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[January 2026] IND Safety Reporting Guidance, eCopy Compliance in the eStar Era + Manufacturing Warning Letter

IND safety reporting guidance, prevent format holds in medical device submissions, and a warning letter that shows what happens when a cleaning products company wanders into OTC drug production.

Originally published January 2026.

Welcome to Insider issue #45.

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This month brings the finalized IND safety reporting guidance that changes how sponsors should think about individual case reports versus aggregate analysis. The core message: stop flooding the FDA with uninformative safety reports. Not every serious adverse event requires an IND safety report—and submitting one that belongs in aggregate analysis is now a compliance issue, not a conservative practice.

For medical device companies, we’re covering eCopy compliance in the eStar era. Format holds aren’t caused by complex scientific issues—they’re triggered by preventable operational failures like naming errors and oversized PDFs. And our warning letter analysis covers a Wisconsin cleaning products company that meandered into OTC hand sanitizer production without understanding what that meant under cGMP.

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