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QbD principles are woven into regulatory guidance documents, primarily guidances Q8 to Q11 of the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH). Practising QbD in biosimilar product development. For biosimilars, however, this process is slightly more complex.
And regulating LDTs through guidance documents is vulnerable to legal challenge on procedural grounds. See , e.g. , ACLA WhitePaper on LDTs here. Rulemaking avoids the twin problems of dependency on action by Congress and the legal weakness of imposing substantive legal requirements through guidance.
Fast-forward to March 2023, when The White House OSTP issued a document per Executive Order 14081, titled “ Bold Goals for U.S. Biotechnology and Biomanufacturing; Harnessing Research and Development to Further Societal Goals.”
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