Verrica Pharmaceuticals · VP-102 · 2020 – 2023
How did Verrica's account of its three FDA letters change from 2020 to 2022?
In 2020 and 2021 Verrica said the letter raised no clinical or safety issue; in 2022, no deficiency but one. What it said the letters did raise moved from CMC and human factors, to general quality at a contract manufacturer, to a named manufacturer's reinspection.
EphemerisX Research · Published · 8 source documents · 1 min read
Short answer
In 2020 and 2021 Verrica said the FDA had identified no clinical or safety deficiency; in 2022 it said the letter identified no other deficiency than a contract manufacturer's reinspection. The reasons it reported changed: CMC and human factors in 2020, general quality issues at a contract manufacturer in 2021, and a reinspection of Sterling's facility in 2022, when it added that the FDA had completed its review and the label was ready.
What the evidence shows
July 2020: No Clinical Safety or Efficacy Issues Identified
8-K · Jul 14, 2020. September 2021: The FDA did not identify any clinical, safety or product specific chemistry, manufacturing, and controls deficiencies related to the NDA.
8-K · Sep 20, 2021 May 2022: The CRL did not identify any other deficiencies.
8-K · May 25, 2022
The name YCANTH runs through both sets of documents. The 2020 letter: This name was found conditionally
FDA · Jul 13, 2020 · p. 16. Verrica's releases: conditionally accepted brand name YCANTH
8-K · Jul 14, 2020. The 2021 and 2022 letters: This name was found acceptable pending approval of the application in the current review cycle.
FDA · Sep 16, 2021 · p. 8 August 2022: the resubmission would seek conditional approval to market VP-102 in the United States under the brand name YCANTH
8-K · Aug 11, 2022. The 10-K: YCANTH (VP-102) (cantharidin) 0.7% topical solution was the first product approved by the FDA
10-K · Mar 11, 2026.
What changed
2020, the reasons: the FDA is seeking additional information regarding certain aspects of the CMC (Chemistry, Manufacturing, and Controls) process for the drug/device combination, as well as Human Factors validation
8-K · Jul 14, 2020.
2021: identifying deficiencies at a facility of a contract manufacturing organization
8-K · Sep 20, 2021; in the presentation, open general inspection items at a contract manufacturer (CMO)
8-K · Sep 29, 2021.
2022: deficiencies identified at a general reinspection of a facility of Sterling Pharmaceutical Services, LLC
8-K · May 25, 2022; by August, the only deficiency listed was related to the deficiencies identified at a general reinspection of the contract manufacturing organization (CMO) that manufactures Verrica’s bulk solution drug product
8-K · Aug 11, 2022.
The timing. After the first resubmission, The Prescription Drug User Fee Act (PDUFA) goal date assigned by the FDA for this NDA is June 23, 2021.
8-K · Feb 17, 2021 The second letter is signed 09/16/2021
FDA · Sep 16, 2021 · p. 11.
Follow the thread
- How did Verrica describe the FDA's first letter?“No Clinical Safety or Efficacy Issues Identified”
- What were the “Human Factor comments” the FDA's second letter said would follow separately?“No clinical, safety or product specific” deficiencies
- What changed between Verrica's second and third FDA letters?“The CRL did not identify any other deficiencies”
This investigation connects to
- What happens after a second FDA Complete Response Letter?Cross-investigation · Divergent outcome · with Aldeyra Therapeutics, CorMedix, Outlook Therapeutics, Replimune
- What happens when an FDA letter turns on a contract manufacturer, not the drug?Cross-investigation · Shared concern · with CorMedix
- What did “no efficacy or safety issues” cover in these FDA letter announcements?Cross-investigation · Shared concern · with CorMedix, Replimune
The documents, by date
The passages quoted
FDA Complete Response Letter, July 13, 2020 · page 16
Please refer to correspondence dated, December 6, 2019 which addresses the proposed proprietary name, Ycanth. This name was found conditionallyOpen at the source →
Verrica Pharmaceuticals Form 8-K, filed July 14, 2020
Complete Response Letter Requests Additional Chemistry, Manufacturing, and Controls (CMC) and Human Factors Information – – No Clinical Safety or Efficacy Issues IdentifiedOpen at the source →
Verrica Pharmaceuticals Form 8-K, filed July 14, 2020
If approved, VP-102 will be marketed in the United States under the conditionally accepted brand name YCANTHOpen at the source →
Verrica Pharmaceuticals Form 8-K, filed July 14, 2020
According to the CRL, the FDA is seeking additional information regarding certain aspects of the CMC (Chemistry, Manufacturing, and Controls) process for the drug/device combination, as well as Human Factors validation. Importantly, the FDA did not identify any clinical deficiencies.Open at the source →
Verrica Pharmaceuticals Form 8-K, filed February 17, 2021
The Prescription Drug User Fee Act (PDUFA) goal date assigned by the FDA for this NDA is June 23, 2021.Open at the source →
FDA Complete Response Letter, September 16, 2021 · page 8
described at FDA.gov.3 CARTON AND CONTAINER LABELING (2) We reserve comment on the proposed labeling until the application is otherwise adequate. PROPRIETARY NAME Please refer to correspondence dated, March 23, 2021, which addresses the proposed proprietary name, Ycanth. This name was found acceptable pending approval of the application in the current review cycle. Please resubmit the proposed proprietary name when you respond to the application deficiencies.Open at the source →
FDA Complete Response Letter, September 16, 2021 · page 11
KENDALL A MARCUS 09/16/2021 02:20:43 PMOpen at the source →
Verrica Pharmaceuticals Form 8-K, filed September 20, 2021
announced that it received a complete response letter from the U.S. Food and Drug Administration (the “ FDA ”) identifying deficiencies at a facility of a contract manufacturing organization for its New Drug Application (the “ NDA ”) for VP-102 for the treatment of molluscum contagiosum. The identified deficiencies do not specifically relate to the manufacturing of VP-102, but instead raise general quality issues at the facility. The FDA did not identify any clinical, safety or product specific chemistry, manufacturing, and controls deficiencies related to the NDA.Open at the source →
Verrica Pharmaceuticals Form 8-K, filed September 29, 2021
Verrica received a Complete Response Letter (CRL) from the FDA in September 2021 due to open general inspection items at a contract manufacturer (CMO) that were not specific to VP-102. The Company will request a Type A meeting with the FDA in Q4 ‘21 to demonstrate that the Company’s good manufacturing practices, controls and processes ensure that any deficiencies at the CMO do not impact the efficacy, safety or quality of VP-102. The CMO has also advised Verrica that it is expecting a satisfactory resolution of the facilities identified deficiencies from the FDA prior to the Type A meeting.Open at the source →
Verrica Pharmaceuticals Form 8-K, filed May 25, 2022
announced that it received a complete response letter (“ CRL ”) from the U.S. Food and Drug Administration (the “ FDA ”) as a direct result of deficiencies identified at a general reinspection of a facility of Sterling Pharmaceutical Services, LLC (“ Sterling ”), a contract manufacturing organization for its New Drug Application (the “ NDA ”) for VP-102 for the treatment of molluscum contagiosum. The CRL did not identify any other deficiencies. Sterling advised the Company that it received notice on May 19, 2022 that it is on Official Action Indicated (“ OAI ”) status. None of the issues identified by FDA during the reinspection were specific to the manufacturing of VP-102. The Company was informed by the FDA that it had completed its review of the NDA and product label, there were no open questions on the NDA review, and the VP-102 label was ready to be communicated.Open at the source →
Verrica Pharmaceuticals Form 8-K, filed August 11, 2022
Verrica expects to resubmit the NDA for VP-102 for the treatment of molluscum in the first quarter of 2023 and in its resubmission will seek conditional approval to market VP-102 in the United States under the brand name YCANTHOpen at the source →
Verrica Pharmaceuticals Form 8-K, filed August 11, 2022
According to the CRL, the only deficiency listed was related to the deficiencies identified at a general reinspection of the contract manufacturing organization (CMO) that manufactures Verrica’s bulk solution drug product. None of the issues identified by FDA during the reinspection were specific to the manufacturing of VP-102.Open at the source →
Verrica Pharmaceuticals Form 10-K, filed March 11, 2026
On July 21, 2023, YCANTH (VP-102) (cantharidin) 0.7% topical solution was the first product approved by the FDA for the treatment of molluscum in adult and pediatric patients two years of age and older. We commercially launched YCANTH (VP-102) in August 2023 in the United States for the treatment of molluscum.Open at the source →