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Not just telling you your faults but how to rectify

March 30th, 2014 by

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.

The new EU Process Validation Guidance and what it says

February 28th, 2013 by

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.

What are the requirements for shipping products?

December 12th, 2012 by

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.

Regulations versus Good Business Practices

November 30th, 2012 by

It has come to my attention in webinars I present, mostly through The Tungsten Shield Group, classes I teach at University of California and my consulting work, that many people have lost sight of what their goals should be. When we develop systems, put controls in place, monitor processes, we do it because it makes good business sense. Rather I am sensing a trend for people doing this activity to satisfy regulators. They ask the question

“what do the regulators expect?”

That is instead of developing a robust business process and fine tuning it to meet their needs.
I illustrated this point several months ago related to lot disposition in Designing your QMS post
But in a recent class, I unearthed another example. I was presenting a case for validating components of the cold chain – specifically, the ability of the insulated shipper to keep the product cold for the required time. I iterated that after the validation activity, I would ship certain prodcts with monitoring probes to track the temperature of the shipment for the duration. I indicated I would do it for the first x batches to confirm that the validation was indeed valid. Also it was a measure to assure product integrity if the shipping took longer than planned or the expternal temperature was outside anticipated range. I also indicated that there might be circumstances where I might continue this for a long period.

You might view this as belt and suspenders. But when the integrity of a product in shipment is critical, I think this is small price to pay. When would I do it? For clinical trial materials, where product integrity is critical is one example. I might also do it fr critical product lanuches where success needs to be assured.

The questioner followed up and stated.

If the regulators do not require it I won’t do it?

This in my mind is an example of putting the horse before the cart. and an unwise practice.
We should design processes that meet our business needs. I can assure you that they will meet 95% of regulatory requirements if they are designed well.

Designing your QMS

September 4th, 2012 by

At a recent webinar I presented for Tungsten Shield on the topic of Lot Disposition, I had an interesting question.  It occurred when I was discussing review of investigation reports and it went like this:

What regulation calls for the Lot Disposition group in the US to review the technical content of an investigation before dispositioning a lot for the clinic or commerce?

And this question was prompted because of the following comments I made.

We all know that the QP in Europe examines all the information, he deems necessary prior to dispotioning a lot – it’s what he is obligated to do by law.  That includes review of the investigation reports related to deviations.  It includes a review for completeness and also a technical review to assure he agrees with the conclusions and the content.  He further assures he understands and agrees with the logic behind the decision.  I contend that in the US, the equivalent person responsible for lot disposition should also review the content to understand the decision to release the material or not and if the investigation is not complete or to his liking, should send it back before moving forward to release the lot.  After all by signing the release, you have made a decision that the lot is acceptable.  Part is to assure the investigation is complete but another part is that the decision is logical and supported by the report.  It is not simply a compliance agreement but a techncial one as well.  During an inspection, he would be asked why he released the lot. And an answer of “the investigation was complete and said so, does not wash”.

The questioner did not get it and responded that no regulation actually required it so why do it.  I responded that when I sign something eg lot release, I am putting my name on the line and am assuring the decision is right.  It is just a good business process.

I sense many people just do not buy into that concept but rather look to the regualtory bodies to tell them what to do rather than develop good business processes.