per attached specifications) Fill Weight (5.0%) Individual Fill Weight (7.5%) Yields Actual Bulk Weight Calculated Filling Yield Actual Filling Yield Overall Filling Yield
Limit: 94.0 - 106.0% of labeled amount RSD 6.0% Target 000 Target 000.0 Limit: 000 - 000 mL Limit: 000.0 - 000.0 g
Limit: NLT 98.0% (based on actual quantities processed) Limit: NLT 100.0% (based on bulk weight / target fill weight). NMT 2.0% unexplained loss from the previous final blend step NLT 95.0%
Note: Exact Decimal points have been set for each specification
Sect:12. 16
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

IN-PROCESS CONTROL SPECIFICATION
SUMMARY
PIVOTAL BATCH
Product: [Generic name] SEMISOLID [USP] [000.0] mg/g. Quantity 000000 Weight Controls Target Fill weight 000.0 (g) Weight of 10 Containers #1 (g) Weight of 10 Containers #2 (g) Weight of 10 Containers #3 (g) Weight of 10 Containers #4 (g) Weight of 10 Containers #5 (g) Weight of 10 Containers #6 (g) Weight of 10 Containers #7 (g) Weight of 10 Containers #8 (g) 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 MNF Date: Lowest
Lot No: 000 Mean 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 Highest 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0 000.0
Month DD, 1998 / 9
In-Process Yields Yield after filling vs. bulk material Yield after filling to theoretical Permissible Loss
00.0 % 00.0 % NMT 2.0% unexplained loss from the previous step
Recorded on Statistical Data Semisolid Filling Work Sheets.
Sect:12. 17
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

RELEASE SPECIFICATION FOR SEMISOLID [USP] SUMMARY
Product: [Generic name] Semisolid [000.0] mg / 5 mL Labeled Amount: Each [00.0] g contains [000.0] mg [Active Material]
Description Identification A: Identification B: [Opaque] uniform homogeneous Semisolid with a [type] color and [type] odor. The Infra Red Absorption Spectrum conforms to the Reference Standard The Chromatogram of the sample solution exhibits a peak with the same retention time as the standard solution.
Fill Weight (5.0%)

pH (o.5/1.0 unit) SG Viscosity
Target 000
Target 0.0 Target 0.000 Target 0000
Limit: 000 - 000 mL

Limit: 0.0 - 0.0 Limit: 0.000 - 0.000 g/mL Limit: 0000 - 0000 cp.
Uniformity of Dosage Units: Content Uniformity Total Microbial Count Total Aerobic Count Objectionable Organisms Impurities /Degradation Products determination - Each Individual: - Any other Individual: - Total: Assay (Preservative)
Conforms to the current USP NMT 100 CFU / mL NMT 100 CFU / mL Absent: S aureus; E coli; P aerugenosa; Salmonella species; Indicator orgs
NMT 0.5% of the labeled amount NMT 0.5% of the labeled amount NMT 2.0% of the labeled amount
Limit: 50.0 - 110.0% of labeled amount [00.0] - [00.0] mg / g Limit: 90.0 - 110.0% of labeled amount [00.0] - [00.0] mg / g
Assay (Active)
Sect:12. 18
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

OUTLINE of IN-HOUSE ANALYTICAL SOP

Content Uniformity
The requirements for content Uniformity are met if the amount of the active ingredient in each of the 10 samples, as determined from the Content Uniformity Analytical Method, lies within the range of 90.0 - 110.0% of the labeled amount and the Relative Standard Deviation is less than or equal to 6.0%. If 1 sample is outside the range of 90.0 - 110.0% of labeled amount and no sample is outside the range of 80.0 - 120.0% of labeled amount, or if the Relative Standard Deviation is greater than 6.0%, or if both conditions prevail, test 20 additional samples. The requirements are met if not more than 1 sample of the 30 is outside the range of 90.0 110.0% of labeled amount and no sample is outside the range of 80.0 - 120.0% of labeled amount, the Relative Standard Deviation of the 30 samples does not exceed 7.8%.
Preservative Efficacy Testing (USP) is omitted as a routine QC test when fully qualified with justification during the formulation development, process qualification AND pivotal batch lot testing. Preservative Efficacy Test USP are evaluated on stability testing at time of manufacture, 12; 24; and 36 months for PQ, Pivotal and validation batches only.
Preservative Efficacy / Preservative Assay

Preservative Efficacy Testing (USP) and Assay is omitted as a routine QC test when fully qualified with justification during the formulation development, process qualification AND pivotal batch lot testing. Preservative Efficacy / Preservative Assay are evaluated on stability testing at time of manufacture, 12; 24; and 36 months for PQ, Pivotal and validation batches only.
Regulatory Requirements - Preservative Assay

In cases of regulatory requests or insistence Preservative Assays are performed on every th 5 production batch or at least once per year where only one batch is made.
Sect:12. 19
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

PACKAGING OPERATION DESCRIPTION Product: [Generic name] SEMISOLID [USP] [000] mg /g - Batch No: 000
Stage One. PACKAGING COMPONENTS: 1. Bulk Product 2. HDPE / Glass Containers 3. Package Outsert (Product Leaflets) 4. Container Label 5. Master Cartons 6. Carton Shipping Labels Stage Two PACKAGING PROCEDURE: HDPE Containers & Bulk Feed
Tube/Jar Cleaning Process (Air and Vacuum) Count & Fill
Capping (Screw Cap - Jars)
Closure Torque Test
Container Label
and Outsert Attachment
Packed in Master Shipping Cartons
Sect:12. 20
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

PACKAGING OPERATION - EQUIPMENT LISTING:
Product: [Generic name] SEMISOLID [USP] [000] mg /g - Batch No: 000

Machine Operation Manufacturer Supplier
1
Type
Serial #
Output CONTAINERS per min2 50 Low 100 High
Schenck
HDPE Bottle or Amber Glass Feeding
Schenck Process GMBH Darmstadt
1000-S AccuRate
No: 543123
King
Air Cleaning
C.E. King Ltd, UK SuperKleen
MK-2994
50 Low 100 High
Cream Filling
ALLFILL KING CAPPER FILLER(1) CAP 80
L-333 L-334
Count
50 50* 100 100*
Capper
Capping
22322234
50 Low 100 High 50 Low 100 High 50 Low 100 High
Torque checker
Torque (Jars) Outserter
H.G.Kalish Inc., Canada Groninger & Co KarlsHeim, Germany DFVK 3000
22349987 5664
6.
Groninger
7.
Prestek
Labelling & Printing
Prestek Ltd Science Park Nottingham UK
SmartDate Intelligent Thermal Transfer Printer
53342
50 Low 100 High
(1)
Average figures for containers per minute output for Slow and High Speed. All indicated machine outputs are adjusted to the Fill rate.
(2)
Sect:12. 21
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

BATCH RECORDS FOR EXECUTED BATCH
SEMISOLID Lot No Enclosed are the batch records of the executed batch labeling). (master, packaging and
Note: Translation Policy - (Foreign Manufacturing Plants): All documents provided are authenticated photocopies of the executed batch document. The documents are written in (local language) with parts of the data and information presented in English. Where information is provided in the (local language), a verified English translation is provided together with the original document in the local language. Where, only English is used in a document, the original copy document is provided. Executed SEMISOLID batch was manufactured on production equipment under actual production conditions. ACTIVE MATERIAL The active material is manufactured by [BPC] Pharmaceutical and Chemical Manufacturing Company - [Address].
Label Reconciliation:
A 100% Label Reconciliation is conducted for each packaging run. All damaged / rejected labels are stuck to a label card and counted & defaced at the end of the run. Reconciliation Summary: Total number of labels _________ issued [a] Total number of labels _________ On product [b] Total number of labels _________ On Samples [c] Total number of labels _________ Damaged [d] Total number of labels _________ Not used [e] Signed by Signed by Signed by Signed by Signed by (Warehouse) (Line Checker) (QA Staff) (Line Checker) (QA Staff)
% Label Reconciliation ________ (Calculation a - [b+c+d+e] ) < 5/1000 (NMT 0.5%) Note: Where the issue of labels are calculated by weight, the issue count error permitted is NMT 0.5 %.
Sect:12. 22
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12
FILL WEIGHT
RANGE VERIFICATION
The following specification were given for the executed (pivotal) batch:
WEIGHT RANGE
TARGET FILL RANGE 0000.0 mg
NLT 0000.0 - NMT 0000.0 mg
During the manufacture of the executed (pivotal) batch, FILL WEIGHT range verification testing was performed. The result demonstrate that FILLING of _____________SEMISOLID on production equipment at production speeds was within the proposed weight range (minimum 000, maximum 000). The uniformity of content was evaluated on at least three samples taken at each speed. Each tube sampled and tested for U of C from the top, middle and crimp positions. The weight range results demonstrate that the range limits have been suitably validated for routine commercial production batch manufacture. NOTE: Fill Weight Range verification is performed on each strength for multi-strength presentations e.g.
Table 1 Table 2 000 mg / g 000 mg / g etc.
Sect:12. 23
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12
FILL WEIGHT
RANGE VERIFICATION
Table 1
SAMPLE
LOW SPEED
Fill Weight
(g)
HIGH SPEED
Fill Weight
(g)
TARGET SPEED
Fill Weight
(g)
NO.
Uniformity of Content (check 3:20)
Uniformity of Content (check 3:20) Lot No 00.000 00.000 00.000 -
Uniformity of Content (check 3:20)
Machine Type 1 2 3 4 5 6 7 8 9 10 11 12 13 14 14 16 17 18 19 20 AVG. RSD % USL LSL 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 -
Machine No: 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000
Date 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000 00.000
Sect:12. 24
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12
PACKAGING TRAIL
PACKAGING AND DISBURSEMENTS Product: [Generic name] SEMISOLID [000]mg /g - Batch No: 000
The disposition and distribution of the [000] mg strength are shown as actual numerical example. The packaging trail should show the packed units used in the pivotal lot for: Quality Control Testing (Physical, Chemical & Microbial) Stability testing
QA Reserve Samples for Annual Evaluation Topical Bioequivalency testing
Topical Bioequivalency Retention Samples.
Bulk Material:
[150] Kg packed in : [Two] bulk containers x 75 Kg Packaging date: M onth DD, 1999
[75 Kg] bulk containers Release Bio & Stability Testing
[75 Kg] bulk containers Release Bio & Stability Testing
M onth DD, 1999
M onth DD, 1999
(US)
(EU)
Sect:12. 25
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION
XII
SECTION 12

Product: [Generic name] SEMISOLID [000]mg /g - Batch No: 000
000g HDPE Container (Jar) with

Screw cap [00 mm]
Nov.28, 1996
5 unit QC Testing & Reserve units
15 units Release & Stability Testing
280 units Balance stored in Pivotal Warehouse
M onth DD, 1999
M onth DD, 1999
000g HDPE CONTAINER (Jar) with

Screw cap [00 mm]
5 unit QC Testing & Reserve units
25 units Release & Stability Testing
168 units Balance stored in Pivotal Warehouse
M onth DD, 1999
M onth DD, 1999
Sect:12. 26
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XII
SECTION 12

PACKAGING AND DISBURSEMENT
Product: [Generic name] SEMISOLID [USP] [000]mg /g - Batch No: 000

Nov.28, 1996
5 units x 60 g QC Testing
BIOSTUDY
80 units 60 g Balance stored in Pivotal Warehouse
M onth DD, 1999
M onth DD, 1999

60 units 60 g Biostudy (European Market)
M onth DD, 1999

Nov.28, 1996
10 units x 30 g QC Testing & Reserve units
200 units x 30 g
BIOSTUDY
Balance stored in Pivotal Warehouse
M onth DD, 1999
M onth DD, 1999
65 units x 30 g Biostudy & Retained Samples
M onth DD, 1999
Topical Biostudy Disbursements (See Semisolid Trail) Section 6
Sect:12. 27
Topical SEMISOLID
ANDA DEVELOPMENT
NOTES
Sect:12. 28
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XIII
SECTION 13
Packaging and Labeling Procedures
TABLE OF CONTENTS
This Section contains information on the container-closure systems, including type

III DMF authorization letters from the component manufacturers, as well as the applicant's component specifications and component test data.
The
container closure system for the drug product are described in detail in the specifications and drawings included in this section. 13.1 13.2 Outlines for Packaging and Labeling Procedures Blank Packaging Forms and Packaging reconciliation .
A relatively standardized ANDA section that emphasizes the intended commercial production packaging procedures and reconciliation controls in force.
The limit for unexplained loss of 20 per 1000 i.e. 2% of the amount received is a common upper limit industry standard. Unexplained material losses of 0.5 - 1% are generally target levels.
NOTE: STANDARD OPERATION PROCEDURES - OUTLINES.
Actual
Standard Operation Procedures should not generally be included in an ANDA submission. For various reasons new editions or amendments to SOPs are continually being development or new SOP procedure are introduced from time to time.
The
period between submission and pre-approval inspection or first commercial production lots may well have resulted in a new SOP in use. FDA's Published January 1999 ANDA Guideline Requirements:
(actual excerpt as published in agency guideline)
Section XIII.
Packaging Materials Controls 1. Summary of packaging system 2. Components specification and test data (Type III DMF references) 3. Packaging configuration and sizes 4. Container/closure testing (include ingress testing in Section XXII, as appropriate for sterile processes only) 5. Vendor qualification specifications 6. Applicants acceptance criteria 7. Retest schedule
4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13

OUTLINE OF STANDARD OPERATING PROCEDURES FOR: PACKAGING AND LABELING PROCEDURES Applicants Acceptance Criteria The Acceptance criteria for new packaging
components are detailed in the firms appropriate SOPs required according to cGMP (21 CFR 211). Actual acceptance activities are cross-checked by the firms QA department prior to manufacturer. A narrative outline of the QA system is given. 1. The packaging work station is inspected prior to the start of work, for work station and equipment cleanliness. The packaging station must be free of all previous leftover work materials and the packaging line must be completely clear. 2. The product and packaging materials are identified according to the Standard Packaging Sheets printed with the required packaging specifications. 3. In-Process Control of the packaging procedure is carried out at the start of packaging procedure, and then at approximately every hour during the packaging process. When packaging machines are temporary stopped, the work station is re-inspected and full In-Process Control checks are carried out prior to restarting the cleared line. 4. At the end of packaging procedure, a material balance and a packaging reconciliation is performed on the packed product and the unused printed packaging materials that contain any overprinting (Lot number ; Expiry Date). (Example of the material balance & packaging reconciliation sheet attached). 5. Any quantity absent during packaging reconciliation is resolved as an unexplained loss. The limit for the unexplained loss may not exceed 2% of the amount received. 6. A Packaging Department supervisor / representative and a QA representative checks and approves that the entire packaging procedure was performed according to required specifications, and signs the Packaging Work Sheet. NOTE: BLANK PACKAGING FORMS Examples of Blank Packaging Forms are not given in this example. The critical checks to proper packaging control forms are; Identify and quantify - all incoming printed packaging material (including primary and secondary packaging materials) Identify and quantify - all incoming containers, closures and containers inserts (including applicators, special nozzles etc.) Perform a material balance check on all Packed Goods and a Packaging Reconciliation on all printed materials and containers.
333
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13

Packaging Material Balance and Reconciliation
Product & Strength: _______________________ Packaging Size ________________ Batch No:
1. PACKAGING SUMMARY
Date Package Material Description Total Packages Received Total Units Packaged Total Units Rejected Total Units Sampled Non packaged Quarantine Units Initial
2. PACKAGING Reconciliation 2.1 TOTAL Units packed 2.2 TOTAL Packs rejected 2.3 TOTAL Packs sampled 100 x [Total no. of units] = _______% Theoretical no. of units Compare to last production stage (2%) Signature _______ Date ________ 2.4 TOTAL PACKS Department Material Balance:
3. TOTAL BATCH RECONCILIATION (OF OVERALL PACKAGING PROCESS) 3.1 3.2 Material Rejected
______________________ units
Samples Taken
______________________ units
[2.1 + 3.1 + 3.2] _x _100 Theoretical no. of units Signature:
(Limits: 95.0% - 103.0%) Date: _______________
_______________________ Quality Assurance Unit
Sect: 13.3
ANDA DEVELOPMENT
ANDA DEVELOPMENT
TABLE OF CONTENTS
(Overall ANDA Guideline Requirements for this Section). Glass Thermoplastic Containers
Solid oral dosage forms.
Vendor qualification Specifications

Appropriate documentation from the packaging component manufacturer as highlighted below is obtained for each component according to in-house SOPs, including but not limited to, DMF reference authorization letters, cGMP compliance certifications, manufacturers specifications and test results. Furthermore samples of all materials with corresponding manufacturers Certificate of Analysis are evaluated for QC and functionality testing as well as any compatibility testing with the intended product.
FROM THE GENERIC FIRM'S QC LAB

1. 2. 3. 4. 5. General description (summary) of Container-closure-liner-seal-cotton system used for each dosage strength Description of Packaging Components of pack sizes used for each strength Testing Specifications or protocol and test results (CoA) of Generic packaging Lab. CoAs of Containers from the QC Packaging Lab. Batch Compliance Statement of applicants acceptance tests
FROM THE CONTAINER MANUFACTURER:6 Container Specifications:-name, product code and manufacturer (including) - drawings / diagrams with annotated dimensions - Tests performed on closure to include USP <661> and <671> n Light transmission and n moisture vapor permeation - Certificate of Conformance meeting all USP XXIII - Complies to 21 CFR requirements / Food Additives Regulations Certificate of Analysis DSC thermal analysis (for thermoplastic containers only) Brief description of manufacturing process (as appropriate) Letters of Authorization - (LoA) i. LoA from manufacturer referencing their facility DMF #. ii. LoA from manufacturer referencing their container DMF #. Note: Glass requires less tests and documentation
7 8
FROM THE RESIN MANUFACTURER:9 10 LoA from resin manufacturer referencing their resin DMF # as used in the manufacture of the container Obtain separate letters for each resin type used in different plastic containers
4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13
Packaging Components Description

TABLE OF CONTENTS
(Overall ANDA Guideline Requirements for this Section). Metal Caps or Thermoplastic Closures Solid oral dosage forms.
FROM THE GENERIC FIRM'S QC LAB:11 12 13 Testing Specifications or protocol and test results (CoA) of Generic packaging Lab CoA of closures from the QC Packaging Lab Batch Compliance Statement of applicants acceptance tests
FROM THE CLOSURE MANUFACTURERS :14 15 16 17 18 19 20 21 Closure Specifications (including) - drawings / diagrams with annotated dimensions - Tests performed on closure system to include USP <661> and <671> n moisture vapor permeation - Certificate of Conformance meeting all USP XXIII - Complies to 21 CFR requirements / Food Additives Regulations - Certificate of Analysis - DSC thermal analysis (for thermoplastic closure only) Letters of Authorization i. LoA from manufacturer referencing their facility DMF #. ii. LoA from closure manufacturer referencing DMF # of cap Statement of GMP compliance of manufacturer
FROM THE RESIN MANUFACTURER:(Not required for metal closures) 22 23 i. LoA from (cap) resin manufacturer referring thermoplastic resin DMF # and Statement of GMP compliance of manufacturer Obtain separate letters for each resin type used in thermoplastic closures
Note:
Child Resistant Closures (CRCs) may consists of two parts made with different HDPP/HDPE resins. Both inner (HDPP) and outer part (HDPE) resins need to be treated separately in the documentation requirements.
4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13
TABLE OF CONTENTS
Inner closure liner

Solid oral dosage forms.
FROM THE GENERIC FIRM'S QC LAB:24 25 26 Testing Specifications or protocol and test results (CoA) of Generic packaging Lab CoA of liner from the QC Packaging Lab Batch Compliance Statement of applicants acceptance tests
FROM THE LINER MANUFACTURER:27 28 29 30 31 Liner Specifications (including); - drawings / diagrams with annotated dimensions - Tests performed on liner - Certificate of Conformance meeting all current USP requirements and complies to 21 CFR requirements - Certificate of Analysis
LETTERS OF AUTHORIZATION:32 33 34 35 i. LoA from manufacturer referencing their facility DMF #. ii. LoA from liner manufacturer referencing DMF # of liner
STATEMENTS OF COMPLIANCE
Statement of GMP compliance of liner manufacturer Statements of Compliance with Applicable Sections of the Indirect Food Additive Regulations (21 CFR).
Note: A change from one type of resin to another type - requires prior approval. A change from one type of resin to the same type - prior approval not required. Changing resins requires an equivalency protocol which demonstrates sameness. For solid dosage forms only, The USP section <661> is in fact an existing compendial interchangeability protocol for equivalent HDPE resins.
4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13
TABLE OF CONTENTS
Foam Seals
Pressure sensitive, tamper resistant, adhesive seals
(data required for each container seal) Solid oral dosage forms.
FROM THE GENERIC FIRM'S QC LAB:36 37 38 Testing Specifications or protocol and test results (CoA) of Generic packaging Lab. CoA of adhesive seal from the QC Packaging Lab. Batch Compliance Statement of applicants acceptance tests
FROM THE ADHESIVE SEAL MANUFACTURERS :39 40 41 42 43 Adhesive seal Specifications (including) - Drawings / diagrams with annotated dimensions - Tests performed on adhesive seal - Complies to 21 CFR requirements - Certificate of Analysis
LETTERS OF AUTHORIZATION - (LOA)

44 45 46 47 LoA from seal manufacturer referencing their facility DMF #. LoA from manufacturer referencing their seal DMF #.
STATEMENTS OF COMPLIANCE
Statement of GMP compliance of seal manufacturer Statements of Compliance with Applicable Sections of the Indirect Food Additive Regulations (21 CFR).
NOTE: Moisture permeability - USP <661>: Max 10mg/day/Liter. Container closing Torque - USP <671>: Should establish a good seal at target torque.
Sect: 13.7
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13

TABLE OF CONTENTS
Nozzles / Applicators
(required for Applicator/Nozzle ) Topical Dosage Forms.
FROM THE GENERIC FIRM:

48 49 50 Testing Specifications or protocol and test results (CoA) of Generic packaging Lab. CoA from the QC Packaging Lab Batch Compliance Statement of applicants acceptance tests
FROM THE APPLICATOR MANUFACTURERS :51 52 53 54 55 Applicator/Nozzle Specifications (including) - Tests performed on Applicator/Nozzle - Compliance to USP requirements - Complies to 21 CFR requirements - Certificate of Analysis (include resin ID)
LETTERS OF AUTHORIZATION - (LOA)

56 57 58 LoA from Applicator/Nozzle manufacturer referencing their facility DMF #. LoA from manufacturer referencing their Applicator/Nozzle DMF #. STATEMENTS OF COMPLIANCE Applicator/Nozzle manufacturer's: Statement of GMP Compliance Statements of Compliance with Applicable Sections of the Indirect Food Additive Regulations (21 CFR).
Sect: 13.8
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13
TABLE OF CONTENTS
(Overall ANDA Guideline Requirements for this Section)
This Section Contains:

Package Characteristics for container-liner-closure systems Package Description concerning container-liner-closure systems Documents for container-liner-closure system include the following:
Certificates of Analysis outlining the components used for packages containing; 00 / 000 cc Flexible Tube 00 / 000 cc HDPE (Bulk) Jar (HDPE nozzle) (HDPE cap with liner).
Technical Specifications (Diagrams &Drawings) of each component. Certificates of Analysis of [Generic Company Name Inc./Ltd.] packages. DMF Referral Letters
Statements of Compliance with applicable sections of the Indirect Food Additive

Regulations (21 CFR).
USP XXIII Testing Results of the closure system.
Sect: 13.9
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13

PACKAGE CHARACTERISTICS
[Generic name] SEMISOLID [USP] [000.0] mg /g. Lot: 000
Pivotal Lot
ITEM
TYPE 1
Drug Plastics & Glass Co. Inc. 00 / 000cc round, HDPE JAR HDPE Quantum LR-734043 U.S. CAN (Penn-Wheeling Closure Corp.) White Ampacet 11078 Polyethylene HDPE LDPE 00 / 00 mm Tekni-Plex Inc. Foamseal PS 22 TEKNISEAL RVT + LF Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000
TYPE 2
Drug Plastics & Glass Co. Inc. 00 / 000cc round, HDPE JAR HDPE Quantum LR-734043 U.S. CAN (Penn-Wheeling Closure Corp.) White Ampacet 11078 Polyethylene HDPE LDPE 00 / 00 mm Tekni-Plex Inc. Foamseal PS 22 TEKNISEAL X-14 (polyethylene/Kraft Paper laminate) Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000
TYPE 3
Drug Plastics & Glass Co. Inc. 00 / 000cc HDPE/
COLLAPSIBLE TUBE
TYPE 4
COLLAPSIBLE TUBE
Container manufacturer Container size Resin Type Cap Manufacturer 11087 PE White Master batch Cap / Nozzle Type Cap Size Closure Liner Foam seal Mfg Inner liner composition
CONTAINER CONTAINER CAP Nozzle / Applicator LINER SEAL
(coated metal)
HDPE Quantum LR-734043 U.S. CAN (Penn-Wheeling Closure Corp.) White Ampacet 11078 Polyethylene HDPE LDPE 00 / 00 mm -
(coated metal)
Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 CoA #00000
CoA = Certificate of Analysis/Compliance
Sect: 13.10
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13

PACKAGING COMPONENT DESCRIPTION FOR THERMOPLASTIC CONTAINERS CONTAINING:
All container and closure systems are certified to comply with the indirect food additive regulations (Parts 170-199) or are otherwise certified safe for use in contact with a drug product - generally accepted as safe (Appear in the 21 CFR GRAS List) 30 and 60 & 1000 Units
HDPE:
Description White, Round HDPE Bottle with 29/33/53 mm/400 Neck Finish Code 000 Size: 30, 50, 750 cc
CODE & Size

Manufacturer Resin used Color Batch DMF (MFG) DMF (Item) LoA
Drug Plastics & Glass Company, Inc., DMF # 1933
QUANTUM
DMF # 885
AMPACET 11078 PE, DMF # 8354 DMF [0000] DMF [0000] Month DD, YYYY
21 CFR Documentation General Tests & Assays
Complies with Food Additives Regulations Part 170 -199 Relevant data copies of the manufacturers current DMF # [0000] (Type II) are attached for ease and simplicity of review. All relevant tests applicable to the container closure system as per table 14-A are performed by either the vendor or applicant and supported in the documentation attached. Where product stability testing is conducted referencing this specific item's code then all above specifications shall apply to the container-closure item.
Stability Testing
4
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13

PACKAGING COMPONENT DESCRIPTION FOR CLOSURES OF CONTAINERS CONTAINING: BULK Units
CLOSURES
Description CODE & Size
Fits Container Size HDPE cap, 38 mm / 400 White, Unlined Polypropylene Cap with Pressure Sensitive Inner Seal Code 000 000 & 000 cc 29/33 mm diameter
Manufacturer Inner Liner Foam Seal

DMF (MFG) DMF (Item) LoA
Owens Brockway None Foamseal PS 22 - Pressure Sensitive, adhesive

DMF [0000] DMF DMF # 2229 Month DD, YYYY
21 CFR Documentation General Tests & Assays
Stability Testing
Sect: 13.12
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13

PACKAGING COMPONENT DESCRIPTION FOR CLOSURES OF CONTAINERS CONTAINING: Bulk Containers
METAL SCREW CAP

Description
38/53 mm 400 White, Tin Plated Metal Screw Cap with Pressure Sensitive Inner Seal Code 000 000 & 000 mL Size: [38/53] mm diameter
CODE & Size

Fits Container Size
Manufacturer:
U.S. CAN [Full address] DMF #4162 DMF #4162

Month DD, YYYY
21 CFR Documentation
General Tests & Assays
Stability Testing
Sect: 13.13
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13

PACKAGING COMPONENT DESCRIPTION FOR CLOSURES OF CONTAINERS CONTAINING: Bulk Containers
INNER CAP LINER

Inner Liner CODE & Size Manufacturer
Tekniseal X-14(Polyethylene)
Code 000 Size: [00] mm diameter
Tekni-Plex Inc. DMF # 1378 DMF # 1378 Month DD, YYYY
21 CFR
Complies with Food Additives Regulations Part 170 -199
CONTAINER FOAM SEAL

Foam Seal Manufacturer Size
DMF (Mfg) DMF (Item) LoA
Foam seal PS 22 - Pressure Sensitive, adhesive

US CAN.
[00] mm diameter
DMF # 1378 DMF # 1378 Month DD, YYYY
21 CFR General Tests & Assays
Complies with Food Additives Regulations Part 170 -199 All relevant tests applicable to the container closure system as per table 14-A are performed by either the vendor or applicant and supported in the documentation attached.
Sect: 13.14
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13

PACKAGING COMPONENT DESCRIPTION FOR CLOSURES OF CONTAINERS CONTAINING:
[Generic name] SEMISOLID [USP] [000.0] mg/g. Lot: 000
Collapsible Tubes
Description Inner Coating Length Size Manufacturer Seal DMF of MNF Product DMF LoA : : : : : : : : :
[000] cc lined collapsible LD Tube with HDPE nozzle Epoxy Coat [0.0] mm thick [00] mm
000 & 000 g

[Name].
Heat sealed or breaking inner seal DMF [0000] DMF [0000] Month DD, YY
Extended Nozzle
Description: Size Fits Sizes Manufacturer: DMF of MNF Product DMF : : : : : :
[000] White, HDPE Nozzle [00] mm (length)
000 & 000 mL [Name] DMF [0000] DMF [0000]
Sect: 13.15
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIII
SECTION 13

U.S. Pharmacopoeia / National Formulary
General Tests and Assays - Table 1
Ref. No 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. <691> <671> <601> <661> USP <No> <1> <87> <88> <161> <381> TITLE Injections In vitro In vivo Transfusion Biological Reactivity Tests Biological Reactivity Tests Transfusion and Infusion Assemblies SUBTITLE General Tests and Assays
Elastomeric closures for injections n n Aerosols Containers n n n n n n n n n Containers n Cotton Light transmission Chemical resistance - Glass Containers Biological Tests - Plastic and others Polymer Physiochemical Test - Plastics Polyethylene Containers Polyethylene Terephthalate / Terephthalate G Bottles Single Unit Containers & Unit Dose (Containers for Non-sterile solid & liquids dosage forms ) Customized Patient Medication Packages Permeation - n Multiple unit containers for capsules and tablets Permeation - n Single unit containers and Unit dose for capsules and tablets Cotton or Purified Rayon Monograph (with exclusions) Ointments Biological Test Procedures Physiochemical Test Procedures
22. 23.
<771> <1151>
Ophthalmic
Pharmaceutical Dosage Forms
Sect: 13.16
ANDA DEVELOPMENT
ANDA DEVELOPMENT
Above - Table 1 contains all USP testing procedures described in the pharmacopoeia that impact on aspects of container closure systems. All components comply with the appropriate tests.
Sect: 13.17
ANDA DEVELOPMENT
ANDA DEVELOPMENT
SECTION XIV
SECTION 14
Finished Dosage Form Controls
TABLE OF CONTENTS
(Overall ANDA Guideline Requirements for this Section). 14.1 Section Page and Title State if drug product is: q Compendial and test methods used are USP XXIII q Non-Compendial and test methods are validated in-house methods. q Non-Compendial and test methods based on published analytical methods and validated.
14.2
Certificate of Analysis of Pivotal Batch(es), including:q HPLC, TLC, GC, UV chromatograms and spectra for all pivotal strengths q CoA for each strength of SEMISOLID [USP] + HPLC chromatograms
Stability Indicating Assay Impurity Limit Tests USP Monograph tests USPC Inc. Pharmacopeial Forum Published Reference Works
Sect: 14.1
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XIV
SECTION 14

THE DRUG PRODUCT IS NON-COMPENDIAL. Certificates of Analysis for the finished drug product [Generic name] SEMISOLID [000.0] mg/g (all strengths). Copies of the test methods and method validations are enclosed in Sections XVI, for Analytical Methods. These methods are used for release and stability purposes, assuring identity, strength, quality and purity of the finished drug product. Note: Additionally, separately bound copies of all non-compendial methods have been provided in accordance with 21 CFR 314.50(e)(2)(i). or THE DRUG PRODUCT IS COMPENDIAL. Certificates of Analysis for the finished drug product [Generic name] SEMISOLID [000.0] mg/g (all strengths). The drug product is compendial. Copies of the stability indicating test methods and method validations are enclosed in Sections XVI, under Analytical Methods. Compendial methods are used for release, assuring identity, strength, quality and purity of the finished drug product on batch release. Stability indicating test methods are used for stability, assuring identity, strength, and purity of the finished drug product during the entire shelf life period of the drug.
Note:
Additionally, separately bound copies of all non-compendial methods have been provided in accordance with 21 CFR 314.50(e)(2)(i).
Sect: 14.2
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XIV
SECTION 14

SUMMARY OF CERTIFICATE OF ANALYSES
AND ANALYTICAL SPECTRA :

Pivotal Batch
C of A No.
C 000-01
Executed Lot Pivotal Lot No: [000-01]
[000.0] mg per g
GC Pivotal Lot No: [000-01] [000.0] mg per g
SPECTRA
C 000-01
UV Pivotal Lot No: [000-01] [000.0] mg per g
SPECTRA
C 000-01
HPLC Pivotal Lot No: [000-01] [000.0] mg per g
SPECTRA
C 000-01
TLC Pivotal Lot No: [000-01]
[000.0] mg per g
C 000-01
(Labeled Photocopies of TLC plates provided)
NOTE: Attach summary and spectra for each of the pivotal lots and strengths manufactured. Above table represents one pivotal lot of each dosage strength.
Sect: 14.3
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XIV
SECTION 14

SUMMARY OF ANALYTICAL METHODS AND METHOD NUMBERS:
Table details the analytical Control Methods used :
Analytical Method
Stability PURPOSES
Not Applicable
QC Release PURPOSES
QC-021-00
Method Validation
SI -V -021-00
Active Ingredient Finished Product Physical TESTS Finished Product Assay / Impurities Finished Product Microbial testing
SI-A22-00
SI-A23-00 SI-D24-00
QC-025-00
SI -V -A23-00 SI -V -D24-00
KEY QC = A Quality Control Method that has been validated and based on the R&D validated method. SI = A Stability Indicating Method that has been fully validated A = An Assay Method V = The full validation procedure and test results of a corresponding stability indicting method (Note: the same method number is used) 00 = The last two zeros (-00) indicated the editions number of the procedure - i.e. edition number three is written as '-03.' Test methods for release and for stability purposes. The R&D analytical methods are used for product stability purposes. The QC. testing methods which are based on the R&D methods are used for the release of the raw material and the drug product. QC Release and Stability testing use the same validated Analytical Method. Thus QC-025-00 is in fact, a combination of SI-A23-00 & SI-A24-00.
Sect: 14.4
Topical SEMISOLID
ANDA DEVELOPMENT
SECTION XV
SECTION 15
Analytical Methods
TABLE OF CONTENTS
Included
in his section are the analytical methods, method validations and test specifications and data for the drug substance [Generic name] and the drug product [Generic name] tablets [000]mg manufactured by the applicant. The methodology includes validated stability indicating analytical assay methods
State if drug substance and drug product is:

- Compendial and test methods used are USP XXIV - Non-Compendial and test methods in-house and validated. - US Non-Compendial test methods based on published reference works and validated (e.g. Ph Eur / BP / Japan Pharm / DAB.) Active material 15.1 Active Ingredient Test Method (QC Release method) 15.2 Active Ingredient Test Method Validation (Stability Check method) In-process Material 15.3 Final Blend Test Methods Finished Product 15.4 Finished Product Test Methods (QC Release method) - physical tests - Chemical tests - microbiological tests - (where required) [If compendial - methods are USP monograph] 15.5 Finished Product Test Methods (Stability Check method) - stability Indicating Test Method - impurity limit Test Method - dissolution Test Method 15.6 Finished Product Analytical Validation methodology. - Validation of Stability Indicating Assay - Validation of impurity limits - Validation of dissolution method. q q q
FDA's Published January 1999 ANDA Guideline Requirements:

Section XV. Analytical Methods (two additional separately bound copies if the drug substance and/or drug product are not USP articles) 1. Methods for drug substance a. Method validation b. Test specifications and data (derived from bioequivalent batch lot) 2. Methods for drug product a. Method validation b. Test specifications and data (derived from bioequivalent batch lot)
Edition Number: 01 Ed. Status : New Effective Date: DD/MM/YY
APPROVED
24 VOLUME DRUG DEVELOPMENT SERIES:
Sect: 15.1
ANDA Development
ANDA DEVELOPMENT
SECTION XV
SECTION 15
Analytical Methods
Non Compendial USP materials.
The active drug substance, [Active Material], and the finished drug product
[Generic name] [USP] [000.0]mg., are both non-compendial in the US Pharmacopoeia. The active material is of compendial status in the BP and Ph. Eur. - US Pharmacopoeia - US Pharmacopoeial Forum - BP Pharmacopoeia - Ph. Eur. Pharmacopoeia - In-house Stability Indicting methods (based on BP Pharmacopoeia)
Drug Product analytical methods and stability indicating methodology are in-house
based on the current BP ; Ph. Eur. or US Pharmacopoeial Forum and have been fully validated in-house. - US Pharmacopoeia - US Pharmacopoeial Forum - BP Pharmacopoeia - Ph. Eur. Pharmacopoeia - In-house Stability Indicting methods (based on BP Pharmacopoeia). This analytical section contains: Active Ingredient Test Methods Final Blend Test Methods Finished Product Test Methods (Release) Finished Product Test Methods (Stability) Note: Additional separately bound copies are provided in accordance with 21 CFR 314.50(e)(2)(i). Assay/Impurities Degradation Products Determination Dissolution Test Test of Appearance (ref. pages [00] to [00]) (ref. pages [00] to [00]) (ref. pages [00] to [00]) (ref. pages [00] to [00]) (ref. pages [00] to [00])
Finished Product Analytical Method Validation
Edition Number: 01 Ed. Status : New
APPROVED
Sect: 15.2
ANDA Development
ANDA DEVELOPMENT
SECTION XV
SECTION 15
Analytical Methods
SUMMARY OF ANALYTICAL METHODS AND METHOD NUMBERS:
Analytical Method
Active Material Stability Indicating Assay Impurity Limit tests Validation of Stability Indicating Assay
Method No.
SI-1000-01 SI-1000-01 SI-1000-01
In-process Material Content Uniformity (on bulk material) Microbial Limit test (on bulk material) SI-2000-01
Finished Product Release QC Release Assay Impurity Limit tests Content Uniformity (on bulk material) Microbial Limit test (on bulk material)
SI-4000-01 SI-4000-01 SI-4000-01 SI-4000-01
Finished Product Stability Methods Stability Indicating Assay Impurity Limit tests Validation of Stability Indicating Assay Microbial Limit test Preservative Efficacy test SI-5000-01 SI-5000-01 SI-5000-01 SI-5000-01 SI-5000-01
(All Analytical Methods Placed Here)

Edition Number: 01 Ed. Status : New Effective Date: DD/MM/YY
APPROVED
Sect: 15.3
ANDA Development
ANDA DEVELOPMENT
SECTION XV
SECTION 15
Analytical Methods
(TYPICAL ANALYTICAL METHOD VALIDATION) 1. PURPOSE The purpose of this Standard Analytical Procedure is to demonstrate the procedure required to validate in-house HPLC analytical methods and to show that the methods are stability-indicating. Methods based on the USP but modified for stability indicating test purposes require full in-house validation. This procedure ensures that the Product Development Process and Process Qualification Batch analysis is based on a foundation of Good Laboratory Practice using validated test procedures. 2. RESPONSIBILITY The Head of Analytical Development in coordination with the managers of QC and Regulatory Affairs at the proposed manufacturing site. 3. FREQUENCY For each non-compendial analytical method intended for ANDA (or OTC ANDA) manufactured products. For Stability-Indicating Assays and limit testing of impurities that may be based on compendial methods. Each Product strength will follow the full method validation procedure. 4. PROCEDURE [a]. Method Validation Non-compendial methods validation will follow the USP direction for parameters needed for the validation of test methods. Typical parameters for validating assays and other non-compendial analytical methods designed for providing quantitative results shall include : Accuracy Recovery Precision ( System reproducibility, Method reproducibility ) Specificity Linearity Range Ruggedness (different analysts / days /different equipment models / columns)
[b]. Placebo Analysis. A mixture of non-actives (placebo) shall be prepared and subjected to analysis. No interfering peaks shall be observed in the graph of the placebo chromatogram.
APPROVED
Sect: 15.4
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[c]. The stability of the Standard solution is assessed by re-injection of the standard solution after 24 x n hours (where n = number of days the Standard will be used). Standard Preparation for Assay Comparison of standard solutions for Assay of Active material, injected after one month and freshly prepared demonstrate that the standard solutions are stable and does not lose its quality after one month if refrigerated. Standard Preparation for Impurity Comparison of standard solutions of Guanine, injected after one month and freshly prepared demonstrate that the standard solutions are stable and does not lose its quality after 1 month if refrigerated. Name of standards Storage conditions Difference. relative to freshly prepared standard <2% <2%
[Active] 100% [Impurity] 100%
4C 4C
Standard Solutions are stored at controlled temperatures and light conditions as per labeling. [d]. Stability Indicating Procedures. For the Stability Indicating Method, the product sample shall include forced degradation by stressed analysis. Conditions of concentration and reaction time may vary depending on the active drug substance and drug product e.g. : Oxidation Base Hydrolysis Acid Hydrolysis Sun light Heat (H2O2 plus standing time). (NaOH x N plus standing time). (HCl conc. plus standing time). (24 hours standing time). (x degrees C).
Summary of Stability Indicating Results

Stressed Conditions Temp.
(C)
Time
(hr)
Raw Material;
Remaining Substance. (%) 100.2 101.3 101.1 99.8 77.5 79.7 Peak Purity, (Figure) pure pure pure pure pure pure
Tablets
Remaining Substance
(%) 98 92 84.8 100.2 90.5 78.6
Peak Purity, (Figure) pure pure pure pure pure pure
Solution heating Solid heating Sunlight 765 w/m

2
90 160 40 70 37 Room
12 2 14 10 3 20
3,3N Sodium Hydroxide 10%Hydrogen Peroxide 5% Hydrochloric Acid
APPROVED
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[e]Specificity and Suitability (Resolution and Tailing Factors). When a satisfactory separations of all the degradation peaks have been achieved through the forced degradation reactions, a Resolution Factor (according to the USP requirements) between the main active peak and the nearest degradant peak is calculated using the USP formula. A Tailing Factor (according to the USP formula) is calculated for the main active peak. [f] System Suitability Test A mixture of [Active] AS. standard at the concentration about [0.1]mg/mL and of [Impurity] AS. standard at the concentration about [0.01]mg/mL according to Method SI-1000 was prepared and injected into the HPLC system. For chromatogram obtained the following values were calculated (according to USP): 1. Relative Retention Time for [Impurity] peak RRT = RT [Impurity] RT [Active] 2. Tailing factor for [Active] peak
Tf = W0.05 9 = = 1.1 2f 4.2 =
2.65 = 0.31 8.45
The values depict the specificity of the method for resolution between the main peak and impurity peak. (values shown for demonstrations purposes).
Peak Purity
The photo diode-array is used for the evaluation of the stability indicating nature of the assay method number SI-1000 for [000]mg and [000]mg tablets using a Waters 996 Unit, controlled by the chromatography manager Millennium 2010. Peak purity and match results are reported as: Purity Angle is a measure of spectral non-homogeneity across a peak - i.e. the weighed average of all Spectral Contrast Angles calculated by comparing all spectra in the integrated peak against the peak apex spectrum. Purity Threshold is the sum of Noise Angle and Solvent Angle. It is the limit of detection of shape differences between two spectra. Match Angle is a comparison of the spectrum at the peak apex against a library spectrum. Match Threshold is the sum of the Match Noise Angle and Match Solvent Angle. Noise Angle is a measure of spectral non-homogeneity caused by system noise.
APPROVED
Sect: 15.6
ANDA Development
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Peak Purity
(Cont.)
Solvent Angle is a measure of spectral non-homogeneity caused by solvent composition. It the purity angle is smaller than the purity threshold and the match angle is smaller than the match threshold, this indicates that no significant differences between spectra are detected. There is no spectroscopic evidence for co-elution and the peak is considered pure.
[f] Relative Retention Time of Main and Additional peaks.

Each stressed analysis shall indicate the percentage by which the Main peak is decreased as well as the RRT for any other Additional peaks. If the RRT of an Additional peak corresponds to a known degradant/impurity etc. it shall be stated. The peak purity of the main peak shall be given for each stressed analysis (where possible).
[g]. * * *
Validation of limit testing for impurity methods shall include : Specificity Detection Limit (DL) Quantitation Limit (QL)
Detection Limit (DL) The detection limit of an individual analytical procedure is the lowest amount of analyte in a sample which can be detested but not necessary quantitated as an exact value. Quantitation Limit (QL) The Quantitation limit of an individual analytical procedure is the lowest amount of analyte in a sample which can be quantitatively determined with suitable precision and accuracy. Used in the determination of impurities and or degradation products. [h]. Contents of a typical HPLC Analytical Validation Protocol refer Method No. A-0340-01-1299
APPROVED
Sect: 15.7
ANDA Development
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Validation of HPLC Analytical Method

Method No: A-0340-01-1299
[1] Introduction - A brief description is given of the following parameters :
* * * * Method and Edition # used Batch # of samples tested (test the lowest and the highest label strength) Type of detector used to analyze stressed samples Stress testing of Standard solution to determine origin of Additional peaks.
[2] System Reproducibility - Precision

Ten replicate (single) injections of the standard solution at the nominal concentration described in the method is performed and the RSD calculated. The Results (sample # and peak areas) are tabulated. The Average Peak Area, SD and RSD are shown in the table. Target values for RSD = 0.5 to 1.0 (Keep this standard solution for the stability of Standard Solutions - Point 9)
SYSTEM REPRODUCIBILITY
SAMPLE No. PEAK AREAS
1. 2. 3. 4. 5. 6. 7. 8. 9. 10.
Average Peak Area Standard Deviation Relative Standard Deviation
= = =
0.5 - 1.0
APPROVED
Sect: 15.8
ANDA Development
ANDA DEVELOPMENT
[3] Method Reproducibility - Precision

The full analytical method # is carried out and repeated Ten times on the finished product (batch #) and the RSD is calculated. Two HPLC injections are performed per method assay and the peak areas are averaged. The Results (assay %) are tabulated. The Average Assay %, SD and RSD are calculated and shown in the tabulations. Target values for RSD = 1.5 to 3.0.
METHOD REPRODUCIBILITY
SAMPLE No
Batch No: 1 2 3 4 5 6 7 8 9 10
ASSAY %
Average Assay % Standard Deviation Relative Standard Deviation.
= = = 1.5 - 3.0
[4] Accuracy
The Accuracy of an analytical procedure expresses the closeness of agreement between the true value and the value found. Ten replicate (single) injections of the standard solution at the nominal concentration of x mg/100 mL as described in the Analytical Method / Ed # [00] is made and the percent deviation from the true values as determined from the linear regression line is calculated. The Results (Peak areas and % accuracy) are tabulated. The Mean, SD and C.of.V are shown in the tabulations
APPROVED
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[4] Accuracy (continued).
ACCURACY
INJECTION No PEAK AREA CALCULATED CONC. % ACCURACY
1 2 3 4 5 6 7 8 9 10
Mean (% Accuracy) = Standard Deviation = % Coef. of Variation =
[5] Recovery
(Extraction time)
The extraction efficiency is demonstrated by varying the extraction time of prepared sample solutions as described in the analytical method #. Two HPLC injections are performed per method assay and the peak areas are averaged. The extraction time suitable to ensure complete extraction is highlighted. Not less than three different extraction times are used namely 0.5 T, T and 1.5 T (where T is the extraction time of the method).
APPROVED
Sect: 15.10
ANDA Development
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[5] Recovery
(Extraction time - tabulations continued).
The Results (Extraction time and Assay %) are tabulated as shown.
RECOVERY - EXTRACTION
TIME IN MINUTES Batch No: % ASSAY
0.5 T T 1.5 T
[6] Recovery (spiked placebo samples).

Five spiked admixtures of the active substance and the non-active vehicle (placebo) at concentrations of about 50 % to 150 % of the stated concentration required by the assay procedure is prepared and analyzed to show the percentage active recovery. Two HPLC injections are performed per method assay and the peak areas are averaged. The Results (Theoretical conc. Actual conc. and % recovery ) are tabulated. The Average Recovery, SD and the % Coefficient of Variation are given.
APPROVED
Sect: 15.11
ANDA Development
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[6] Recovery (spiked placebo samples tables - continued).
The
recovery results are shown graphically (peak area Vs conc. (mg/100 mL). These results also show extraction method and detector linearity.
RECOVERY
Standard solution mg/100mL Peak Area =
CONC. Theoretical (mg/100ml) PEAK AREA FOUND CONC. FOUND (mg/100ml) PERCENTAGE RECOVERY
50 75 100 125 150
Mean (% Recovery) = Standard Deviation = % Coef of Variation =
The Linear Regression value, Slope and Y-Intercept are shown in the GRAPH. The placebo chromatogram (vehicle only) is shown to highlight the absence of Additional Peaks
[7] Linearity and range.
The linearity on an analytical procedure is its ability (within a given range) to obtain
test results which are directly proportional to the concentration (amount) of the analyte in the test sample.
Five Standard solutions in a concentration range of (about) 50 % to 150 % of the

stated concentration required by the assay procedure are prepared and analyzed by the stated method. Two HPLC injections are performed per method assay and the peak areas are averaged.
APPROVED
Sect: 15.12
ANDA Development
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[7] Linearity and range - (continued).
The Area count and concentration range is plotted. Linear regression analysis will
demonstrate the acceptability of the method for quantitative analysis over the full spectrum of the concentration range. Detector linearity is demonstrated. The Results (Range conc. and peak areas ) are tabulated.
LINEARITY AND R A N G E
CONC. Batch No: PEAK AREAS
50 % 75 % 100 % 125 % 150 %
Linear Regression Y-Intercept Slope
= = =
The results are shown graphically (peak area Vs range conc. (mg/100 mL). GRAPH OF LINEARITY
120000 P e 100000 a 80000 k 60000 A 40000 r e 20000 a 0 0 25 50 75 100 125 150 Conc. mg/100mL
APPROVED
Sect: 15.13
ANDA Development
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[8] RUGGEDNESS & Robustness.

Ruggedness measures the lack of external influence on the test results whereas robustness measures the lack of internal influences on the test results. The Robustness of an analytical procedure is a measure of its capacity to remain unaffected by small but deliberate variations in method parameters and thus providing an indication of its reliability normal usage. The method may be evaluated for specificity using two different columns. No differences in specificity, selectivity or column performance should be observed.
Robustness
Robustness determinations are essential when transferring analytical methods from the development laboratory to the commercial plant quality control laboratory. There may usually be a difference in columns or HPLC machine models used. Deliberate variations according to the following table were made to the critical parameters of the method such as column, flow rate and concentration of [organic acid] in the mobile phase. Using the System Suitability solution and LOQ solution as the Test Solutions the performance of the method was evaluated. Column 1: Phenomenex Bondclone 10, C-18, 300 x 3.9mm (OOH-2117-CD) Column 2: Waters -Bondapak 10, C-18, 300 x 3.9mm (27324) CONDITION
Condition Column No. 1 2 3 4 5 1 1 1 1 2 Flow Rate mL/min 2.5 2.2 2.8 2.5 2.5 Buffer Conc. (%) 0.1 0.1 0.1 0.15 0.1 RRT
RESULTS
Tf RSD RSD bet. LOQ of bet. LOQ of [Active] [Impurity] <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
0.3 0.3 0.3 0.3 0.3
1.1 1.1 1.1 1.1 1.1
Notes on different terms frequently used: INTERMEDIATE PRECISION The analytical variation expressed between laboratories on different days; with different equipment; or different analysts is known as - intermediate precision. REPRODUCIBILITY (INTRA-LAB) This intra-laboratory precision or the precision between laboratories is known as reproducibility or more specifically - intra-laboratory reproducibility. Both the above are ruggedness - and a USP requirement.
APPROVED
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[8] RUGGEDNESS & Robustness - (Tabulations - continued).

The Results (Average assay % for Analyst 1 and 2 ) are tabulated.
RUGGEDNESS
ANALYST No 1 1 2 3 4 5 6 7 8 9 10 % ASSAY Column I ANALYST No 2 % ASSAY Column 2
Mean (% Accuracy) = Standard Deviation = % Coef of Variation =
Robustness. The evaluation of robustness should be finalized at the end of the development phase - around the time of the process qualification lot manufacture. The robustness evaluation should be developed with the commercial laboratory equipment in mind. It should show the reliability of an analysis with respect to deliberate variations in the method parameters A consequence of robustness evaluation is that a series of system suitability parameters are established to ensure that the validity of the analytical procedure is maintained whenever used.
Robustness is defined by both the USP and the ICH Tripartite guidelines as "a measure of its capacity to remain unaffected by small but deliberate variations in method parameters and provides an indication of its reliability during normal use " Robustness is defined both in the USP and ICH, but is not required.
APPROVED
Sect: 15.15
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[9] Stability of Standard solutions

Re-chromatography of ten replicate single injections of the same standard solution (which have been allowed to stand for x hours ) against freshly prepared Standards showed no significant differences from the original results.
STABILITY OF STANDARD SOLUTIONS mg/100mL Initial Analysis (Date)

1 injection 2 injection 3 injection 4 injection 5 injection 6 injection 7 injection 8 injection 9 injection 10 injection Mean Standard Deviation Relative Standard Dev.
mg/100mL Repeat Analysis 2nd (Date)

1 injection 2 injection 3 injection 4 injection 5 injection 6 injection 7 injection 8 injection 9 injection 10 injection = = = NMT 2.0 %
[10] Typical Chromatograms. Representative chromatograms of the following traces are routinely provided:-
System Suitability Standard Solution Drug Product placebo
APPROVED
Sect: 15.16
ANDA Development
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Typical Chromatograms
When Representative Chromatograms are displayed - all peaks are LABELED with the peak name and RRT.
Representative chromatogram Drug Product
Label the peak clearly Name and Retention time (8.78 min)
[11] Conclusion.
(Closing Statement) An appropriate conclusion should be given stating clearly that:

The method # IAG00-005 Ed. No [00] is shown to be accurate and precise for carrying out assay analysis as part of the Assay and Stability Studies for the Drug Product conforming to the formula as shown in Appendix 1
[12] References and Appendixes.
Acknowledgment
to references as well as attachments such as the drug product formula are attached at the end of the validation protocol.
It is important to emphasize that analytical
validation applies to a drug formula and a set manufacturing procedure. Extraneous peaks and processing stresses are specific to a manufacturing procedure, equipment used and the nature of the excipients.
References:
1. "Validation of compendial methods" USP 23 <1225> USPC Rockville Maryland USA 1994. 2. USP/NF XXIII USPC Rockville Maryland USA 1994. 3. Scale up and Post approval Changes Manufacturing and Controls In vitro Dissolution and In Vivo Bioequivalence Documentation CEDER 1995 (SUPAC) 4. International Conference on Harmonization "Guidelines on validation of Analytical Procedures: Definitions and Terminology; Federal Register (March 1, 1995.) 5. ASTM Standard Guide For Conducting Ruggedness Tests E1169 American Society for testing Materials Philadelphia 1989. 6. G. Kateman and L. Buydens, The Ruggedness Test Quality Control in the Analytical chemistry John Wiley and Sons NY 2nd Edition 1993, pp118 125.
APPROVED
Sect: 15.17
ANDA Development
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NOTES
APPROVED
Sect: 15.18
ANDA Development
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SECTION XVI
SECTION 16
TABLE OF CONTENTS
16.1 16.2 16.3 16.4 Section Page and Title. Stability Protocol for Post Approval Production Batches (ANDA commitment) Expiration Dating Period Statement Package Configuration and sizes (largest and smallest) used in stability studies. Stability Protocol used for Pivotal lot Stability Reports indicating results of Pivotal lot from 3 months accelerated and controlled room temperature studies Stability Data Summary Report (plus 0 and 12 week graphs).
16.5 16.6
16.7

Section XVI - Section 16. Stability of Finished Dosage Form 1. Protocol 2. Post-approval commitments 3. Expiration dating period 4. Stability data submitted 5. Stability-indicating test data of samples under various stress conditions
Sect: 16.1
ANDA Development
ANDA DEVELOPMENT
SECTION XVI
SECTION 16

This stability section contains:
Stability protocol for post-approval production batches Proposed expiration date and stability commitment - a signed commitment to conduct long term stability studies as described in our stability protocol (ref. page [00 - 00]) Summary of Stability summary - that addresses the details of our stability program for the finished project. This protocol includes container-closure system, storage conditions, methods and specifications , report format , batch size, dates of analysis and room temperature intervals. (ref. page [00 - 00]) Stability reports containing data from 3 month accelerated and 6 months controlled room temperature studies. (ref. page [00 - 00]) Package Characteristic of pivotal batch. (ref. page [00 - 00])
OVERVIEW
Stability testing is performed on the largest and smallest container-closure systems

proposed for marketing; i.e. in each material type, namely plastic (HDPE/HDPP), glass, or push-through blister packs. When more than one closure for the same container material type (e.g. glass bottle) is used in the proposed marketing containers, the largest and smallest containerclosure configuration is tested, - for both accelerated and long term studies. In cases where plastic bottles of the same size range and shape are manufactured from different thermoplastic resins, they exhibition different storage characteristics and thus are considered as completely separate container-closure systems. The expiration dating process starts between 21 to 30 days from the completion of the manufacturing of the pivotal batch and release by quality control. This 21 to 30 day period is in keeping with the 1987 informal guidance document which stipulates that stability testing should initiate at the time of release which should not itself exceed 30 days from the date of manufacture.
The example below for the following packaging configuration highlights the number of stability tests needed. Tests may be reduced using a matrix stability protocol.
1. 2. 3. HDPP (smallest) container with plastic HDPE cap / nozzle HDPP (smallest) container with plastic HDPE cap / nozzle HDPP (largest) container with plastic HDPE cap / nozzle
When tested on ONE strength with 4 container-closure configuration at accelerated

and long term testing (2) will produce 8 separate stability protocols Calculation. (4 container/sizes x [1 Strength] x 1 closures x [25C+40C] = 8 studies).
4
Sect: 16.2
ANDA Development
ANDA DEVELOPMENT
SECTION XVI
SECTION 16

Proposed Expiration Date and Stability Commitment
ll stability data support the proposed expiration period of 24 months when the product is stored at room temperatures. This conditional dating will be verified by 24 month room temperature studies which will be filed annual as the data becomes available, as per our commitment.
Stability commitment
Long
term commercial stability studied in accordance with the approved stability protocol shall be carried out by [Generic Company Name Inc./Ltd.] The stability results of these studies shall be submitted in the routine annual ANDA Reports filed on the anniversary date of the submitted product or as specified by the FDA. Extensions to the expiration date will be made via the annual ANDA Reports as acceptable long term stability data becomes available. The extension will be files in the annual reports in accordance with 21 CFR 314.70 (d)(5) data will be submitted in the annual reports in accordance with 21 CFR 314.70 (d)(6) or in a prior approval supplement in accordance with 21 CFR 314.70 (b)(2), whichever is appropriate at the time of submission. procedures may be submitted for batches that fail to meet established specifications. Prior to implementation, these procedures will be submitted in a supplement in accord with: 21 CFR 314.70 (b)(2)(x) on a lot by lot basis. [Generic Company Name Inc./Ltd.] commits to remove any batch promptly from the market place any material falling outside the products check specifications. BATCH ANALYSIS COMMITMENT Where future batch analysis of 3 consecutive finished product lots indicate that the specifications limits of the impurities/degradation products present in future commercial production need to be tightened then the stability specifications in the finished product stability protocols will be amended appropriately. The stability data of future batches will comply with the new specifications where appropriate..
Stability
Rework
Sect: 16.3
ANDA Development
ANDA DEVELOPMENT
SECTION XVI
SECTION 16

Stability Protocol for Post-approval Production Batches
[Generic name] SEMISOLID [USP] [000.0] mg per g. [Batch No: 00] FINISHED PRODUCT STABILITY PROTOCOL Package sizes: Smallest and largest containers Storage Conditions: Controlled Room Temperature: 25-30C. Test Intervals: 0,3,6,9,12,18,24 and 36 months. Samples: First three marketable production batches and annual batch thereafter. Storage Conditions Accelerated Temperature: 40C / 75%RH. Test Intervals: 1, 2, 3 months. Samples: To be submitted as appropriate in supplements to the approved application Stability Testing. Test parameters will include:
TEST PROCEDURE 1 2 3 4 Appearance pH Assay (Preservative) [Only where necessary] Assay Active material TEST METHOD & ED. NUMBER SI-5-000-01 SI-5-000-01 SI-5-000-01 SI-5-000-01 SPECIFICATION Conforms NLT 0.0 NMT 0.0 50.0 - 105.0% of labeled amount To (annually) and End of Study 90.0 - 110.0% of labeled amount
IMPURITIES / DEGRADATION PRODUCTS 5 - Each Individual - Any other Individual - Total: Microbial Limit Test SI-5-000-01 SI-5-000-01 SI-5-000-01 SI-5-000-01 NMT 0.5% of the labeled amount NMT 0.5% of the labeled amount NMT 2.0% of the labeled amount Meets USP Specifications o T (annually) and End of Study Meets USP Specifications o T (annually) and End of Study
SI-5-000-01
Report Format Results will be tabulated in the format of the Stability Report Form:
1) Product Name, and Strength 2) Batch Number and Batch size 3) Storage Conditions and Intervals 4) Container/Closure Systems - Description 5) Inventory Control Number of (4) 6) Fill Size and No of units on stability 7) Batch Manufacturing Date 8) Batch Packaging Date 9) 10) 11) 12) 13) 14) 15) 16) Stability Start Date Manufacturing Site Manufacturer of Bulk Drug Inventory Control Number of (11) Manufacturer of Container/Closure Formulation Data profile Methodology and Specifications
Sect: 16.4
ANDA Development
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SECTION XVI
SECTION 16

SUMMARY OF STABILITY STUDIES
Stability Data Overview The 3 months accelerated (40 2C / 75 RH 5% ) and 6 months room temperature
(25 2C / 60 RH 5%) stability data in all container-closure systems were examined for Lots #[000] and Lots #[000] of [Generic Drug name] [USP] [00.0] mg. Labeled chromatograms for the end 12 week period are included. (ref. page [00 00]) The data indicate that the formulation is stable, with no observed degradation peaks, under test conditions. Samples were stored for testing in their proposed market container/closure systems. The stability results indicate that the formulation is stable, with no observed degradation, under the tested conditions. No significant change in either chemical or physical attributes was noted in any sample under any of the storage conditions. This stability data supports the proposed expiry period of the product of 2 years at room temperature as there was no significant changes in either the physical chemical, or microbiological specifications in any samples evaluated after the exposed storage test conditions. The attached tables and graphs are summaries of the results for the parameters used to establish the stability profile of [Generic Drug name] [USP] [00.0] mg. (ref. page [00 - 00]) The attached tables and graphs are summaries of the results for the parameters used to establish the stability profile of [Generic Drug name] [USP] [00.0] mg. Included, are assay chromatogram spectra of the stability tests for zero time (T0) and the three (3) months accelerated test conditions. [Generic Drug name] [USP] [00.0]mg were stored at accelerated conditions (40 2C / 75% RH 5%) and at room temperature (25 2C/ 60% RH 5%) in the proposed market container/closure system. Where PRODUCTS fail the accelerated testing, Intermediate testing is performed according to the following specification. Intermediate testing 0,1,2,3,6,9 and 302C/605%RH 12 months This stability data supports the proposed expiry period of the product of 2 years at room temperature as there was no significant changes in either the physical chemical, or microbiological specifications in any samples evaluated after the exposed storage test conditions. Thus stability data generated support the proposed expiration period of 2 years when the product is stored at the defined room temperatures.
4
Sect: 16.5
ANDA Development
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SECTION XVI
SECTION 16

SUMMARY OF STABILITY STUDY RESULTS.
HDPE Container Closure liner system Container Size (cc) 000 mL 000 mL HDPE Tube with (HDPP Cap) HDPE Container with (HDPP Cap)
25C 60%RH Smallest Largest 40C 75%RH Smallest Largest
Glass Container Closure liner system

Bulk Packaging

2 1 4 1 1 1 8
Number of Temperature/RH Levels Number of Dosage Strengths Number of Container Closure Sizes Number of Resins present in Containers Number of Closures Number of Resins present in Closures Number of Stability Studies Performed
Number of resins used in the HDPE containers = one resin from same supplier.
Sect: 16.6
ANDA Development
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SECTION XVI
SECTION 16

STABILITY REPORT
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Product name, dosage form and strength. Fill size Site of Manufacture Batch or lot number Batch size (type) Batch manufacturing Date and Packaging Date Manufacturer of Active Material (approved supplier) Date placed on stability Batch number or receiving number of Active Material Full details of container/closure system (type, material, resin) [Generic name] [000.0] mg./g 00 cc SEMISOLID [USP] NJ MNF SITE 002 000 Kg Month DD, YY / Month DD YY LEK Chemical Co. dd Month DD, YY LK 2323 80cc HDPE (LR-7340-43) HDPP white cap (resin LR-7340-43) Goods Receiving number of container-liner GRN 96-2-02234 (body) Goods Receiving number of closure GRN 96-2-02237 (cap) Manufacturer of container/closure Wheeler Cap Co PA USA. Objective of the stability program Pivotal Batch Site where stability test conducted US PA MAN Site Number of units to be sent for testing in each time interval 2 x 80cc Analytical method number and Edition Number for each stability indicating testS-I 555-03 / S-I 1234 Ed . 03 Stability specifications indicating names of test required. Tabulated Number of packages placed on stability 70 Testing intervals required 0, 1, 2, 3 months
20 Stability storage conditions
40 degrees C / 75% RH
Contents Appearance ASSAY Percentage Preservative Efficacy Microbial Limits Test pH
Stability Parameters
Storage Period
Date of Analysis
SPECIFICATIONS
Months
Description COLOR S-I 552 -02
90.0 % 110.0% S-I 555 -03
Microbial Limits Test
Method #
0 1 2 3
6/6/97 5/7/97 7/8/97 6/9/97
conforms conforms conforms conforms
100.8 101.4 100.3 100.9
Meets Specification Meets Specification
Conforms Conforms Conforms Conforms
Conforms Conforms Conforms Conforms
21. Product Formula On Stability (Formula No: S000).

1. 2. 3. 4. 5. 6. 7. 8. Miconazole USP Micronized Pegoxol 7 Stearate [Tefose 63] Heavy Mineral OIL NF Benzoic Acid USP Butylated Hydroxyanizole Peglico 5 Oleate [LABRAFIL M 1944] Edetate Disodium USP Purified Water USP
Sect: 16.7
ANDA Development
ANDA DEVELOPMENT
SECTION XVI
SECTION 16

STABILITY REPORT
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Product name, dosage form and strength. Fill size Site of Manufacture Batch or lot number Batch size (type) Batch manufacturing Date and Packaging Date Manufacturer of Active Material (approved supplier) Date placed on stability Batch number or receiving number of Active Material Full details of container/closure system (type, material, resin) [Generic name] [000.0] mg/g. 00 cc SEMISOLID [USP] NJ MNF SITE P-5432 000 Kg May 22, 1996 / May 28, 1996 LEK Chemical Co. dd June 15, 1996 LK 2323 80cc HDPE (LR-7340-43) HDPP white cap (resin LR-7340-43) Goods Receiving number of container-liner GRN 96-2-02234 (body) Goods Receiving number of closure GRN 96-2-02237 (cap) Manufacturer of container/closure Wheeler Cap Co PA USA. Objective of the stability program Pivotal Batch Site where stability test conducted US PA MNF Site Number of units to be sent for testing in each time interval 2 x 80cc Analytical method number and Edition Number for each stability indicating testS-I 555-03 / S-I 1234 Ed . 03 Stability specifications indicating names of test required. Tabulated Number of packages placed on stability 70 Testing intervals required 0; 3; 6; 12; 18; 24; 36; months
20 Stability storage conditions
25 degrees C / 60% RH
Contents Appearance ASSAY Percentage
Stability Parameters
Storage Period
Date of Analysis
SPECIFICATIONS
Months
Description COLOR S-I 000-02
90.0 % 110.0% S-I 000 -03
Preservative Efficacy Test S-I 000 -03
Microbial Limits
pH
Method #
S-I 000 -03
S-I 000 -03
0 3 6 9 12 18 24 36
4/6/97 5/9/97 6/12/97 15/3/98 5/6/98 5/9/98 7/3/99 6/3/00
conforms conforms conforms conforms conforms conforms conforms
101.3 99.9 101.3 101.2 100.6 102.2 100.4
Meets Specification Meets Specification Meets Specification
Conforms Conforms Conforms
Conforms Conforms Conforms Conforms Conforms Conforms Conforms
21. Product Formula On Stability (Formula No: S000).

1. 2. 3. 4. 5. 6. 7. 8. Miconazole USP Micronized Pegoxol 7 Stearate [Tefose 63] Heavy Mineral OIL NF Benzoic Acid USP Butylated Hydroxyanizole Peglico 5 Oleate [LABRAFIL M 1944] Edetate Disodium USP Purified Water USP
Sect: 16.8
ANDA Development
ANDA DEVELOPMENT
SECTION XVI
SECTION 16

PACKAGE CHARACTERISTICS
[Generic name] SEMISOLID [USP] [000.0] mg per g. [Batch No: 00]
Pivotal Lot Packaging Material Characteristics

ITEM
TYPE 1
Drug Plastics & Glass Co. Inc. 00 / 000cc round, HDPE JAR HDPE Quantum LR-734043 U.S. CAN (Penn-Wheeling Closure Corp.) White Ampacet 11078 Polyethylene HDPE LDPE 00 / 00 mm Tekni-Plex Inc. Foamseal PS 22 TEKNISEAL RVT + LF Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000
TYPE 2
Drug Plastics & Glass Co. Inc. 00 / 000cc round, HDPE JAR HDPE Quantum LR-734043 U.S. CAN (Penn-Wheeling Closure Corp.) White Ampacet 11078 Polyethylene HDPE LDPE 00 / 00 mm Tekni-Plex Inc. Foamseal PS 22 TEKNISEAL X-14 (polyethylene/Kraft Paper laminate) Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000 CoA #0000 Lot #00000
TYPE 3
COLLAPSIBLE TUBE
TYPE 4
COLLAPSIBLE TUBE
Container manufacturer Container size Resin Type Cap Manufacturer 11087 PE White Master batch Cap / Nozzle Type Cap Size Closure Liner Foam seal Mfg Inner liner composition
CONTAINER CONTAINER CAP Nozzle / Applicator LINER SEAL
(coated metal)
(coated metal)
CoA = Certificate of Analysis/Compliance
Sect: 16.9
ANDA Development
ANDA DEVELOPMENT
NOTES
Sect: 16.10
ANDA Development
ANDA DEVELOPMENT
SECTION XVII
SECTION 17
Reserved
TABLE OF CONTENTS
17.1
RESERVED
This section is reserved:

ELECTRONIC FORMATTED ANDAs
Proposed use is anticipated for electronic formatted ANDAs
Sect: 17.1
ANDA Development
ANDA DEVELOPMENT
SECTION XVII
SECTION 17
RESERVED
THIS SECTION HAS BEEN RESERVED FOR FUTURE USE.
ELECTRONIC FORMATTED ANDAs

Proposed use is anticipated for electronic formatted ANDAs
Sect: 17.2
ANDA Development
ANDA DEVELOPMENT
SECTION XVIII
SECTION 18
Samples of Drug/Article Components
TABLE OF CONTENTS
18.1 18.2 18.3 18.4 18.5
Section Page and Title Statement on Sample Submission Procedures to FDA on request Drug substance Finished drug product Reference Standards with appropriate identification, graphs and spectra

Section XVIII.
Samples ( 3l4.94(a)(l0)). 1. Drug substance 2. Finished dosage form Sample availability and identification of:
4
Sect: 18.1
ANDA Development
ANDA DEVELOPMENT
SECTION XVIII
SECTION 18
Samples of Drug/Article Components
SAMPLES OF THE
DRUG AND ARTICLES

USED AS COMPONENTS
21 CFR Section 314.50 (e) (1).
[Generic Company Name Inc./Ltd.] shall submit samples of the drug substance or the finished drug product or otherwise make such samples FDA, in accordance with their instructions and requirements pertaining to 21 CFR Section: 314.50 (e) (1). Furthermore the [Generic Company Name Inc./Ltd.] shall submit appropriate REFERENCE STANDARDS with appropriate identification, graphs and spectra as required.

__________________________
___________________
Date
Director Quality Assurance Unit Pharmaceutical Manufacturing Division [Generic Company Name Inc. Ltd.]
Sect: 18.2
ANDA Development
ANDA DEVELOPMENT
SECTION XIX
SECTION 19
Environmental Impact Analysis Reports
TABLE OF CONTENTS
20.1 20.2
Section Page and Title Environmental Exclusion Assessment - Development Site - Manufacturing Site
20.3
Applicable Environmental Laws (National / State / Local /Foreign) - Development Site - Manufacturing Site - Contract Manufacturers
20.4
Site Environmental Certification - Development Site - Manufacturing Site - Contract Manufacturers
20.5
Statement on Environmental Compliance - Development Site - Manufacturing Site - Contract Manufacturers
20.6
Commercial Plant Manager and QA Director Signatures.
FDA's Published January 1999 ANDA Guideline requirements:1. 2. Environmental Consideration: Environmental Assessment (EA) or Claim of Categorical Exclusion ( 3l4.94(a)(9))
Sect: 19.1
ANDA Development
ANDA DEVELOPMENT
SECTION XIX
SECTION 19

Requests for Categorical Exclusion Environmental Regulations Compliance Certification Environmental Regulations Compliance Certification (Foreign Firms)
Site Environmental Certification (USA)
OVERVIEW
This section is used for clarifying the various ENVIRONMENTAL PROTECTION REQUIREMENTS that apply to the development and the manufacturing environment. Note:Where the development and/or the manufacturing of the drug product is performed in a foreign country, the applicable National Environmental laws of the country need to be closely observed. Statements of Environmental Compliance with respect to:-
1. 2. 3.
Toxic waste Waste disposal Environmental Compliance Laws
need to be addressed with appropriate signed certification by senior responsible personnel. The FDA needs to see that there was no infringement of the local countries Environment and Waste Management laws in BOTH the development and manufacture of the drug product or the drug's Active Ingredient.
Sect: 19.2
ANDA Development
ANDA DEVELOPMENT
SECTION XIX
SECTION 19

REQUEST FOR CATEGORICAL EXCLUSION FROM REQUIREMENTS OF AN
ENVIRONMENTAL ASSESSMENT,
21 CFR 25.31(a).
[Generic Company Name Inc./Ltd.] hereby requests a categorical exclusion [in
accord with 21 CFR 25.23(c) and 21 CFR 25.24(c)(1)] from the requirement of an Environmental Assessment Statement [21 CFR 25.31(a)]. This request is based on two facts: 1. The finished drug product which is the subject of the Abbreviated New Drug Application will not be administered at higher dosage levels, for longer duration, or for different indications than previously in effect for the listed drug product (RLD) as stated more fully in section IV of this application. 2. Data available to the Agency does not establish that, at the expected level of exposure, the substance may be toxic to organisms in the environment.
On the basis of the forgoing statements [Generic Company Name Inc./Ltd.] submits that an Environmental Impact Analysis Statement is not required with this application and, therefore requests that it be categorically excluded from the requirements to submit an Environmental Impact Analysis.
___________________________________
[Name of Responsible Person] Director Pharmaceutical Research & Development Pharmaceutical Division
_________________
Date
Sect: 19.3
ANDA Development
ANDA DEVELOPMENT
SECTION XIX
SECTION 19
STATEMENT OF ENVIRONMENTAL COMPLIANCE

The undersigned hereby certifies that [Generic Company Name Inc./Ltd.] operates its [Address] manufacturing facility in compliance with all local and national environmental laws and with the emission requirements set forth in all permits. The undersigned further certifies that the approval and subsequent increase in production at the facility is not expected to affect compliance with current emission requirements or compliance with environmental laws.
__________________________
___________________
Date
Plant Manager Pharmaceutical Manufacturing Division [Generic Company Name Inc. Ltd.]
__________________________
___________________
Date
Sect: 19.4
ANDA Development
ANDA DEVELOPMENT
SECTION XIX
SECTION 19
STATEMENT OF ENVIRONMENTAL COMPLIANCE
FOREIGN SITE
Development and manufacturing The undersigned hereby certifies that [Generic Company Name Inc./Ltd.] operates a certified waste disposal program its [Address] manufacturing facility which is in full compliance with all Local, State and National environmental laws and with the emission requirements set forth in all required permits. The undersigned further certifies that the approval and subsequent increase in production at the facility is not expected to affect compliance with current emission requirements or compliance with environmental laws. [Signature of Responsible Person]
__________________________
___________________
Date

__________________________
___________________
Date
Director Quality Assurance Unit Pharmaceutical Manufacturing Division [Generic Company Name Inc. Ltd. ]
Sect: 19.5
ANDA Development
ANDA DEVELOPMENT
SECTION XIX
SECTION 19
Site Environmental Certification

The undersigned hereby certifies that [Generic Company Name Inc. / Ltd.]. maintains compliance with all appropriate Federal, Sate and Local environmental laws and regulations in the distribution of [Generic name] Tablets [USP] [000.0] mg.

__________________________
___________________
Date

__________________________
___________________
Date
333
Sect: 19.6
ANDA Development
ANDA DEVELOPMENT
SECTION XX
SECTION 20
Generic Drug Enforcement Act
TABLE OF CONTENTS
19.1
Section Page and Title and Color Tag
19.2 19.3
Generic Drug Enforcement Act U.S. Agent Letter of Authorization

1. Generic Drug Enforcement Act 2. U.S. Agent - Letter of Authorization
Sect: 20.1
ANDA Development
ANDA DEVELOPMENT
SECTION XX
SECTION 20
Applicant or Agent Letterhead
STATEMENT
Where Company has NO previous convictions AND does not use a debarred person in connection with the ANDA

n behalf of [Generic Company Name's Inc. / Ltd.], the applicant, I hereby certify, pursuant to Section 2(k) Generic Drug Enforcement Act of 1992, 21 USC 335a (k), that the applicant has not used, is not using and will not in the future use in any capacity the services of any person who has been debarred pursuant to Section 2 (a) and or Section 2 (b) Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), in connection with this application.
Applicant further certifies that there have been no conviction of applicant for any of
the types of crimes set forth in Section 2(a) and Section 2(b) of the Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), within the five years prior to the date of this certification, nor has any person affiliated with the applicant, who is responsible in whole or in part, for the development or the submission of this application been convicted of any crime of the type listed in Section 2(a) and Section 2(b) of the Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), within the five years prior to the date of this certification.

__________________________
______________________
Date
Director Quality Assurance Unit Pharmaceutical Manufacturing Division [Generic Company Name Inc. Ltd. ]
Sect: 20.2
ANDA Development
ANDA DEVELOPMENT
SECTION XX
SECTION 20
Applicant or Agent Letterhead
STATEMENT
Where Company has a previous conviction but does not use a debarred person in connection with the ANDA.

n behalf of [Generic Company Name's Inc. / Ltd.], the applicant, I hereby certify, pursuant to Section 2(k) Generic Drug Enforcement Act of 1992, 21 USC 335a (k), that the applicant has not used, is not using and will not in the future use in any capacity the services of any person who has been debarred pursuant to Section 2 (a) and or Section 2 (b) Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), in connection with this application.
Applicant further certifies that during the previous five years it has sustained the
following conviction for the types of offenses as set forth in Section 2(a) and Section 2(b) of the Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), Date of Conviction Nature of Conviction MM/DD/YY Conviction on six counts of fraudulent documentation pertaining to stability reports.
To the best of [Generic Company Name's Inc. / Ltd.] knowledge no person affiliated with the applicant, who is responsible in whole or in part, for the development or the submission of this application has been convicted of any offence of the type listed in Section 2(a) and Section 2(b) of the Generic Drug Enforcement Act of 1992, 21 USC 335a (a) and/or (b), within the five years prior to the date of this certification.
[Signature of Responsible Person] ------------------------------------------------[Name of Responsible Person]
--------------------------------------Date
Sect: 20.3
ANDA Development
ANDA DEVELOPMENT
Sect: 20.4
ANDA Development
ANDA DEVELOPMENT
SECTION XX
SECTION 20
Letter of Authorization - US Agent
[PRINTED ON US APPOINTED AGENTS LETTERHEAD]
n behalf of [Generic Company Name's Inc. / Ltd.], I, [US APPOINTED Applicant's Name] hereby certify, that [Applicant Company Name Inc. / Ltd.] has been duly appointed as representative applicant for the submission of the this ANDA and that the said applicant shall be the responsible person for all future communications with the relevant agencies in connection with matters pertaining to this application.
US APPOINTED APPLICANT
[Applicant Company Site Address]
Full Site Address
[Applicant Company Contact Numbers] Contact Person. Responsibility. Director of Registration Quality Assurance Director
Tel.
Fax.
4
Sect: 20.5
ANDA Development
ANDA DEVELOPMENT
SECTION XXI
SECTION 21
Additional Information
OVERVIEW
his section is used for clarifying the various ADDITIONAL DATA REQUIREMENTS that may apply to the development and the manufacturing procedures of this application.
Note:Where the manufacturing of the drug product may require a rework procedure the
data validating the process step is summarized in this section. All necessary data is presented that indicates no significant change in the overall drug specifications both at product release and during the overall shelf life period claimed for the drug.
Steps that do not require support data are minor process procedures; such as fluid
bed drying operations that may require additional drying to reach the required target moisture content (LOD %) of the granule or additional bulk mixing or homogenization in liquids and semisolids. These conditional procedures are highlighted as standard instructions in the manufacturing method or manufacturing instructions.
This
section is also useful to tabulate Drug Master File (DMF) numbers and list Letters of Access (LOA) to various DMFs as referenced in the Application. LOA letters should be clear copies and display recent dates with correct vendor names and addresses - especially if there has been a name or site change in the vendor's organization.
(Cut and paste where required)
Sect: 21. 1
Topical SEMISOLID.
ANDA DEVELOPMENT
SECTION XXI
SECTION 21
TABLE OF CONTENTS
21.1 21.2 Outline of manufacturing re-work study Table of DMF Numbers (with LOA dates)
Special Note: DMF numbers are required for active / excipient materials such as. Active material Specific Excipients Capsules (Hard Gelatin) Film coating color premixes. Colors/dyes (require US Certification.) DMF numbers are required for container/closure materials. Primary Material in direct contact with the drug product e.g. Plastic containers Plastic / Metal caps Plastic / Metal closures Plastic liners / laminates Plastic seals (Foam seals / tamper evident seals) Plastic application nozzles / integral measuring cups (Glass bottles are exempt from a DMF number) Product DMF numbers are required for container closure material that is a; Secondary Material in indirect contact or during use of the drug product e.g. Inner Liners Closure seals Epoxy Coated Liners (tubes) Foam Seals Cotton Wool (solid dosage forms only.) Silica gel drying agent in plastic containers (solid dosage forms only.) Measuring caps as an integral part of closure system. MNF DMFs Manufacturing DMF numbers are required for the manufacturing facility supplying the raw material. LOAs Letters of Access (recent date and two copies is essential) are required for all referenced DMF numbers.
Sect: 21. 2
Topical SEMISOLID.
ANDA DEVELOPMENT
SECTION XXI
SECTION 21
SUMMARY OF DMF NUMBERS USED IN THIS APPLICATION:
RAW MATERIAL / COMPONENT

ACTIVE MATERIAL(S) Active material used for Biostudy and Pivotal Alternative Supplier Alternative Supplier NON ACTIVE MATERIALS Non-compendial Excipient I Non-compendial Excipient II Color / Pigment (US Certification) Color / Pigment (US Certification) Special Ingredients Special Ingredients CONTAINER-CLOSURES HDPE / LDPE Container (rigid / collapsible) HDPE / LDPE Container (rigid / collapsible) HDPE Cap ROPP Cap Metal Cap Cap liner Adhesive Tamper evident inner-seal Special delivery nozzles or applicators / droppers THERMOPLASTIC RESINS AND MASTER BATCH DYES Resin No [001] Resin No [002] Resin No [003] Master Batch White Master Batch color
DMF NO.
DMF DMF DMF
DMF DMF Cert. Cert. DMF DMF
DMF DMF DMF DMF DMF DMF DMF DMF
DMF DMF DMF DMF DMF
Sect: 21. 3
Topical SEMISOLID.
ANDA DEVELOPMENT
SECTION XXI
SECTION 21
SUMMARY OF LOA LETTERS BY DATE AS USED IN THIS APPLICATION:
RAW MATERIAL / COMPONENT

ACTIVE MATERIAL(S) Active material used for Biostudy and Pivotal Alternative Supplier NON ACTIVE MATERIALS Color / Pigment (US Certification) Color / Pigment (US Certification) Special Ingredients CONTAINER-CLOSURES HDPE / LDPE Container (rigid / collapsible) HDPE / LDPE Container (rigid / collapsible) HDPE Cap ROPP Cap Metal Cap Cap liner Adhesive Tamper evident inner-seal / Foam seals Special delivery nozzles or applicators / droppers THERMOPLASTIC RESINS AND MASTER BATCH DYES Resin No [123456] of THERMOPLASTIC container Resin No [12345] of Cap Resin No [1234] of CRC OUTER component Resin No [123] of CRC INNER component Master Batch White Master Batch color Resin No [001] Resin No [002] Resin No [003] Master Batch White Master Batch color
1 1
LOA DATE.
LOA LOA Cert. Cert. LOA LOA LOA LOA LOA LOA LOA LOA LOA DMF DMF DMF DMF LOA LOA LOA LOA LOA LOA LOA LOA LOA LOA LOA
No LOA date greater than two years. Change in Ownership show new DMF Holder. 1 Note: Child Resistant Closures consist of both an inner and outer component.
Sect: 21. 4
Topical SEMISOLID.
ANDA DEVELOPMENT
SECTION XXII
SECTION 22
Sterilization Assurance
TABLE OF CONTENTS
This section applies to sterile processes:

Sterile Manufacturing Processes Only Copies of the original batch manufacturing instructions in the language of origin q Chinese q Dutch q French q Hebrew q Italian q Polish q Portuguese q Spanish q _________
Section XXII.
Sterilization Assurance Information and Data

Note: This section can be provided as a separate volume for ease of review. If the microbiology section is in a separate volume, please provide copies of the indicated information that may be in other sections of the application instead of page references. 1. General Information a. Copy of cover letter (or page reference) b. Label/package insert copy (or page reference) c. Summary of manufacturing process including components and composition statement (or page reference) d. Copies of pages from completed batch production record containing holding times, filtration integrity testing sterilization records (or page reference) NOTE:Follow the portions of guidance for industry on Submission of Documentation for Sterilization Process Validation in Applications for Human and Veterinary Drug Products that apply to the process in the application.
Sect: 22.1
ANDA Development
ANDA DEVELOPMENT
Do's and Don'ts

13 Commandments when Preparing an Application.
1. 2. 3. 4. 5. 6. 7. 8. The less you make the reviewer work the sooner you get the application! Make it really easy for agency reviewers to review your work. Prepare the applications so that you drag the reviewer through it. Don't challenge the FDA reviewer to think deeply. Don't make them look for a copy of the Orange Book. Don't make them go and find the suitability petition letter. Do include every DMF # and GMP certification that you refer to. Do prepare a detailed narrative where ever possible to give a quick overview of what they can expect. Write confirmation narrative letters on all protocol discussions. Do make your narratives reader friendly - take your time writing them. Don't exclude and executive summary just because its not a statutory requirement - they really help to get the message across. Do layout and assemble your application so that the reviewer can cruise though it by making it a real joy to read. Supply a PDF copy on CD ROM of the full application. Do use the KISS principle - ' Keep it Simple Scientist '.
9. 10. 11. 12. 13.
24 VOLUME DRUG DEVELOPMENT SERIES
ANDA DEVELOPMENT
ANDA DEVELOPMENT
International Association
Drug2000Manufacturers
High Quality Low Cost Drug Development & Manufacturing Excellence World Wide
Innovative & Generic
HANDBOOK OF DRUG DEVELOPMENT

Series Part I - Drug Development Part II - US Type CMCs & EC DOSSIERS
US CHEMISTRY MANUFACTURING CONTROL Know How Technology & EU DOSSIERS Know How Technology
ANDA DEVELOPMENT
ANDA DEVELOPMENT
I n t e r n a t i o n a l
A s s o c i a t i o n
Drug2000Manufacturers
High Quality Cost Effective Drug Development & M anufacturing Excellence World Wide
I n n o v a t i v e
&
G e n e r i c
HANDBOOK of DRUG DEVELOPMENT +120 Title Specific Series
Part I - Drug Development Part II - US Type CMCs or EC DOSSIERS

Generic Development ISSN Series number 0793 7407 Generic Development ISSN Series number 0793 7792 - Electronic Issue (Disk/CD ROM)
The follow HBGD HANDBOOKS KNOW-HOW SERIES are available in the most common dosage forms namely solid, semisolid and liquid dosage forms. The presentation of the actual data is based on manufactured production batches and the format of all sections is similar to the data in the standard ANDA.
Drug Development Series

Alendronate Sodium Alendronate Sodium
Form
Tablets Tablets Tablets Suspension Capsules Tablets Tablets Tablets Capsules Tablets Syrup Tablets Tablets Tablets Tablets Chewable Tab Coated Tab Tablets Tablets Tablets Tablets Suspension Suspension Suspension Capsules Vials Tablets USP
Strength
5 - 10 mg
Volume
Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II
Part
1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2
Amitriphyline HCl Azithromycin Azithromycin Azithromycin Atenolol EU Atenolol US Amoxicillin Bromhexine Hydrochloride Bromhexine Hydrochloride Bromocriptine Mesylate Bupropion Buspirone HCl Carbamazepine (EU + US) Carbamazepine (Chewable) Carbamazepine (Extented Release) Geigy TEGRATOL XR Carbidopa/Levodopa Carbidopa/Levodopa Carbidopa/Levodopa Carbidopa/Levodopa ER Cefaclor Oral Suspension USP Cefaclor Oral Suspension USP Cefaclor Oral Suspension EU Cefaclor Cefuroxime Sodium USP Clonazepam Tablets USP
40 mg 10 mg 200 mg 250 /600 mg 600 mg 50 /100 mg 50 /100 mg 250/500mg 8mg 8mg 2.5mg 75.0/100 mg 5 mg /10 mg 200mg 100 mg 400 mg 10/100 mg 25/100 mg 25/250mg 50/200mg
125 /187 mg/5mL
250/375 mg/5mL 250 mg/5mL 250/500mg 750-1500mg

0.5/1.0/ 2.0mg
Latest Lists are viewable on web http://locumusa.com/2go
ANDA DEVELOPMENT
ANDA DEVELOPMENT
HANDBOOK of DRUG DEVELOPMENT +120 Series

Clomiphene Citrate Clomipramine HCl Clomipramine HCl Diclofenac Potassium Diclofenac Sodium Diclofenac Sodium Diclofenac Sodium Dorzolamide HCL Ophthalmic Etodolac Etodolac Wyeth Lodine Etodolac Wyeth Lodine Enalapril Maleate Etidronate Disodium Famotidine Famotidine Famotidine Felodipine Felodipine Felodipine Extended Release Felodipine Extended Release Felodipine Extended Release Flunisolide Hemihydrate solution Flunitazapam Fluoxetine Fusemide Gabapentin (=Neurontin-Park Davis) Gabapentin (=Neurontin-Park Davis) Gemfibrosil Gemfibrosil Extended Release Glibenclamide Glipizide Extended Release Ibuprofen Isosorbide Mononitrate Ketorolac Tromethamine Levodopa/ Benserazide HCl Labetalol HCL Labetalol HCL Loperimide Mesalamine (Enteric Coated) Metformin HCl (Coated) Metformin HCl (Coated) Miconazole/Hydrocortazone Miconazole Nitrate Nabumatone Nabumatone
Tablets USP Capsules Capsules Tablets Tablets Tablets Clear Gel Solution Capsules Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Nasal solution Tablets Capsules Capsules Capsules Capsules Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Tablets Cream Cream Tablets Tablets
50mg 25/50 mg 75 mg 50 mg 50 / 75 mg 100 mg 10 mg/g 2% 200/300mg 400 mg 500 mg 40 mg 0 mg 10 mg 20 mg 40 mg 5 mg 10 mg 2.5 mg 5 mg 10 mg 1mg/5mL 2 mg 10 / 20 mg 40 mg 100/200 mg 300 /400 mg 450 mg 600 mg 5 mg 2.5 mg 200-800mg 20 mg 10 mg 200/50 mg 100 +200mg 300mg 400mg 500 mg 850 mg 2% + 1% 2% 500 mg 750mg
Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II Volume II
1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2
Copyright 1995-9 by Locum Publishing House Inc. All Rights Reserved. Neither this book nor any part may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying, microfilming and recording, or by any information storage and retrieval system, without the permission of the publishers
ANDA DEVELOPMENT
ANDA DEVELOPMENT
HANDBOOK of DRUG DEVELOPMENT
+120 Series
Naproxen (Enteric Coated) Naproxen DR Naproxen Sodium Naproxen Sodium Norfloxacin USP Ofloxacin
Tablets 250mg Volume II Tablets 375/500mg Volume II Tablets 220 mg Volume II Tablets 275/550 mg Volume II Tablets 400 mg Volume II Tablets 400 mg Volume II 100/200/ Oxolamine Syrup 10 mg/mL Volume II Paracetamol - sugar/dye-free Syrup 125 mg Volume II Paracetamol Chewable Fruit Flavors Tablets 160 mg Volume II Pentoxifylline ER Tablets 400 mg Volume II Penfluridol Capsules 10 mg Volume II Piroxicam Capsules 20 mg Volume II Quinidine Bisulphate Tetrahydrate Tablets 250 mg Volume II Ranitidine HCl Tablets 150 mg Volume II Ranitidine HCl Tablets 300 mg Volume II Simvastatin Tablets 5/10mg 20 / 40 mg Volume II Scopolamine Butylbromide Tablets 10 mg Volume II Selegiline Tablets 5 /10 mg Volume II Sotalol (=Betapace/Berlex) Tablets 80 /120mg Volume II Sotalol (=Betapace/Berlex) Tablets 160 /240mg Volume II Silver Sulphadiazine Cream 1% Volume II Tamoxifen EU Tablets 10 / 20 mg Volume II Tamoxifen EU Tablets 30 / 40mg Volume II Tamoxifen US Tablets 10/20/40mg Volume II Terbutaline Sulfate Syrup 0.3 mg/mL Volume II Terazosin Tablets 1mg / 2mg Volume II Terazosin Tablets 5mg / 10mg Volume II Terfenadine Tablets 60 mg Volume II Tetrahydrozoline HCl USP Eye Drops 2,5mg/5mL Volume II Ticlopidine Tablets 250 mg Volume II Timolol maleate Drops USP Eye Drops 0.25 / 0.5% Volume II Tolmetin Sod. Capsules 400 mg Volume II Tolmetin Sod. Tablets 600 mg Volume II Trazodone Tablets 50/100 mg Volume II Trazodone Tablets 150 mg Volume II Tretinoin Cream USP 0.025% Volume II Sulfamethoxazole Trimethoprim Tablets USP 80/400mg Volume II Sulfamethoxazole Trimethoprim Tablets USP 160/800mg Volume II Sulfamethoxazole Trimethoprim Suspension 80/400mg Volume II Sodium Valproate Syrup 200mg/5mL Volume II Verapamil Hydrochloride Tablets 40 mg Volume II AN ONGOING SERIES - NEW ADDITIONS ADDED TO SERIES
1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2 1&2
Second International Edition - 02 (First to Fourth Print). Fourth printing published and distributed in UK, US, EU, Israel, Asia, and Japan in January 1998 by Locum International Publishing House (Houston, Israel, South Africa) in Hard Cover; Soft and Spiral Cover; Electronic Diskette; and e-mail attachment versions. All print and electronic versions identical in content and format
ANDA DEVELOPMENT

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