Reviewing these submissions in a timely way is a "great task," says DPME Director Eric Duffy. Although there are fewer supplements for new drugs compared with generics, FDA must pay more attention to them because it has relatively little experience with the new products, Duffy points out. The goal of his office is to develop a streamlined review process that encourages manufacturers to be innovative and adopt continuous-improvement approaches. DPME uses a risk-based triage approach to identify supplements that require more extensive scrutiny because of the impact a proposed change would likely have on pro-duct performance. The approach also considers manufacturers' degree of understanding of product design, desired product performance, and the manufacturing process.

The importance of user-fee support for the drug-review program can be seen in the much slower pace for processing supplements for generic drugs. A generic manufacturer often files 20–30 postapproval supplements during a product's life cycle, pointed out Hospira vice-president Richard Stec, representing the Generic Pharmaceutical Association at the public meeting. This adds up to thousands of supplements submitted each year to FDA's Office of Generic Drugs (OGD). It takes 9–18 months for OGD to review a typical chemistry, manufacturing, and controls prior-approval supplement, says Stec. The whole process of developing a new production system, filing the supplement, and obtaining FDA approval can take four years, Stec explained. OGD Division Director Vilayat Sayeed says that the agency strives to review important supplements within a year but acknowledges that this is a very long time for a company to wait.

To deal with its voluminous workload, OGD is implementing a triage approach to identify the risk associated with the type of change being reporting and the importance of more immediate review. OGD also has launched a question-based review process to accelerate the review of applications that provide information about how the sponsor's quality-control system can ensure consistent product quality. This approach streamlines the application-review process for new generics and also facilitates the evaluation of supplements.

Although there is broad agreement that the current supplement-review system is outmoded and overprescriptive, revising the rules will not be easy. Some manufacturers propose eliminating CBE supplements altogether and providing needed information in annual reports. One idea is to create a new reporting category of "changes that do not require notification to FDA," suggests Clark of OPS.

A key need is to redefine "major" and "moderate" changes and other terms. Phrases such as "moderate potential to adversely affect" a product are too vague. Almost any change has potential to affect a product, and the language encourages companies to file supplements even for changes with limited adverse effects.

Manufacturers agree that many reporting categories described in current rules and guidances are not necessary. Leo Lucisano of GlaxoSmithKline, representing the Pharmaceutical Quality Steering Committee of the Pharmaceutical Research and Manufacturers of America, advocated reducing or eliminating CBE supplements for packaging and testing-site changes and adopting equivalent or superior analytical methods, among other low-risk revisions.

Opportunities to reduce supplements for generics manufacturers

While revising its own rules, industry wants FDA to pay attention to similar efforts in Europe to streamline oversight of drug product "variations." These activities provide an opportunity for regulatory authorities to harmonize postapproval policies globally. European manufacturers back a system with two variation categories: minor changes to be filed with the regulatory authority and major changes requiring prior assessment. This structure could establish a model for revising US rules.