Agency could not have approved the application or supplement without relying on that investigation.  Thus, the investigation is not essential to the approval if 1) no clinical investigation is necessary to support the supplement or application in light of previously approved applications (.e., information other than clinical trials, such as bioavailability data, would be sufficient to provide a basis for approval as an ANDA or 505(b) (2) application because of what is already known about a previously approved product), or 2) there are published reports of studies (other than those conducted or sponsored by the applicant) or other publicly available data that independently would have been sufficient to support approval of the application, without reference to the clinical investigation submitted in the application.

 

 

For the purposes of this section, studies comparing two products with the same ingredient(s) are considered to be bioavailability studies.

 

(a)    In light of previously approved applications, is a clinical investigation (either conducted by the applicant or available from some other source, including the published literature) necessary to support approval of the application or supplement?

                                                                              YES /___/        NO /___/

 

If “no,” state the basis for your conclusion that a clinical trial is not necessary for approval AND GO DIRECTLY TO SIGNATURE BLOCK ON Page 9:

 

(b)    Did the applicant submit a list of published studies relevant to the safety and effectiveness of this drug product and a statement that the publicly available data would not independently support approval of the application?

 

                                                                                    YES /___/        NO /___/

 

(1)    If the answer to 2(b) is “yes,” do you personally know of any reason to disagree with the applicant’s conclusion?  If not applicable, answer NO.

 

                                                                              YES /___/        NO /___/

 

 

Page 5

 

 

 

 

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