Jun 18th, 2010
FDA investigators will be looking for more transparency between a sponsor and its contract sites regarding the sponsor’s drug application commitments and the contractor’s plant-wide GMP status, FDA Cincinnati District Investigator and Preapproval Manager Kathleen Culver emphasized at a Global Outsourcing Conference at Xavier University on June 14.
Drug firms that outsource manufacturing and testing activities should share the appropriate sections of their drug applications with the contract firms to avoid misunderstandings, facilitate site compliance with the commitments in the application and aid review and pre-approval inspections, Culver emphasized. “I am looking for this when I do the pre-approval inspection to assure there are no misunderstandings and that we will not end up with adulterated or misbranded drug product,” she explained.
In turn, where the contract firm manufactures for multiple clients, it is important that the sponsor have access to other client’s audit findings and records that shed light on the contractor’s overall quality system, Culver stressed. “How can you really thoroughly audit a GMP system when you cannot review all the deviations, investigations or data generated in that system?” the FDA investigator asked. She stressed the importance of performing thorough audits of the quality systems during the contract manufacturer selection process.
More on the issue of transparency between sponsors and contract sites and the regulatory implications and links to relevant documents is available to subscribers. Login here to view page 2.
Before launching IPQ in September 2007, Bill served for over two decades as the primary author of “The Gold Sheet.” During his career tracking the drug and biotech quality regulatory process, Bill's identification of key issues and problem areas and emerging solutions has been influential in the targeting of resources by industry and FDA and has impacted the dialogue on the shaping of new CMC and GMP policies.
More about About Bill PaulsonStay tuned for the next in-depth special report.