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Changes to Compliance Program Guidance Manual (CPGM) 7346.832: 
Preapproval Inspections/Investigations, Part II Implementation - 
Inspection Categories that Would Prompt a Preapproval Inspection

This is to inform District Preapproval Managers and those Field personnel who conduct preapproval inspections of the changes CDER has made to the Preapproval Inspection/Investigation CPGM. The Implementation portion of CPGM 7346.832 has been updated to incorporate a risk based approach consistent with the Agency's GMPs for the 21st Century Initiative in order to help reduce the number of preapproval inspections and leverage preapproval resources, where practical, for post approval and/or CGMP coverage.

The strategy for assigning PAIs now includes two general categories, those that will regularly prompt an inspection request from CDER and categories where the district office may choose to perform an inspection. This revised inspection strategy provides ORA Field Offices greater flexibility in determining if a preapproval inspection is necessary based on the most current knowledge and cGMP status of a firm. Additional changes include the deletion of the inspection categories for narrow therapeutic range drugs and generic versions of the top 200 most-prescribed drugs.

These changes are effective immediately and have been incorporated into Compliance Program 7346.832.PDF document  

CDER is anticipating additional changes to the remainder of the Preapproval Inspection/Investigation CPGM. However, FDA determined that these changes are needed immediately to allow greater use of risk-based decisions in the assignment and conduct of preapproval inspections.

The revision to the CPGM was also discussed in the 9/3/2003 FDA Press Release regarding the progress of FDA’s Risk Based Approach to Pharmaceutical GMP for the 21st Century. 

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Date created: September 5, 2003

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