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Pharmaceuticals · NDA Manufacturing Support

Manufacturing and Validation Support for an NDA

The short answer

This is the site-side companion to an NDA filing: making sure the validated process, the control strategy and the records at the manufacturing site match what the application says, and that the people there can explain it during a pre-approval inspection.

01

Why this matters

  • Pre-approval inspections test whether the filing describes reality.
  • A defensible validation package is built during execution, not written afterward.
  • Subject matter experts who cannot explain their own rationale create findings out of good science.
02

Applicable regulations and standards

21 CFR Part 211
cGMP for finished pharmaceuticals.
FDA Process Validation Guidance (2011)
Lifecycle validation expectations.
FDA Compliance Program 7346.832
Pre-approval inspection program objectives.
03

What our consultants actually do

  • Review the validation package for technical defensibility before filing
  • Implement the filed control strategy in site procedures and batch records
  • Assess analytical method validation and transfer at the release laboratory
  • Conduct readiness assessments and coach subject matter experts
  • Remediate gaps between filed commitments and site practice
04

Across the product lifecycle

  1. 01 / DEVELOP

    Data organized to justify filed ranges.

  2. 02 / SCALE

    Commercial equipment differences resolved.

  3. 03 / TRANSFER

    Process and methods transferred and documented.

  4. 04 / VALIDATE

    PPQ executed and reported defensibly.

  5. 05 / MANUFACTURE

    Routine production under the filed control strategy.

  6. 06 / MAINTAIN

    CPV trending and change-driven revalidation.

05

Problems we are usually called about

  • Batch records that omit parameters listed as critical in the filing
  • Validation reports that assert success without addressing observed variability
  • Subject matter experts unfamiliar with the content of their own application
06

Typical deliverables

  • Validation package technical review
  • Control strategy implementation gap assessment
  • Method validation and transfer review
  • Readiness report and SME coaching plan
07

Frequently asked

How long before the inspection should readiness work start?
Far enough ahead that findings can be corrected rather than explained — typically several months, because remediating a validation gap takes longer than writing a narrative about it.
08

References

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