India-based drug manufacturing facilities have been criticized by the FDA in recent years for violating quality standards, as the agency increases oversight of key suppliers to the United States.
Food and Drug Administration (FDA) has raised concerns over quality controls at a Mylan NV manufacturing plant in India, according to a warning letter from the agency dated April 3.
The European Compliance Academy (ECA) Analytical Quality Control Working Group (3) recently launched version 2 of its standard operating procedure (SOP) on OOS investigations (4), which harmonizes the FDA and European regulatory approaches.
In an earlier column, the question of retest sample size selection was discussed and proposals (5) were made.
There are two well-established ways of taking an OOS result into consideration in arriving at a reportable result.
Firstly, we will look at isolating the OOS result using a standard confidence interval approach.
bit.ly/2p2b KGV ---------------------------------- "Your firm failed to thoroughly investigate any unexplained discrepancy or failure of a batch or any of its components to meet any of its specifications, whether or not the batch has already been distributed (21 CFR 211.192)." ------------------------- FDA lashes out at Mylan for dismal quality control at HIV drug facility Facility making HIV drugs ignored bad quality control data, regulator says."The publication of the guidance document at this time is not in response to any specific event or trend but, rather, is intended to address long-standing requests from the pharmaceutical industry for clarification of FDA policy in this area." The guidance addresses investigations of OOS results in the laboratory phase, including responsibilities of the analyst and supervisor, and when indicated, the expansion of an investigation outside of the laboratory to include production processes, and raw materials as appropriate.One of the objectives of the new guidance, which has been in development for several years, is to tackle a practice called "testing into compliance" that is sometimes carried out by labs, and which consists in responding to an OOS result only by performing additional testing on a product until a passing result is obtained.Much of the Barr Decision related to data management practices in quality control (QC) laboratories and became the basis of the FDA guidance (OOS guidance).But don’t be fooled into thinking the decision only applies to the QC laboratories, because when viewed from a higher level, the points drive controls for data generated across pharmaceutical companies.In a letter to Mylan, the FDA outlined several violations at the facility, based in Maharashtra, India, and warned Mylan to shape up.Specifically, the FDA said that investigators found that facility employees inexplicably invalidated quality control data that showed that drug batches didn't meet standards.What Are The Basic Principles Of Data Integrity And GMP Data Control?While this article is not intended to be a complete summary of Judge Wolin’s decision and all that it discussed, let’s look at some of the data integrity principles the decision contained.It amazes me that, with all the data integrity issues highlighted in regulatory agency inspections over the last several years, very few people I talk with today are familiar with the court case that set the legal precedent for data integrity standards. FDA felt that Barr Labs’ control practices — including release of product not meeting specifications, inadequate investigations of failed product, failure to control product manufacturing steps, and averaging of testing results — were not sufficient to ensure that products meeting its quality standards were distributed to the public. The company’s argument, though, was that the practices FDA claimed it needed to follow were not specifically required by the GMPs.To me, this is one of the reasons why we see so many data integrity issues — those who forget the past are condemned to repeat it. In response, Barr sued FDA for practicing “ad hoc” drug regulation.