The Top Line

PreCheck pulse check: What the industry is saying about FDA’s production initiative

Nov 7, 2025
Christopher Schilling, Chief Regulatory Officer at Forge Biologics, shares insights from his extensive experience in gene therapy and manufacturing. He discusses the FDA's PreCheck initiative aimed at streamlining U.S. biopharma facility buildouts. Key topics include the program’s goals for partnership and predictability, expected timelines, and the need for clear guidance on regulatory processes. Schilling highlights the importance of early engagement and the role of CDMOs in scaling complex therapies, advocating for more transparency from the FDA.
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INSIGHT

PreCheck Promises Predictability

  • The FDA's PreCheck aims to create predictable, partnered engagement between regulators and manufacturers.
  • Christopher Schilling says the proposal is promising but needs clearer guidance and resourcing to be effective.
ADVICE

Comment Now To Influence Final Rule

  • Stakeholders should submit public comments while the PreCheck docket is open to shape the final policy.
  • Christopher Schilling recommends expecting agency review and hopes for implementation in 2026 but urges patience for FDA timing.
ADVICE

Clarify Meeting Rules Upfront

  • Ask the FDA for clarification on meeting processes, timelines, and formal minutes when engaging under PreCheck.
  • Schilling suggests clarifying whether meetings follow PDUFA cadence and whether they are timeboxed.
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