Wednesday, November 2, 2016

Warning Letter of the Week: aseptic technique edition

Just when you thought that FDA 483s are all about sending letters to Pigu Huaxue International in Chengdu, China, they send a letter to the CEO of Teva Pharmaceutical Works Pvt. Ltd. about a facility in Hungary:
1.    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) 
...b.    Sterility Test Positive Investigations 
You also did not thoroughly investigate sterility test positives. For example, your investigation of  a sterility test failure for [redacted] injection (batch [redacted]) did not adequately assess the hazards in the aseptic manufacturing operation that led to the sterility failure. You also did not determine whether other batches made on the same production line were affected.

In addition, you invalidated multiple sterility test positive results obtained during batch release testing. However, we note that your firm uses a sterility test [redacted] as well as a sterility testing kit that minimizes potential for adventitious contamination that could cause false positives....
2.    Your firm failed to establish and follow appropriate written procedures that are designed to prevent microbiological contamination of drug products purporting to be sterile, and that include validation of all aseptic and sterilization processes. (21 CFR 211.113(b)) 
a.    Poor Aseptic Behavior 
During the inspection, our investigators observed poor aseptic processing techniques that had been previously videotaped at your facility. For example, video from September 8 and 9, 2015, showed the following during the set-up and filling of the sterile injectable drug [redacted]:
  • an operator passing a pen directly over the stopper bowl to another operator.
  • an operator sitting on the clean room floor during set-up of the filling line and not changing the gown after standing up.
  • operators leaning against the cleanroom walls.
  • an operator leaving the RABS [redacted] open for extended periods of time during filling line set-up, even when he was not working in the immediate area.
The economics of general sterile injectable drugs seems to me to be pretty crummy. There's not going to be a huge margins on these drugs, and the regulatory burden is going to be (quite justifiably) very high. It's just gotta be a huge volume play, right? 

1 comment:

  1. it is good that FDA is onto them, Teva has had many quality problems in the past, not just in Hungary. People are not robots and working in a cleanroom on aseptic product line is probably quite repetitive but it is their business not to screw up. If the batches start showing up positive on sterility test, the management must immediately investigate, rather than trying to cover it up - which is what is hinted at in the FDA warning letter.


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