Vaccines, Blood & Biologics

July 22, 2011 Approval Letter - Gammagard Liquid

Our STN:  BL 125105/708                                  

Baxter Healthcare Corporation
Attention: Ms. Angela Blackshere
One Baxter Way
Westlake Village, CA 91362
Dear Ms. Blackshere:
We have approved your request to supplement your biologics license application for Immune Globulin Infusion (Human) [GAMMAGARD LIQUID], for the treatment of primary immunodeficiency disorders (PID) associated with defects in humoral immunity by subcutaneous route of administration.  Immune Globulin Infusion (Human) is manufactured at your facility in Lessines, Belgium.
The review of this product was associated with the following National Clinical Trial (NCT) number: NCT00546871
Under 21 CFR 201.57(c)(18), patient labeling must be reprinted at the end of the package insert. We request that the text of information distributed to patients be printed in a minimum of 10-point font.
Please provide your final content of labeling in Structured Product Labeling (SPL) format and include the carton and container labels. In addition, please submit three original paper copies for carton and container final printed labeling.  All final labeling should be submitted as Product Correspondence to this BLA at the time of use (prior to marketing) and include implementation information on FDA Form 356h.
In addition, please submit the final content of labeling (21 CFR 601.14) in SPL format via the FDA automated drug registration and listing system, (eLIST), as described at:
Information on submitting SPL files using eLIST may be found in the guidance for industry titled, “SPL Standard for Content of Labeling Technical Qs and As” at:
You may submit two draft copies of the proposed introductory advertising and promotional labeling with an FDA Form 2253 to the Center for Biologics Evaluation and Research, Advertising and Promotional Labeling Branch, HFM-602, 1401 Rockville Pike, Rockville, MD 20852-1448.  You must submit copies of your final advertisement and promotional labeling at the time of initial dissemination or publication, accompanied by Form FDA 2253 (21 CFR 601.12[f][4]).
All promotional claims must be consistent with and not contrary to approved labeling. You should not make a comparative promotional claim or claim of superiority over other products unless you have substantial evidence or substantial clinical experience to support such claims (21 CFR 202.1[e][6]).
Please submit an amendment to all pending supplemental applications for this BLA that include revised labeling incorporating a revised content of labeling that includes this change.
Under the Pediatric Research Equity Act (PREA) (21 U.S.C. 355c), all applications for new active ingredients, new indications, new dosage forms, new dosing regimens, or new routes of administration are required to contain an assessment of the safety and effectiveness of the product for the claimed indication in pediatric patients unless this requirement is waived, deferred, or inapplicable.
We are waiving the pediatric study requirement for neonates and children up to 2 years of age because necessary studies are impossible or highly impracticable.  It is difficult to study neonates and infants with immune deficiency in a prospective clinical trial due to the rarity of diagnosis in this age group. 
This product is appropriately labeled for use in ages 2-16 years for this indication. Therefore, no additional studies are needed in this pediatric group.
We will include information contained in the above-referenced supplement in your biologics license application file.
Sincerely yours,
Basil Golding, M.D.
Division of Hematology
Office of Blood Research and Review  
Center for Biologics
 Evaluation and Research

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