If your company has used Cetero Research’s Houston facility to conduct bioanalytical studies between April 1, 2005 and June 15, 2010, your marketing applications may need to be repeated or confirmed. By now, you should have received a letter from FDA asking that new bioequivalence studies be conducted, or if there is supporting stability of the analyte throughout the entire frozen storage period, that samples from the original BE studies be re-assayed.

The week, FDA further clarified their requirements regarding studies conducted at Cetero during the aforementioned time frame as follows:

• April 1, 2005, to February 29, 2008: Studies that were previously submitted as part of an approved or pending application, or studies that will be submitted as part of a new application, will need complete reanalysis (if adequate stability data exist) or repeat of the study.
• March 1, 2008, to August 31, 2009: The Agency will accept studies for submission and review if the sponsor performs an independent third-party data integrity audit using the Bioanalytical Electronic Raw Data Audit Plan (provided by FDA). Further, studies that were previously submitted as part of an approved or pending application will also need verification of data integrity by an independent third-party audit.
• September 1, 2009, to June 15, 2010: The Agency will accept studies for submission and review without reanalysis, repeating, or further audit by Cetero or a third party.

The Weinberg Group, a globally recognized regulatory and scientific consulting firm headquartered in Washington DC, has experience helping pharma companies in these matters. We were, in fact, a key player in remediating the similar MDS Pharma Services crisis at their Montreal facility in 2007, helping our clients prevail with minimal disruption to their organizations and supply chains.

If you are in need of our assistance, please do not hesitate to contact Jeff Antos (202.280.0815) immediately.