When I read FDA Warning Letters and I do often, most take the format of telling you the observations and then indicating that this is not a complete list. However, about 10% go one step further and basically read you the riot act suggesting that you need to hire a consultant to “educate you” on the errors of your ways. These are quite common.
But I believe they went to the next level for USV Limited of Mumbai. In the 2/6/2014 WL, they even listed out 7 steps for remediation. View this as reading the riot act 7 times over. Basically there was suspicion of fraud in the data.

The link is Warning Letter

They went on as follows
Get a consultant specialising in data fraud to do the following
1.) Identify the time period when the issue occurred
2.) Identify and interview employees involved in that period
3.) Identify and interview employees who have left who were employed during the period
4.) Gather data to support what comes out of the interview
5.) Trace issues to specific managers including senior management
6.) Determine if any other offending managers are in a position to influence data integrity decisions and expand your oversight
7.) Put into place procedures to prevent recurrence and assure there are no discrepancies between what was filed and reality. Create CAPAs to remedy issues. This does not apply simply to what we found but everything in essence.
Nothing revolutionary just common sense.

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Just when you thought you had it straight, the FDA throws you a fast ball – or is it a slider, a spit ball. Not being a baseball fan, never quite certain what the saying is. Had I used the cricket analogy, I would have said a googly. But I digress.

Reading the new batch of FDA warning letters before my morning coffee, I came across an interesting paradigm breaker.

We all know FDA issues guidances and agrees to the ICH guidances. However, being guidances they are not law. That means that these documents and their contents are “suggestions” of practices they agree with. If you follow them they will give you no grief. They are really the path of least resistance. You can perform other practices and if satisfactory, you are OK. Just it might take more discussion during an inspection.

Now to the warning letter. It was issued to CBSCHEM Ltd of Hong Kong. In observation 1, they find fault in the traceability of the APIs. And which source of “regulation”?. The guidance ICH Q7 together with a hyperlink to the FDA website.

IS this the beginning of a new paradigm where they will cite Guidances?

Time will tell.

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The initial draft of the EU Guidance for Process Validation was released for comment and the comment period closed in October. So what has the thoughts on the new guidance since it was released? Read the linked article in Master Control on line journal for some insights.

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In February I published an article on the topic of Quality by Design as it applies to the Vaccines World. This was based on a presentation at an IBC conference on vaccine development. As you might imagine, QbD has been slow in development of biologics but even slower in Vaccines. Check out the article on the IBC website

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Pharmaceuticals are notoriously heat labile; at least many of the new high tech ones. Many require cold temperature storage at 2-8C. While they can withstand higher temperature for short periods of time, the shelf life of the products is defined by the recommended storage temperature of 2-8C.

With that understanding, is it acceptable to routinely ship them at elevated temperatures eg. ambient? Think of the money we could save says your friendly distribution staff.

This was the question posed to me recently in a webinar hosted by The Tungsten Shield Group on Cold Chain Distribution.

The European regulations are clear. The transportation temperature must be the same as the recommended storage condition. Distribution is really moving storage. Thus, a product designed as requiring cold storage, also requires the same cold condition for distribution. It is clear.

However, the FDA is particularly silent on this in regulations at least. However, they do expect transportation conditions to equal the storage conditions. Thus even the FDA does no condone this practice.

Both regulatory bodies recognize that things go wrong. A shipment heats up due to delays beyond the validated time. Patients leave the drug on the dashboard of the car for hours. These things happen. And a robust stability program designed to explore the impact of elevated temperatures can come to the rescue to determine if the abnormal conditions have degraded the product or not.

However, these accelerated conditions hsould not be used to justify a save a buck program that puts product in jeopardy.

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