WARNING LETTERS: DRAMATIC INCREASE TO CHINESE COMPANIES
The analysis of the Warning Letters of the fiscal year 2016 offers a surprise in several respects. On the one hand, with a total of 83 Warning Letters, the number of letters sent to pharmaceutical companies is very high. However, the main portion of this went to US "Compounding Pharmacies", i.e. institutions that produce individual medicinal products according to medical prescriptions, also including sterile preparations. After the deduction of these Warning Letters - 54 in number - 29 Warning Letters remain, almost half of which were addressed to pharmaceutical companies in China and India. The remaining Warning Letters went to companies in the USA, Latin America and Europe. From the Warning Letters directed at API manufacturers around 70% went to Chinese and Indian companies, which is a significantly higher share.
As is well known, FDA inspectors have been increasingly focusing on the GMP-compliant handling of production- related data for some time. Frequently, they find deficiencies concerning this matter in locations in Far Eastern countries.
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The following frequency distribution of the Warning Letters of the FY 2016 in conjunction with "Data Integrity Issues" reflects this situation:
It is interesting to take a look at the Warning Letters for companies producing pharmaceutical active ingredients. In the FY 2016, the FDA concentrated again on the facilities located in India and China. A total of 22 Warning Letters were sent to active substance manufacturers (of these, four are already included in the 29 Warning Letters addressed to pharmaceutical companies, since the companies concerned produce both active substances and finished medicinal products, and the same WLs cover the deficiencies in API and pharmaceutical production. The total number of Warning Letters for pharmaceutical and API companies is therefore 47). Here, the frequency distribution is as follows:
As this review shows, inspectors found violations of data integrity requirements especially in Chinese and Indian companies. In most cases this was not only a question of uncontrolled access to data storage, but often blatant fraud in connection with the manipulation and destruction of data. The content breakdown of the Warning Letters to the pharmaceutical companies according to the most frequently cited deficiencies results in the following ranking of the "Top Five Issues": According to this table, the most common deficiencies infringe basic GMP requirements such as
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- The absence of written SOPs for production and quality control
- The absence of a quality unit that establishes a minimum level of such instructions, enforces compliance and releases materials, intermediates and products
- The absence of the test to release the final product
- The absence of SOPs for the cleaning and maintenance of the production equipment
- The non-compliance of the quarantine status of components, containers and closures before their testing and approval by the quality unit
- The absence of written SOPs to prevent microbial contamination in sterile products and the lack of validation of aseptic processes and sterilization procedures
- The absence of scientifically based test methods in quality control
It is first of all surprising that medicinal products are being produced in pharmaceutical companies without these minimum standards, which have been known for several decades. A partial explanation emerges from the fact that the proportion of Indian and Chinese companies receiving these complaints is high. But there are also always "black sheep" among US American and European companies, which do not meet the minimum standards of Good Manufacturing Practice.
As the analysis of the warning letters of the past fiscal years shows, the focus of the FDA is continuously shifting. A clear trend goes towards data integrity, mainly for API manufacturers in India and China. But "basic GMPs" is also a focus of most FDA inspections again.
A detailed evaluation of the API Warning Letters is the subject of an investigation in a later edition of the GMP Journal.
Dr Gerhard Becker
... is Operations Director and organises and conducts courses and conferences on behalf of the ECA Academy in analytical and compliance topics.