
PDA Regulatory Commenting
Keeping abreast of regulations and requirements is an ongoing concern for the pharmaceutical manufacturing community. When new and updated guidance is published, PDA Members work together to provide feedback regarding the content of the draft documents, which include proposed regulations, technical guidance documents, inspection procedures, policy statements, Pharmacopoeia proposals, standards setting activities, and other related items developed by the global regulatory bodies (e.g. US FDA, EMA, WHO, USP, ANVISA). The contributions of PDA’s members ensure a broad industry perspective is presented and considered for inclusion or revision of the draft document. Below are the comments submitted by PDA on behalf of its members to a variety of global regulatory and pharmacopeial bodies. The documents are available for review to all PDA Members as a valuable reference for staying up to date on compliance-related topics and concerns.
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For more information or to suggest a topic for PDA commenting, please contact Carrie Horton, Regulatory Affairs Program Manager.
Comments Archive
2025 PDA Regulatory Comments
- PDA Comments to FDA-2022-D-2301 Small Volume Parenteral Drug Products and Pharmacy Bulk Packages for Parenteral Nutrition Aluminum Content and Labeling Recommendations 28 August 2025 (1020 KB)
- PDA Comments to USP-1037-PAT 29 July 2025 (957 KB)
- PDA Comments to EMA-INS-GMP-48771 Part IV Guidelines on GMP 30 June 2025 (607 KB)
- PDA Comments to EDQM PhEU 5.1.6 Alternative Methods for Control of Microbiological Quality 27 June 2025 (886 KB)
- PDA Comments to PhEU 2.6.14 Bacterial Endotoxins27 June 2025 (1245 KB)
- PDA Comments to NMPA-FGWJ-2025-127 Appendix of Sterile Drugs of the GMP for Drugs 30 May 2025 (668 KB)
- PDA Comments to USP 1110 Microbial Contamination Control Strategy Considerations 30 May 2025 (1248 KB)
- PDA Comments to USP 1114 Microbial Contamination Control Strategies for Cell Therapy Products 30 May 2025 (1175 KB)
- PDA Comments to FDA-2024-D-4689 Considerations for the Use of Artificial Intelligence to Support Regulaotry Decision-Making for Drug and Biological Products 2 April 2025 (754 KB)
- PDA Comments to FDA-2024-D-5374 Considerations for Complying with 21 CFR 211.110 - 2 April 2025 (496 KB)
- PDA Comments to FDA-2024-D-4488 AI-Enabled Device Software Functions 1 April 2025 (1364 KB)
- PDA Comments to Health Canada Health Product Shortage Directorate Regulations Amending Certain Regulations Made Under the Food and Drugs Act 8 March 2025 (299 KB)
- PDA Comments FDA 2024-N-0002 Best Practices for FDA Communication Draft Report 3 February 2025 (212 KB)
2024 PDA Regulatory Comments
- PDA Comments to FDA 2023-D-4395 Use of Real-World Evidence to Support Regulatory Decision Making for Medical Devices 7 February 2024 (431 KB)
- PDA Comments to FDA 2023-N-5653 for FDA Draft Report and Plan on the Best Practices for Guidance 4 March 2024 (276 KB)
- PDA Comments to Chinese Pharmacopeial Chapter 9653 Guidelines for Microbial Testing of Pharmaceutical Packaging Material 20 March 2024 (502 KB)
- PDA Comments to USP PF 46 6 Proposed 1071 Rapid Microbiological Methods for the Detection of Contamination in Short-Life Products 28 March 2024 (249 KB)
- PDA Comments to USP Chapter 72 Respiration-Based Microbiological Methods for the Detection of Contamination in Short-Life Products - USP PF 46-6 28 March 2024 (238 KB)
- PDA Comments to USP Chapter 73 ATP Bioluminescence-Based Microbiological Methods for the Detection of Contamination in Short-Life Products USP PF 50_1 28 March 2024 (220 KB)
- PDA Comments to USP Microbiology Expert Committee on Bioburden Monitoring 1119 9 April 2024 (457 KB)
- PDA Comments to USP Microbiology Expert Committee on Bioburden Test 1119.1 9 April 2024 (376 KB)
- PDA Comments to EMA Guideline Quality Clinical Requirements for ATMPs in Clinical Trials 30 May 2024 (261 KB)
- PDA Comments to WHO Working Document QAS 24.943 Good Manufacturing Practices Considerations for the Prevention and Control of Nitrosamine Contamination in Pharmaceutical Products 6 June 2024 (1766 KB)
- PDA Comments to DHS 2022-0010 for Cyber Incident Reporting for Critical Infrastructure Act (CIRCA) 3 July 2024 (405 KB)
- PDA Comments to ChP_ Guidelines for Risk Assessment and Control of Objectionable Microorganisms in Non-sterile Products _First_ 23 July 2024 (1452 KB)
- PDA Comments to Chinese Pharmacopeial Chapter 0261 Water for Pharmaceutical Purposes 23 July 2024 (1039 KB)
- PDA Comments to FDA-2023-D-5021 Process and Practives Applicable to Bioreseach Monitioroing Inspections_5 August 2024 (232 KB)
- PDA Comments to FDA-2024-D-1829 Platform Technology Designation Program for Drug Development 27 August 2024 (333 KB)
- PDA Comments to FDA 2024-D-2560 Essential Drug Delivery Outputs for Devices Intended to Deliver Drugs and Biological Products 30 September 2024 (515 KB)
- PDA Comments to USP 660 Containers Glass 30 November 2024 (424 KB)
- PDA Comments to USP 1660 Evaluation of the Inner Surface Durability of Glass Containers 30 November 2024 (793 KB)
- PDA Comments to FDA 2024-N-3878 New Drugs Regulatory Program Modernization Integrated Assessment of Marketing Applications and Integrated Review Documentation 4 December 2024 (257 KB)
2023 PDA Regulatory Comments
- PDA Comments to EMA Reflection Paper on the Use of Artificial Intelligence in the Lifecycles of Medicines December 2023 (401 KB)
- PDA Comments to FDA 2023-N-3721 Quality Management Maturity Program for Drug Manufacturing Establishments December 2023 (339 KB)
- PDA Comments to FDA 2023-D-3031 Alternative Tools Assessing Drug Manufacturing Facilities Identified in Pending Applications Draft Guidance for Industry - November 2023 (326 KB)
- PDA Comments to FDA 2023-N-3742 Scientific Challenges and Opportunities to Advance the Development of Individualized Cellular and Gene Therapies November 2023 (303 KB)
- PDA Comments to EMA Concept Paper on the Development of a Guideline on the 4 Quality Aspects of mRNA Vaccines September 2023 (302 KB)
- PDA Comments to FDA 2023-N-0743 Using Artificial Intelligence and Machine Learning in the Development of Drug and Biological Products August 2023 (337 KB)
- PDA Comments to FDA 2023-N-1585 Identification, Assessment and Control of Nitrosamine Drug Substance-Related Impurities in Human Drug Products - July 2023 (314 KB)
- PDA Comments to FDA 2023-N-0487 for Artificial Intelligence in Drug Manufacturing Notice-Request for Information and Comments April 2023 (283 KB)
2022 PDA Regulatory Comments
- PDA Comments to FDA 2020-D-1136-0057 Guidance for Industry Remote Interactive Evaluations of Drug Manufacturing and Bioresearch Monitoring Facilities During the COVID-19 Public Health Emergency 2 February 2022 (354 KB)
- PDA Comments FDA 2021-D-0241 Inspection of Injectable Products for Visible Particulates Guidance for Industry 15 February 2022 (312 KB)
- PDA Comments to EMA ICH Quality Risk Management Q9 R1 15 March 2022 (225 KB)
- PDA Comments to FDA 2022-N-0075 Quality Metrics Reporting Program 7 June 2022 (438 KB)
- PDA Comments toUSP Stimuli Article Sterility by Design for Sterile Products15 June 2022 (329 KB)
- PDA Comments to FDA 2022-D-0705-0001 Q9 (R1) Quality Risk Management 11 July 2022 (214 KB)
- PDA Comments to FDA 2022-D-0810 Remote Regulatory Assessments 19 September 2022 (284 KB)
- PDA Comments to FDA 2022-N-1777 Pharmaceutical Science and Clinical Pharmacology Advisory Committee Meeting 10 October 2022 (176 KB)
2021 PDA Regulatory Comments
- PDA Comments to USP Rules & Procedures of the Council of Experts 2020-2025 8 January 2021 (157 KB)
- PDA Comments to FDA 2020-D-1137 Guidance on Development and Licensure of Vaccines to Prevent Covid-19 21 January 2021 (141 KB)
- PDA Comments to WHO Guidelines on the Transfer of Technology in Pharmaceutical Manufacturing 19 February 2021 (419 KB)
- PDA Comments to USP General Chapter 1042 Cell Banking for Recombinant Biologic 31 March 2021 (220 KB)
- PDA Comments to FDA 2020-D-1137 Guidance on Manufacturing Considerations for Licensed and Investigational Cell & Gene Therapy Products 30 April 2021 (76 KB)
- PDA Comments to WHO Guidelines on the Transfer of Technology in Pharmaceutical Manufacturing rev 1.1 June 2021 (362 KB)
- PDA Comments to Health Canada Guidance Process Validation - Terminal Sterilization Processes for Drugs 16 June 2021 (462 KB)
- PDA Comments to Health Canada Issue Identification Paper - Drug-Device Combination Products 21 July 2021 (255 KB)
- PDA Comments to USP Stimuli to the Revision Process Filling the Pharmacopeial Gaps of Visual Inspection 26 July 2021 (170 KB)
- PDA Comments to USP Chapters 1229_19 and 1229_20 Sterilization and Decontamination 17 December 2021 (290 KB)
- PDA Comments to FDA No 2021-D-1031 Guidance for Industry - Reporting Amount of Listed Drugs and Biological Products Under Section 510(j)(3) of the FD&C Act 20 December 2021 (135 KB)
- PDA Comments to FDA 2021-D-0432 Microbiological Quality Considerations in Non Sterile Drug Manufacturing 28 Dec ember2021 (364 KB)
- PDA Comments to EMA Guideline on Computerised Systems and Electronic Data in Clinical Trials December 2021 (293 KB)
2020 PDA Regulatory Comments
- PDA Comments to EDQM Chapter 5.26 Implementation of Pharmacopoeial Procedures 31 Dec 2020 (145 KB)
- PDA Comments to USP1085.1 Use of Recombinant Reagents in BET_PDA Comments 11 Nov 2020 (186 KB)
- PDA Comment to FDA Guidance on Identification of Manufacturing Establishments in Applications 9 Oct 2020 (274 KB)
- PDA Comments to USP General Notices Revision (Biologics Nomenclature) 31 Jul 2020 (60 KB)
- PDA Comments to EMA Annex 1 Revision - Manufacture of Sterile Medicinal Products 13 Jul 2020 (341 KB)
- PDA Comments to WHO Working Document QAS-20.849 on Cleaning Validation 30 Jun 2020 (185 KB)
- PDA Comments to FDA Guidance on Planning for the Effects of High Absenteeism 29 May 2020 (72 KB)
- PDA Comments to USP General Notices Revision 31 Mar 2020 (149 KB)
- PDA Comments to WHO Guideline on Data Integrity 15 Jan 2020 (83 KB)
2019 PDA Regulatory Comments
- PDA Comments to PICS Guidance on Good Practices for Data Management and Integrity 28 February 2019 (178 KB)
- PDA Comments to Health Canada Draft Guidance on GMPs for APIs 29 March 2019 (219 KB)
- PDA Comments to EDQM Pharmacopeia Chapter 2.6.32. Test for Bacterial Endotoxins Using Recombinanat Factor C 29 March 2019 (674 KB)
- PDA Comments to FDA 2018-D-4417 CDER Program for Recognition Voluntary Consensus Standards 13 April 2019 (217 KB)
- PDA Comments to FDA 2018-D-2074 Guidance on Voluntary Recalls 24 June 2019 (242 KB)
- PDA Comments to USP 2020 Convention Resolution Request 27 August 2019 (203 KB)
- PDA Comments to EMA Guideline on Quality Requirements for Drug Device Combinations 31 August 2019 (252 KB)
- PDA Comments to WHO Guidance on Production of Water For Injection By Means Other Than Distillation 20 September 2019 (232 KB)
- PDA Comments to FDA 2015-D-2537 Quality Metrics and Quality Culture Initiatives 10 October 2019 (137 KB)
- PDA Comments to USP General Chapter Proposals on Distribution and Mean Kinetic Temperature 4 December 2019 (361 KB)
- PDA Comments to Health Canada Guidelines for Environmental Control During Storage and Transportation 20 March 2019 (192 KB)
- PDA Comments to WHO Guidance on Production of WFI by Means Other Than Distillation 15 April 2019 (254 KB)
2018 PDA Regulatory Comments
- PDA Comments to USP Changes to Council of Experts Rules 7 January 2018 (150 KB)
- PDA Comments to Israel MOH Draft QP SOP 1 March 2018 (191 KB)
- PDA Comments to EU Annex 1 Revision: Manufacture of Sterile Medicinal Products 20 March 2018 (577 KB)
- PDA Comments to FDA 1995-D-0288 CMC Changes for Certain Biological Products 22 March 2018 (204 KB)
- PDA Comments to ANVISA Stability Revised Guidance 5 April 2018 (394 KB)
- PDA Comments to FDA 2017-N-5101 Review of Existing Center for Drug Evaluation and Research Regulatory and Information Collection Requirements 13 April 2018 (195 KB)
- PDA Comments to EMA QP and API Site Audit Questions 2 May 2018 (126 KB)
- PDA Comments to EMA EU Template for GMP Non-Compliance Statement 15 May 2018 (99 KB)
- PDA to Health Canada ICH Technical and Regulatory Considerations for Pharmaceutical Product Lifecycle Management 10 August 2018 (367 KB)
- PDA Comments to FDA 1999-D-0081 Guidance on CMCs for Gene Therapy INDs 6 December 2018 (277 KB)
- PDA Response to EDQM Proposed EP 5.17.2. Recommendations on Testing of Particulate Contamination 28 Dec 2018 (363 KB)
- PDA Response to EDQM Revision of EP 5.1.5 Application of F Concepts to Heat Sterilisation 28 Dec 2018 (348 KB)
- PDA Response to FDA Draft Guidance on Testing Gene Therapy Products for RCR 6 Dec 2018 (87 KB)
2017 PDA Regulatory Comments
- PDA Comments to CFDA Guidance on Drug Data Management 9 March 2017 (130 KB)
- PDA Comments to FDA Guidance on Comparative HF Studies Drug Device Combo Products for ANDA 20 March 2017 (218 KB)
- PDA Comments to FDA 2015-D-2537-0097 Revised Guidance on Quality Metrics 27 March 2017 (235 KB)
- PDA Comments to Health Canada Draft Guidance on GMPs for Drug Products 1 May 2017 (229 KB)
- PDA Comments to EMA Concept Paper on Need for Revision of Note for Guideline on Water for Pharmaceutical Use 6 June 2017 (108 KB)
- PDA Comment to EMA Q and A for Shared Facilities and HBEL Limits 25 May 2017 (472 KB)
- PDA Comments to FDA 2017-D-0154 Interchangeability Guidance on Human Factors 19 June 2017 (143 KB)
- PDA Comments to CFDA Draft Guidance on Simulation Testing of Sterile Processes 7 September 2017 (330 KB)
- PDA Comments to WHO Draft Guidlines on Procedures and Data Requirement for PAC Biotherapeutics 16 Sep 2017 (208 KB)
2016 PDA Regulatory Comments
- PDA Comments to EMA Guideline on Manufacture of the Finished Dosage Form 15 January 2016 (263 KB)
- PDA Comments to EMA Guidelines on Manufacture of the Finished Dosage Form 15 January 2016 (346 KB)
- PDA Comments to USP General Chapters Prospectus Documents: Storage and Transportation of IDPs 29 March 2016 (151 KB)
- PDA Comments to FDA 2015-D-4848 Guidance for Industry - Human Factors Studies and Related Clinical Study Considerations 4 May 2016 (276 KB)
- PDA Comments to FDA 2015-D-4848 Guidance Implementation of Deemed to be a License Provision of BPCIA 23 May 2016 (198 KB)
- PDA Comments to FDA 2016-D-1113 Guidance Data Integrity and Compliance with cGMP 17 June 2016 (184 KB)
- PDA Comments to FDA 2016-D-0973 Guidance Comparability Protocols for Human Drugs and Biologics 30 June 2016 (153 KB)
- PDA Comments to FDA 2009-D-0539-0024 Assay Development for Immunogenicity Testing of Therapeutic Proteins 5 July 2016 (154 KB)
- PDA Comments to WHO Guideline QAS 16.666 Validation 18 July 2016 (124 KB)
- PDA Comments to WHO Guideline QAS 16.671 Appendix 4 Analytical Method Validation 22 August 2016 (149 KB)
- PDA Comments to WHO Guidelines on Validation: Appendix 6 23 August 2016 (158 KB)
- PDA Comments to FDA 2016-D-1594 Metrics Technical Conformance Guide 26 September 2016 (146 KB)
- PDA Comments to FDA 2016-D-2268 Guidance Insanitary Conditions at Compounding Facilities 3 October 2016 (159 KB)
- PDA Comments to EMA Guidelines on the Sterilization of the Medicinal Product, Active Substance, Excipient and Primary Container 13 October 2016 (535 KB)
- PDA Comments to MHRA GxP Data Integrity Definitions and Guidance for Industry 1 November 2016 (195 KB)
- PDA Comments to EMA QA Production of WFI by Non Distillation Methods 4 November 2016 (219 KB)
- PDA Comments to WHO PAC for Biotherapeutic Products 19 December 2016 (210 KB)
2015 PDA Regulatory Comments
- PDA Comments to FDA Guidance for Human Cells Tissues and Cellular and Tissue-Based Products from Adipose Tissue 23 February 2015 (424 KB)
- PDA Comments to FDA Guidance for Minimal Manipulation of Human Cells Tissues and Cellular and Tissue-Based Products 23 February 2015 (411 KB)
- PDA Comments to WHO Good Pharmacopoeial Practices QAS13.526 30 March 2015 (712 KB)
- PDA Comments to FDA 2015-D-0349 Guidance for Industry Investigating and Reporting Adverse Reactions 21 April 2015 (582 KB)
- PDA Comments to FDA 2015-D-0198 Guidance for Industry Good Manufacturing Practices for Combination Products 27 April 2015 (654 KB)
- PDA Comments to WHO Proposal for Revision of Good Trade and Distribution Practices for Pharmaceutical Starting Materials 12 May 2015 (623 KB)
- PDA Comments to FDA 2014-D-1525 Guidance for Industry Mixing Diluting or Repackaging Biological Products 20 May 2015 (663 KB)
- PDA Comments to FDA 2015-D-1659 Guidance for Industry Established Conditions: Reportable CMC Changes for Approved Drug and Biologic Products 20 August 2015 (805 KB)
- PDA Comments to EDQM Biological Indicators and Related Microbial Preparations 25 Sepember 2015 (624 KB)
- PDA Comments to FDA 2015-D-2537 Guidance for Industry Request for Quality Metrics 12 November 2015 (486 KB)
- PDA Guidance to EMA GMP for Advanced Therapy Medicinal Products 12 November 2015 (345 KB)
- PDA Comments to EC Guidelines for Good Manufacturing Practice for Medicinal Products for Human and Veterinary Use Annex 17 17 December 2015 (271 KB)
2014 PDA Regulatory Comments
- PDA Comments to Health Canada Quality Guidance on New Drug and Abbreviated New Drug Submissions 9 April 2014 (234 KB)
- PDA Comments to FDA 2014-D-0103 Guidance for Industry Analytical Procedures and Methods Validation 20 May 2014 (206 KB)
- PDA Comments to EU GMP Annex 15 Qualification and Validation 29 May 2014 (188 KB)
- PDA Comments to EU Good Distribution Practice of Medicinal Products for Human Use 17 July 2014 (109 KB)
- PDA Comments to FDA Guidance for Industry cGMP Interim Guidance for Human Drug Compounding Outsourcing Facilities 28 August 2014 (420 KB)
- PDA Comments to EMA Guideline on Process Validation of Biotechnology-Derived Active Substances 28 October 2014 (469 KB)
- PDA Comments to CFDA Guidance GMPs Draft Annex 1 Qualification and Validation 24 November 2014 (895 KB)
2013 PDA Regulatory Comments
- PDA Comments to FDA 2013-N-0124 Guidance on Drug Shortages Strategic Plan 13 March 2013 (180 KB)
- PDA Comments to USP Proposed In-Process Revision to General Notice Section 5 Monograph Components 26 March 2013 (141 KB)
- PDA Comments to WHO Draft Guidance on GMP for Pharmaceutical Products 28 March 2013 (192 KB)
- PDA Comments to EU Commission Draft Template on GMPCompliance of Investigational Medicinal Products Manufactured in Non-EU Countries 2 April 2013 (288 KB)
- PDA Comments to EU Commission Guidance on GMP for Excipients of Medicinal Products for Human Use 30 April 2013 (158 KB)
- PDA Commission to EU Commission Guidance on Principles of Good Distribution Practices for Active Substances for Medicinal Products for Human Use 30 April 2013 (164 KB)
- PDA Comments to EU Commission Guidance on Setting Health Based Exposure Limits for Use 26 June 2013 (184 KB)
- PDA Comments to FDA Guidance on Glass Syringes for Delivering Drug and Biological Products 2 July 2013 (198 KB)
- PDA Comments to FDA Guidance on Contract Manufacturing Arrangements for Drugs 29 July 2013 (171 KB)
- PDA Comments to FDA 2013-N-0365 Proposed Rule on Administrative Detention of Drugs 13 September 2013 (162 KB)
- PDA Comments to FDA Guidance on Delaying Denying Limiting or Refusing a Drug Inspection 13 September 2013 (166 KB)
- PDA Comments to EU Commission Guidance on Use of Porcine Trypsin Used in Manufacture of Human Biological Medicinal Products 8 October 2013 (205 KB)
- PDA Comments to EU Commission Guidance on Similar Biological Medicinal Products 30 October 2013 (175 KB)
2012 PDA Regulatory Comments
- PDA Comments to FDA 2011-D-0605 Guidance on Scientific Considerations in Demonstrating Biosimilarity to a Reference Product 13 April 2012 (102 KB)
- PDA Comments to FDA 2011-D-0611 Guidance of Industry Biosimilars: Questions and Answers Regarding Inplementation of the Biologics Price Competition and Innovations Act of 2009 13 April 2012 (103 KB)
- PDA Comments to EU Commission Guidance on GMP for Active Substances in Medicinal Products for Human Use 20 April 2012 (223 KB)
- PDA Comments to EMA on Guidance on Process Validation 30 October 2012 (927 KB)
2011 PDA Regulatory Comments
- PDA Comments to EMA Guidance on Process Validation of Medicinal Products Containing Biotechnology Derived Proteins as Active Sustance 31 August 2011 (110 KB)
- PDA Comments to FDA 2011-D-0436 Q11 Development and Manufacture of Drug Substances 1 September 2011 (148 KB)
- PDA Comments to FDA 2011-N-0080 Amendments to Sterility Test Requirements for Biologic Products 16 September 2011 (103 KB)
- PDA Comments to FDA 2011-D-0691 Guidance on Media Fills for Validation of Aseptic Preparations for PET Drugs 23 December 2011 (125 KB)
- PDA Comments to EMA Guidance on Good Distribution Practice of Medicinal Products for Human Use 31 December 2011 (352 KB)
2010 PDA Regulatory Comments
- PDA Comments to FDA 2008-N-0424 Rule on Postmarketing Safety Reporting for Combination Products 27 January 2010 (44 KB)
- PDA Comments to FDA 2008-D-0409 DDM Rule on Current GMP Requirements for Combination Products 4 February 2010 (61 KB)
- PDA Comments to FDA 2009-D-0568 DDM Draft Guidance on Planning for the Effects of High Absenteeism to Ensure Availability of Medically Necessary Drug Products 4 March 2010 (74 KB)
- PDA Comments to EMA Explanatory Notes for Pharmaceutical Manufacturers on the Preparation of a Site Master File and Content of a Site Master File 30 March 2010 (656 KB)
- PDA Comments to FDA 2009-N-0247 DDM Request for Comments on the Transparency Task Force 12 April 2010 (34 KB)
- PDA Comments to FDA 2010-D-0283 CMC Draft Guidance Postapproval Manufacturing Changes Reportable in Annual Reports 23 September 2010 (54 KB)
- PDA Comments to EMA CMC Draft Guidelines on the Requirements for Quality Documentation Concerning Biological Investigational Medicinal Products in Clinical Trials 31 August 2010 (252 KB)
- PDA Comments to WHO Good Practices for Pharmaceutical Microbiology Laboratories 30 September 2010 (234 KB)
2009 PDA Regulatory Comments
- PDA Comments to FDA 2008-D-0520 Guidance for Industry on Potency Testing of Cellular and Gene Therapy Products 7 January 2009 (136 KB)
- PDA Comments on EMA EU Guidelines to GMP, Medicinal Products for Human and Veternary Use, Annex 13 29 January 2009 (131 KB)
- PDA Comments to FDA 2008-D-0559 Guidance for Industry on Process Validation: General Principles and Practices 3 March 2009 (411 KB)
- PDA Comments to EDQM on Pharmaeuropa Chapters 2.6.16 and 5.2.3 31 March 2009 (124 KB)
- PDA Comments to EDQM Pharmaeuropa Chapter XXXX2031, Monoclonal Antibodies for Human Use 31 March 2009 (241 KB)
- PDA Comments to FDA 2009-D-0001 Standards for Securing the Drug Supply Chain 14 April 2009 (36 KB)
- PDA Comments to EMA Concept Paper for Implementation of ICH Q10 in the EU GMP Guide 27 May 2009 (136 KB)
- PDA Comments to EMA Minimizing the Risk of Transmitting Animal Spongiform Encephalopathy Agents via Human and Veterinary Medicinal Products 30 June 2009 (335 KB)
- PDA Comments to FDA 2009-D-0179 Technical Considerations for Pen, Jet and Related Injectors Intended for Use with Drugs and Biological Products 27 July 2009 (63 KB)
- PDA Comments to WHO Recommendations for the Evaluation of Animal Cell Cultures as Substrates for the Manufacture of Biological Medicinal Products and for the Characterization of Cell Banks 30 September 2009 (225 KB)
2008 PDA Regulatory Comments
- PDA Comments to FDA 2007-D-0459 Evaluation and Recommendation of Pharmacopoeial Texts for Use in ICH Regions 15 February 2008 (42 KB)
- PDA Comments to FDA 2007-0614 Amendment to the Current GMP Regulations for Finished Pharmaceuticals 15 February 2007 (65 KB)
- PDA Comments to EMA Revisions to EU GMP Annex 2 14 March 2008 (106 KB)
- PDA Comments to EMA ICH Topic Q8 Annex, Pharmaceutical Development 31 May 2008 (279 KB)
- PDA Comments to FDA 2008-D-0391 Applications for Parametric Release of Human and Veterinary Drug Products Terminally Sterilized by Most Heat Process 3 October 2008 (85 KB)
- PDA Comments to EMA Guidelines to GMP Draft Annex 11 Computerized Systems 31 October 2008 (89 KB)
- PDA Comments to EMA Guidelines to GMP Chapter 4 31 October 2008 (40 KB)
2007 PDA Regulatory Comments
- PDA Comments to Canada GMP Inspection Unit Proposal for Revisions to Canadian GMPs 20 February 2007 (41 KB)
- PDA Comments to EMA Proposed Revision to Chapter 1 of the GMP Guide to Include Reference to Quality Risk Management Principles 25 April 2007 (74 KB)
- PDA Comments to EMA Batch Release Certificate Referred to in Art-13-3 of Directive 2001-20-EC 31 August 2007 (73 KB)
- PDA Comments to FDA 2007-D-0266 Q10 Pharmaceutical Quality Systems 9 October 2007 (36 KB)
- PDA Comments to EMA Production and Quality Control of Monoclonal Antibodies and Related Substances 30 November 2007 (124 KB)
2006 PDA Regulatory Comments
- PDA Comments to FDA 2005-D-0286 Guidance for Industry, INDS - Approached to Complying with cGMP during Phase 1 17 March 2006 (185 KB)
- PDA Comments to FDA 2005-N-0285 Current Good Manufacturing Practice Regulation and Investigational New Drugs 29 March 2006 (177 KB)
- PDA Comments to EMA on GMP Annex 1-1 24 April 2006 (47 KB)
- PDA Comments to FDA 2006-D-0383 Guidance for Industry: Characterization and Qualification of Cell Substrates and Other Biological Starting Materials 21 December 2006 (37 KB)
- PDA Comments to EMA on Virus Safety Evaluation of Biotechnological Investigational Medicinal Products Guidance 1 28 December 2006 (47 KB)
- Annex 1 Comment Submission Document to the EMEA (87 KB)
- PDA Comments on Biological Starting Materials Guidance2 (142 KB)
- PDA Comments on Draft FDA Guidance for Industry - Phase I GMPs (40 KB)
- PDA Comments on GMP Annex 1-2 (87 KB)
- PDA Comments on GMP Annex 1-3 (77 KB)
- PDA Comments on Virus Safety Evaluation of Biotechnological Investigational Medicinal Products Guidance2 (79 KB)