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quarta-feira, 18 de março de 2015

GMP News: New Website about GMP-Non-Compliance Statements


Information about manufacturing sites that are out of GMP compliance is urgently
 needed. In a globalized world manufacturing is no longer located in the market where 
the medicinal products are sold. Complex manufacturing supply chains exist for both 
medicinal product and API manufacturing. Today, manufacturing steps take place
 in a long chain of production sites. Bulk manufacturing in site A, fill and finish in site B, 
primary packing in site C, secondary packaging in site D etc. And this example is an 
easy one - the reality is far more complex. The supervision of those sites is 
therefore of great importance for both authorities and pharmaceutical industry.
In the past only US FDA provided information about GMP non compliance by means 
of publishing Warning Letters on their website (see also the ECA Academy service of all 
GMP related Warning Letters). In addition the Freedom of Information Act allows to access 
more detailed information such as the Form 483 and the Establishment Inspection Report
 (EIR). Later the WHO has started to issue their reports about negative findings on the
 webpage. However the current list as per 5th March 2015 only counts two manufacturing 
sites - both located in India (Notice of Concern by WHO) Finally the EMA has established the
EudraGMDP Database with GMP and GDP non compliance reports. Although EudraGMDP
 is already the most comprehensive service, there is still a long way to go. The database 
is not well designed and might not always work as needed. Moreover, not all EU Member 
States enter all their reports in the database in a timely manner. As per 5th 
March 2015 the EudraGMDP counted 77 sites with GMP non compliance reports and 
2 with GDP non-compliance reports. An analysis of the companies listed in the 
database was published in January 2014. At that time
 85 companies were listed with GMP Compliance Reports

Health Canada is the next authority which reacts on the need for information to identify 
companies and sites that do not meet GMP standards. On the recently published new 
webpage the agency informs about their non-compliance findings. On 27 February 
2015 the "GMP Inspection Tracker" counted 15 manufacturing sites with serious 
GMP deviations. Again India takes a lead in this list. The country does not have an 
appropriate inspection system in place. Only a small number of the overall 
pharmaceutical manufacturing sites have been inspected by international authorities. 
But within this relative small number of sites (compared to the overall production in India) 
the number of GMP non compliant sites is enormous. Moreover, the findings are very critical
 and often sites have been found where even basic GMP standards have not been met.
 For example manufacturing data (batch records, analytical records) have been 
manipulated, production sites have been found in dirty conditions (even dead insects 
and mold have been found in clean rooms). The current list of 15 GMP non-compliant 
manufacturing sites counts 11 sites in India, 2 in Canada and 2 in China.


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