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Issueing COA for ANDA batch

For ANDA batch (prepared in manufacturing site, pilot scale, used for 
stability testing and ANDA application) requires a COA.  Testing is 
done mainly in R&D lab with some testing in QC.  Who should issue 
COA?  Can R&D lab issue COA for initial testing of ANDA 
batch?  Stability is also mainly done in R&D lab for the same 
ANDA/Stability.  Stability report issued by R&D lab.  Trying to avoid 
stricter QA on QC which delays issuing COA.

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Ranjith Gamage
Beijing Pharma

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