Repeated Failures

What happens when a FDA regulated company has repeated failures during inspection or when promised corrective action does not appear to be effective?

In a recent warning letter, FDA identified four citations:

  1. Releasing products to the US market without conducting finished product quality testing.
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New EMA Guideline

EMA released the Guideline on the sterilisation of the medicinal product, active substance, excipient and primary container on 6 March 2019, and it will go into effect 1 October 2019.

The guideline is available here.
This document addresses:
4. General requirements
 4.1.
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IBM Clinical Development EDC Validation Project Summary

The Challenge

A global organization that develops, manufactures and sells diagnostic instruments and related software needed validation for their cloud based Electronic Data Capture “EDC” platform, “IBM Clinical Development” to help reduce the time and cost of clinical trials.  Their clinical sites would enter study data into the software and it would expedite their data review and processing.more


Pharmakon – Trial set

In a previous blog post I shared the current information on Pharmakon, an Indiana 503B Outsourcing Facility that released sub/super potent drugs. This facility closed in 2016 after the third FDA investigation which was prompted by an adverse event report concerning the administration of superpotent morphine sulfate (2,460 times potency) to three infants.… more


Data Integrity Risks on SCADA Systems

SCADA (Supervisory Control and Data Acquisition) software vendors have historically served industries that require tight controls over system configurations and data records.  As a result, modern SCADA software systems have evolved to provide a robust set of tools intrinsically designed to prevent the intentional or unintentional undetectable alteration of system data.  more


Starting Materials

Starting Materials for Drug Products:

Analysis of 108 FDA Form 483’s issued to Compounding pharmacies in 2018 was performed. A textual analysis for the term non-pharmaceutical identified approximately 11% of the facilities (12) received an observation associated with the use of non-pharmaceutical products as an ingredient (starting materials) and 1 case where a non-pharmaceutical cleaning solution was used for washing glassware.… more


503B Data Integrity Concerns

For compounding pharmacies regulated under section 503B, electronic record data integrity concerns are increasing in regulatory and customer visibility. The concepts of good data integrity practices is not new. Yet an organization can inadvertently open itself up to serious problems with their electronic record integrity if proper operating and computer system validation procedures are not followed.more


Critical Airflow in Compounding Pharmacies

Analysis of 108 FDA Form 483’s issued to Compounding Pharmacies in 2018 was performed. A textual analysis for the term SMOKE identified approximately 1/3 of the facilities (34) received an observation associated with Critical Airflow Visualization or as commonly referred to as Smoke Studies.
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Audit Trail Review for Data Integrity

In December 2018 the FDA finalized its guidance titled “Data Integrity and Compliance with cGMP, Guidance for Industry.”  Among the topics covered in the guidance was ‘audit trails’. The answers to these two questions “How often should audit trails be reviewed?” and “Who should review audit trails?” may represent a significant update to the FDA’s interpretation and enforcement of predicate rules regarding the use of audit trails.more


CDRH – Recognized Standards

As posted in the Federal Register today (March 14, 2019) closes the comment period on CDRH – Recognized Standards.  Once finalized, this document will list all the CDRH – Recognized Standards as FDA recognized consensus standards and will assist manufacturers who elect to declare conformity with consensus standards to meet certain requirements for medical devices.… more