3D Imaging CGMP and Listing Violations

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A 6/9-6/13 FDA inspection at the 3D Imaging Drug Design and Development drug manufacturing facility in Little Rock, AR, found multiple violations in its production of positron emission tomography (PET) drugs. A 12/4 Warning Letter says specific current good manufacturing practice (CGMP) violations were:

  • company facilities are not adequate to ensure the prevention of contamination of equipment or product by substances, personnel, or environmental conditions that could reasonably be expected to have an adverse effect on product quality, and failure to adequately follow procedures to ensure that all equipment is clean, suitable for its intended purposes, properly installed, maintained, and capable of repeatedly producing valid results;
  • failure to have adequate production and process controls to ensure the consistent production of a PET drug that meets the applicable standards of identity, strength, quality, and purity; and
  • failure to have laboratory methods that are suitable for their intended use and sufficiently sensitive, specific, accurate, and reproducible.

The letter says 3D Imaging failed to update its drug listing with FDA for fludeoxyglucose F18 as required by regulations. It also notes that listings for two other drugs have not been updated or certified.

The agency recommends that 3D Imaging engage a qualified consultant to assist it in meeting CGMP requirements.

The company was told to promptly correct the violations and to respond with a list of specific actions it has taken to address the violations and prevent their recurrence, with a schedule for completing the corrections.

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