May 17, 2012

FDA Reorganization Signals More Inspections for Drug, Device Firms

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

Under pressure from all sides, the beleaguered FDA keeps announcing new reorganization initiatives, name changes and all sorts of stuff that would be funny if it was scripted by the same team handling Steve Carell’s departure from “The Office” and the ushering in of the new James Spader era.

Unfortunately, in real life these things aren’t always so funny. The FDA has been mocked in many quarters for its failure to maintain a balance between protecting the public safety and encouraging innovation among device and drug companies.

The list of FDA reorg moves made in just the past year would fill pages of old-fashioned newsletter space, but suffice it to say that the FDA has made a lot of changes and shows no signs of stopping.

Question: Should device and drug manufacturers care?

Short answer: Yes.

Question: Do the FDA changes mean more inspections and enforcement action for device and drug manufacturers.

Short answer: Yes.

We’ve spoke with several drug and device company compliance officers in the past few months, and without exception we’re told that dealings with the FDA have become more time-consuming and frequent. Not surprisingly, none wanted to go on the record for fear of further irritating an already irritating (to them) agency.

“I didn’t like the FDA’s approach five years ago, but now I miss those days,” a mid-size device firm compliance officer recently told us, only half jokingly.

Areta Kupchyk

Areta Kupchyk, a partner and former FDA-er now at Reed Smith LLP, notes that “where FDA puts their resources typically reflects their priorities and approach to enforcement.  For example, FDA appears to be putting resources in enforcement areas and giving some of those divisions more independent authority from the chief counsel’s office to take action,” she tells us.

“FDA also wants to speed review times for 510(k) submissions, orphan drug designations, and therapeutic biologics (especially biosimilars).  The new acting Chief Counsel, Liz Dickinson, has a strong background in generic drugs and biosimilars and we are very likely to see more focus in this area,” Areta adds.

These FDA changes are mostly going to impact mid- and small-sized companies on the device side, Areta says. “Large pharmaceuticals already basically understand how compliance works and how to do it, but the mid-size device companies in particular don’t have enough experience with quality systems and GMPs,” especially as FDA’s interests and demands seem to keep changing.

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FDA Policies Contribute to Serious Domestic Drug Shortage

Patrick Stone, President, TradeStone QA

Our domestic pharmaceutical drug shortage situation is a direct result of FDA regulations, FDA reviewer turn-over/project overload and pharmaceutical companies outsourcing production outside the United States.

These three factors are a key part of the current shortage which has many ingredients such as the high cost of conducting business (shipping, labor, tax, and mfg/dist plant overhead). With all of the current pharma mergers and acquisitions, it’s a miracle only 246 products are in short supply.

Those pharma companies that left Puerto Rico and the mainland United States now have to deal with US Customs and the FDA Import Division along with your host nation’s requirements. The low foreign labor cost benefit analysis may not have accurately accounted for shipping supply delays and operating cost over-runs.

FDA, along with the center specific review divisions, have some turn-over and training issues to contend with, too. Maintaining domestic compliance with 21 CFR Drug Regulations through the systems approach with certified drug investigators is proving to be a difficult task for the FDA Districts and Center Departments. The perfect storm conditions have gathered for a serious drug shortage beyond the 246 we currently have on the books.

Generic Drug TabletIt is a national security issue when the US has drug shortages of vulnerable population drugs and critical care maintenance pharmaceuticals on the shortage list. The Quality by Design (QbD) system will further compound the domestic and International chemical & biotechnology drug product development cycle. The ability to react to a vulnerable population drug shortage should be the focus — not outdated chemistry manufacturing control (CMC) regulations.

The pharmaceutical industry and FDA must collaborate to mitigate further risk to national security. We all have a major stake in health care continuity and national security.

Sound scientific method without FDA manufacturing micro-management should be the focus. A drug supply contingency plan must be approved by FDA for drug production to react to a major market shortage. Let drug manufacturers put in a market shortage contingency plan for their drug products or let the market figure out the best way to conduct business.

FDA needs to focus on QA and not the business side of the pharma industry.

A final message to the pharmaceutical industry: come back home to the US. There are plenty of truly skilled individuals ready to work, and land prices plus pad sites have generally gone down. Come on down and build your plants in my state of Texas — we are a business friendly state with no state tax.

Patrick Stone is the author of Bubble Gum Badge – An FDA His-Story. You can also follow him on Twitter.

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Industry: FDA Policies are Raising Threat of Drug Shortages

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

A sobering report from the American Society of Health-System Pharmacists (ASHP), the American Society of Anesthesiologists (ASA), the American Society of Clinical Oncology (ASCO), and the Institute for Safe Medication Practices (ISMP) highlights a serious and growing drug shortage problem in this country – and the FDA is one of the big problems, according to many in the drug industry.

“This is a national security and health risk conundrum,” says former FDA reviewer and now industry consultant (and fellow Assurx blogger) Patrick Stone.

“If the pill well runs dry on our seniors or high risk folks they may expire or degrade further in health,” Patrick worries. The FDA’s “GMP controls and tightly held batch quotas are a mess. QbD will add fuel to this fire by doubling the number of drugs that don’t make it to the shelves.”

A distressing article from Marginal Revolution raises further questions about why this is happening and FDA’s role in it. “Currently there are about 246 drugs that are in short supply, a record high. These shortages are not just a result of accident, error or unusual circumstance, the number of drugs in short supply has risen steadily since 2006. The shortages arise from a combination of systematic factors, among them the policies of the FDA.

Stone’s take: “The FDA simply doesn’t understand how many drugs are impacted by its regulations.” He challenges the agency to track that, just as it tracks 483 violations and other issues.

Editor’s Note: Watch for a new Patrick Stone blog on this topic next week.

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Quality by Design (QbD) Pilot Presents Industry With New Challenges

Patrick Stone, President, TradeStone QA

What products will be affected by QbD? It will apply to new Marketing Authorization Applications (MAAs)/New Drug Applications (NDAs), Type II Variations/Prior-approval supplements (sNDA) and Scientific Advice requests/CMC formal meeting request that include QbD/PAT elements and are submitted to FDA & EU new applications, for MAAs/NDAs where the sponsor/applicant has agreed to a parallel evaluation by both agencies.

Upon request from the sponsor/applicant, and where procedural time-lines will allow, Type II Variations/NDAs may also be considered on a case by case basis. Right now this is a voluntary pilot with some pharma companies being tapped or nudged by FDA & EMA to join in.

Our geographically diverse health product market involves more contracting and outsourcing for many product components. Finished product real time testing and design space requirements will be crucial for implementing QbD.  ICH third party QA mandates will result from this pilot program.

QbD products will be as unique as the individuals who receive them (personalized medicine). This new model may impact two-thirds of the new health care products in the pipeline (cell therapies, gene therapies, and molecular entity therapy).   There will be many approaches to high order characterization and some are not cost effective at present.  Many of the details will take years to sort out. Collaborations between the FDA, Japan Ministry of Health, and  European Medicines agency will require funding along with mutual scientific trust.

Emerging technologies and laboratory techniques will be required to accomplish the QbD paradigm shift. FDA can’t continue using the chemistry approval model for biotechnology products.  This paradigm shift may increase development times and cost structures.  The ICH model will also bring mandatory third party QA review so prepare your models for this as well.

Here are the essential points to focus on for QbD products:

  1. Target the product profile,
  2. Determine CQAs (Critical Quality Attributes),
  3. Link raw material attributes and process parameters to CQAs,
  4. Risk assessment,
  5. Develop a design space,
  6. Design and implement a control strategy.

Generic Drug TabletThe biotechnology sector QbD product development focus will be on design space and real time release testing. The pilot discussion focus for both regulatory agencies will be on ensuring consistent implementation of ICH Q8, Q9, and Q10 guidelines in the assessment process and to facilitate sharing of regulatory discretion & new regulatory concepts manufacturers of small-molecule generic drugs have concerns the initial lag-time in course correcting for the QbD initiative may exponentially delay the application file time for their products.

It appears some generic-drug manufacturers are not willing to implement any QbD concepts until closer to final harmonization and discussion time frames.

Why do you need higher order structure modeling?  Higher order structure product applicants will have to provide protein folding kinetics models with characterization integration into the application and annual report.  Your research models and early development modeling may be progressed for this function. Personalized medicine with batch to batch consistency including stability of 1-90 days is recommended. There are also talking points about including variants and aggregates of your products in the higher order structure models.  Intra and inter chain disulfide bonding, aggregation, and complete polypeptide modeling may be requested application material.

This may prove to be more cost effective while two juggernauts (FDA & EMA) iron out the red tape that will flow from this type of global initiative.  If the funds necessary to make this effort progress are not available on the FDA or EMA, side delays in the process are inevitable.

Molecular and personalized medicine can’t continue to be reviewed with the FDA chemical entity systems approach, approval model.   Effective cancer therapies and molecular medicine may not have the statistical significance necessary when only a handful of patients are treated with the cell or gene therapy.

Warning to Industry: FDA will obviously not let you have your cake and eat it too.  Innovate inevitable change by comments to FDA or accept the QbD change that is inevitable.   Your comments to the FDA will be monitored on the FDA’s Facebook page and current open comment requests. Contact your respective FDA liaison or center contact for discussion points directly related to your product.

Patrick Stone is the author of Bubble Gum Badge – An FDA His-Story. You can also follow him on Twitter.

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Here’s Your Chance to Weigh in on FDA Compliance Focus

Patrick Stone, President, TradeStone QA

The FDA is evaluating every regulated program in order to enhance compliance strategy. The drug program is on deck for the enhanced program evaluations and the agency will open the comment period for the next sixty days.

The enhancement in drug regulations will mean new drugs in the pipeline will take longer to get to market and the products on the market will endure post market safety studies for continuing evaluation of safety and effectiveness.

I would recommend drug companies make it clear in their comments that these FDA changes will make life tougher for small businesses and elongate the timetable they work with in getting new products to market.

I think that the already rising cost of health care will skyrocket to new highs when the enhanced drug regulations are implemented. Some of the proposed changes appear necessary but only time will tell what regulations are actually enacted.

That’s why it’s important for industry to weigh in with comments.

Combination therapies will have to include much more safety data or risk rejection from CDER. Animal studies (GLP) will be increased for toxicity and risk benefit.

I have observed that many good laboratory firms are conglomerating and outsourcing to far east partners. But the price of doing business out of country will not be cheaper in the long run. Shipping costs and intellectual loss will have to be factored into the great globalization effort.

Quality by design (QbD) is a pilot project now but its reference in the federal registry heralds the inevitable federal mandate. The actual report for new enhanced drug regulation may be found here.

Big pharma may be able to navigate the new ocean of regulation but what happens to the start-up biotech companies? Your voice counts for the next 60 days and then the new regulation will follow accordingly.

Make sure to follow Patrick on Twitter.

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Protect Your Firm as FDA Inspections Spike for CROs, Sponsors

Patrick Stone, President, TradeStone QA

During the last two years of my time with FDA I noticed the amount of Sponsor and CRO inspections triple in number (for CDER, CDRH, & CBER).  CRO’s with less than adequately trained clinic staff and facilities to conduct human clinical trials are receiving warning letters and other FDA regulatory penalties.  The FDA has not conducted enhanced Sponsor or CRO Inspections in many years.  I have observed study sites get warning letters because monitors did not catch informed consent violations early in the trial or for other regulatory and subject record keeping violations.  Catching serious problems early in the trial can prevent adverse events, save time and assets in the long run.

Clinical Investigators and Sponsors  do not want to throw study data out due to preventable errors and inconsistent data.  Monitors for CRO’s and Sponsors should be proficient at the Quality Assurance (QA) they provide and be given adequate time at the study site to ensure regulatory and protocol compliance.

In my time at the FDA, even up to the end of my tenure this past March, I have observed CRO’s collecting original source site documentation from the clinic site at study close-out. I wonder how CRO’s seem to keep missing the basic reason FDA investigator’s conduct data-validation audits.  FDA wants to validate that source documentation match the case report form (CRF) and the sponsor provided data-listing with efficacy end points & adverse event lists.  CRO’s can easily scan the original documents into their system, but physically removing the source documents has conditions.

If a CRO truly wants the original documents for whatever reason, the CRO may certify each copy as a true duplicate of the original (21 CFR describes this process).  In many cases the Clinical Investigator relocates or there is no available space and money to store the records so the sponsor may step in to take over.  There’s not going to be any problem as  long as the FDA can follow the paper trail and review original documents as needed.   Copies may and have been found to be falsified so Investigators will not review paper copies of paper source records.  Electronic printout (output) is a different way to operate now and is acceptable for review.  Sponsors & CRO’s are using more electronic case report forms CRF’s & electronic records in general.  FDA is now requiring field Investigators to review computer systems for 21 CFR part 11 compliance & legacy system maintenance.

Do a search for your competitors’ recent FDA inspections and you will see the trend I am describing.  Build quality into your system from the ground up and you will get quality product results.  Trying to retroactively validate electronic systems and equipment or implement late stage corrections will leave you vulnerable to 483 observations.

You can follow Patrick on Twitter.

 

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FDA’s Electronic Record Review Enforcement Policies Present Challenges

Patrick Stone, President, TradeStone QA

In 1999 the FDA released guidance for industry on the electronic records requirements for human clinical trials involving drugs, devices & biological entities (including the manufacturing of the approved products previously listed). In 2002 the FDA started training the field investigators how to review electronic records during routine inspections of human bioresearch and manufacturing for drugs, devices & biological entities. The catch was FDA investigators were not able to actually cite violations for 21 CFR Part 11 (code of Federal regulations) until approximately 2006.

The FDA instructed field investigators to only write up 21 CFR Part 11 violations if there were other non-Part 11 violations as well. One of the reasons it took so long to enforce the 21 CFR Part 11 violations was that fact that TurboEIR (FDAs report writing template system) did not have 21 CFR Part 11 483 cites. TurboEIR 483 citations became standardized because of the inconsistencies of 483s issued throughout the nation.

Fast forward to 2009 and the FDA starts to ramp up electronic record review for every firm that uses electronic records.

As an FDA investigator I have conducted many electronic record reviews and discussed many 483 cited observations with the Center for Drug Evaluation & Research and the Center for Devices and Radiological Health.

The most recent inspection I conducted for electronic records was a molecular diagnostic laboratory conducting testing for human clinical trials. This was a very special case in which I observed the clinical trial data did not match the data-listing provided by the sponsor. Long story short, the firm was using a data-stick to transfer original data-output and transferring it to an Excel data-set. Microsoft Excel® is not 21 CFR Part 11 compliant and the Excel® program cut off too many digits after the decimal place. The solution was an easy fix in that I suggested the molecular lab simply print out the original data and use that instead of the data-stick transferred data.

The Center put a short hold on the project until the reems of paper could be submitted in proper fashion.

The moral of the story is that as a sponsor or health care manufacturer you have to ensure that any projects slated for all electronic record submissions must be qualified and verified to comply with the electronic record regulation.

I will also give you one more example of a scenario where a project was held up by the agency for electronic record issues. I was inspecting a human clinical drug trial and I observed that source data did not match the sponsor provided data-listing because when the study was closed out and the data-lock was put in place it changed the audit trials and greyed out many data-points.

When choosing an electronic records vendor make sure that the data is never obscured or unreadable when the clinical trial is completed and data-lock is in place. You have to go from cradle to grave with your data and validate every step.

The FDA has made numerous electronic records exemptions for the Department of Defense and other U.S. Government agencies under the following exemption law (device products). A Compilation of Exemptions for Electronic Products Found in 21 CFR Chapter I, Sub-Chapter J — Radiological Health Parts 1000 – 1050.

However, the FDA does not currently abide by the electronic records regulation it enforces, for another case of do what I say, not what I do.

You can follow Patrick on Twitter: http://twitter.com/BIMOQA

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What to Expect When the FDA Comes Calling

Patrick Stone, President, TradeStone QA

Enduring data validation audits and for-cause audits for human clinical trials involving biologicals, devices, or new chemical drugs may at first remind some of going to the dentist to get your wisdom teeth pulled.

But, the FDA has just as much at stake as your company does in the products marketed in the U.S., because if there is a problem or unsafe conditions FDA gets blamed for not doing enough.  That’s top of mind for most inspectors and important for regulated entities to remember.

With that in mind, let’s examine industry trends for these types of inspections.

Lets start by what Consumer Safety Officers (CSOs) look at first.  The regulatory binder is a road map of what happened during the clinical trial.  The IRB approvals, FDA approval documentation, and protocol versions are reviewed and recorded for the report.  The monitor reports and frequency of visits directly corresponds to the amount of observations FDA CSOs finds. So far, so good.

The areas most scrutinized for review are the protocol deviations & violations and adverse event reporting.  If a serious adverse event was not reported or not reported per protocol, you’d better expect a 483.  Failure to follow the IRB approved protocol version is the most cited 483 observation.

How does this keep happening over and over again? Easy: research clinic turn-over, lack of training on updated protocol or study procedures and the lack of monitoring.  The FDA is now requiring 100% consent form review of all subjects.  Failure to obtain informed consent with IRB approved document is the second most cited 483 item.

The third and most documented for clinical research 483 items is lack of complete or inaccurate source documentation.  The FDA is now requesting CSOs to audit the firm electronic systems and record any deficiencies on a 483.  The electronic records evolution started in 1999 and the FDA is now catching up and training CSOs to find your Part 11 computer system shortfalls and deficiencies.  Here, the FDA is turning to the ICH model as a bridge to the European Medicines Agency counterpart inspectorate.

The EMA model requires third party QA for every research trial which has proven to cut down on regulatory deficiencies.  In my opinion having that third set of QA eyes is all the difference between no action indicated (NAI) &  voluntary action indicated (VAI) from official action indicated (OAI) and a project hold.

Editor’s note: This is the the first in a series from our new blogger, Patrick Stone, M.S.  Patrick left the FDA in March 2011 after 12 years as a Biosresearch monitor at the agency’s Austin, TX office. He’s now President of TradeStone QA. While with the FDA, Patrick conducted domestic and international inspections of clinical investigators for pre-approval of pharmaceutical drugs, pharmaceutical drug manufacturing plants and domestic Institutional Review Board investigations.

As Stone recently told us, “I have worked closely with all departments (except foods CFSAN) CDER CBER CDRH and CVM. My work has gone through all of those department heads, too. I have 13 warning letters, one NDA revocation, and countless 483’s. I completed on average of 24 BIMO (clinical trial) audits every year since 2001 when I started conducting audits solo. It is my hope to bring some of that experience to readers of this blog.”

You can follow Patrick on Twitter: http://twitter.com/BIMOQA

 

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How Risky is Risk for FDA-Regulated Life Sciences Companies?

Russ King, Managing Partner, Methodsense

The simple word “Risk” is certainly one of the most frequently used terms in the contemporary Compliance Lexicon. It has become a cliché to say that the FDA advocates a “risk based approach.” Risk Management, Risk Assessment and Risk Mitigation are staples on the menus of virtually every life science conference and exhibition. Life Science publications behave similarly and as a case in point the tag line of the AssurX Blog site is “Compliance, quality and risk: Straight talk for regulated industries” (emphasis mine).

But what the heck is “risk”? Should the very nature of “risk” in and of itself really matter to life science companies on a level beyond scenarios of potential harm, SOP creation and record generation?

First, the (sophomoric) exercise of reviewing alternative definitions of risk to get us started:

  • risk = an unwanted event which may or may not occur.
  • risk = the cause of an unwanted event which may or may not occur.
  • risk = the probability of an unwanted event which may or may not occur.
  • risk = the statistical expectation value of an unwanted event which may or may not occur.
  • risk = the fact that a decision is made under conditions of known probabilities (“decision under risk” as opposed to “decision under uncertainty”)

All of these definitions, as well as others, have a couple of things in common: risk involves unwanted consequences and uncertainty. Obvious, right? (Remember this was a sophomoric exercise). Nevertheless, it is interesting to note that unwanted consequences and uncertainty are something we humans tend to fear and hate. Uncertainty is also generally unpopular with humans.

Now consider this within the context of a medical device, pharmaceutical or biotechnology company. Among the passions driving life science companies is scientific knowledge (humans love knowing) and the practical execution of knowledge on behalf of at least two other passions: improving the length and quality of our lives (something humans generally endorse on a wholesale basis) and economic success (a value that is a tad more controversial, but still generally endorsed by most of us). Not surprisingly, these two values are intimately connected: if a life science company can successfully improve our lives, we tend to be willing to pay for it.

Recall now that element of risk called ‘uncertainty’. Uncertainty seems to be diametrically opposed to knowledge, a core value of a science based endeavor. Uncertainty seems at cross purposes to the other passions of life science companies. There is nothing like the uncertainty about the performance of devices or drugs to keep them out of the market or drive buyers away. (But isn’t that the way things should work?)

How a life science company responds to uncertainty will tell you a lot. We have seen fear, fearlessness, dissembling behavior, aggressive truth seeking….you name it and everything in between.

Uncertainty has the powerful ability to threaten everything built by the driving passions of a life science company from market share to profitability. No wonder the reactions to uncertainty vary so greatly from organization to organization. But there is something special about uncertainty and the advocacy of a risk based approach that should be strongly embraced by life science companies.

Confronting and overcoming uncertainty means that at a level much deeper than SOPs and Quality Records we gain knowledge, the very kind of knowledge that fuels the passions of contributing to our welfare and success. Assessing and understanding risk, managing risk and mitigating risk accomplishes this by delivering a better understanding of a company’s products, their manufacture, new products, better operations, etc. which invariably creates greater opportunities to improve our lives and enhance our wealth.

Yes, peeling back the veil of uncertainty can reveal the possibility or even the probability of unwanted consequences. It is very difficult to keep the ‘bad’ out of everything. But the strength of successful life science companies comes from what they know, when they know it, and what they do with that knowledge. The more skillfully life science companies look for, root out, and drag risks into the appropriate (not just any) well lit forum, the more uncertainty is condemned to understanding. Consequently, the opportunity to forestall the possibility or reduce the probability of unwanted consequences improves dramatically.

In other words, risk is a lot more risky if you take the risk of not facing it.

Russ King is Managing Partner at MethodSense, Inc.

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Handling a Warning Letter: If At First You Don’t Succeed…

Last year, we blogged about the most common drug and device GMP 483 items and how to respond to them in writing.  But what if your response is judged inadequate or the FDA otherwise issues a Warning Letter? First off, understand that the agency even at this point is strongly hoping you will voluntarily take the corrective action required so they can settle this case and move on to something else. They are intended to elicit voluntary correction.

However, if you fail to address the issues raised in a Warning Letter, your company can face some serious repercussions, including: recall, seizure, injunction, monetary fine, debarment, disqualification, license suspension or revocation, and prosecution.

The issuance of a Warning Letter certainly raises the stakes after a 483. The violations it contains represent concerns not only of an investigator, but of the District and/or Center Compliance Officers.

Responding to a Warning Letter

Your first action after you receive a Warning Letter should be to immediately notify top management of the letter and give them an idea of the scope of the problem. You should also contact the FDA’s District Director or Compliance Officer. In your written response to them, you should acknowledge your obligation to comply with the law, discuss the impact the issues raised will have on product quality, address any broader or systemic corrections the Warning Letter may have raised, and offer your corrective actions and timetable for completing them.

Ask to meet with the FDA. That meeting is important for a number of reasons, including:

  • Ensuring there is common understanding of GMP concerns
  • Verifying the adequacy of proposed corrections
  • Revealing if further action is planned by the FDA
  • Achieving agreement on how to proceed
  • Providing a written summary, including any clarifications and additional commitments from either side
  • Setting a timetable for periodic updates on progress

Your company can avoid “unnecessary problems” with the FDA as long as your response avoids the following: unrealistic goals, blaming everything on a lack of training, trivializing the product complaints, failing to proofread your correspondence, citing other firms’ practices as an excuse for your own, and failing to implement promised corrections.

Attorney Peter Reichard with Sheppard Mullin works closely with drug and device companies and former FDA officials. He stressed that your Warning Letter response should focus on how you are addressing the problem. “Companies have a tendency to try and explain something, but the FDA is not interested in that,” he says. “They just want to know your plan and that you followed up,” he says.

Part of that plan, Reichard says, is to put together a Warning Letter response team that goes beyond regulatory personnel. Include those involved in business and legal issues and those who keep a handle on resources and expenditures, he advised.

Avoiding Warning Letters

The only proven technique for avoiding enforcement actions [is] establishing an effective Quality System.  And the FDA defines “establish” in this instance as a Quality System that is defined, documented and implemented.

Companies that have SOPs and teams in place to handle process problems tend to do a better job of avoiding Warning Letters, agreed Adam Bloom, an attorney in Reed Smith’s Life Sciences practice.

But the absolute “worst-case” scenario is to become a repeat offender in the eyes of the FDA, he said. “If you said you would fix something, and they come back a year or two later and find the same problems,” they will view you harshly, he added.

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