14 Observations in Meridian Medical Inspection
FDA has released the FDA-483 issued following a 2/20-3/24 inspection at Pfizer’s Meridian Medical Technologies combination drug/device manufacturer, whose products include the EpiPen, in Brentwood, MO. The 14 inspection observations were:
- failing to thoroughly review any unexplained discrepancy and the failure of a batch or any of its components to meet any of its specifications, whether or not the batch has already been distributed;
- failing to establish control procedures that monitor the output and validate the performance of those manufacturing processes that may be responsible for causing variability in the characteristics of in-process material and the drug product;
- failing to establish, write down, and follow procedures describing the handling of all written and oral complaints about a drug product;
- failing to adequately establish procedures for identifying valid statistical techniques required for establishing, controlling, and verifying the acceptability of process capability and product characteristics;
- failing to maintain records so that data therein can be reviewed at least annually to evaluate the quality standards of each drug product to determine the need for changes in specifications or manufacturing or control procedures;
- failing to adequately establish procedures for design input;
- failing to adequately establish procedures for design validation;
- failing to have laboratory controls include establishment of scientifically sound and appropriate specifications, standards, sampling plans, and test procedures designed to assure that components, drug product containers, in-process materials, labeling, and drug products conform to appropriate standards of identity, strength, quality, and purity;
- failing to give the quality control unit the responsibility and authority to approve and reject all components, drug product containers, in-process materials, packaging material, and drug products;
- failing to establish and follow procedures designed to prevent microbiological contamination of drug products purporting to be sterile;
- failing to follow written production and process control procedures in the execution of production and process control functions and to document them at the time of performance; and
- failing to provide adequate training to employees engaged in the manufacture, processing, packing, and holding of a drug product so they can perform their assigned functions.