45% of CDER Warning Letters Cited GMPs: Report

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CDER says that the majority (45%) of drug Warning Letters issued in fiscal year 2023 cited GMP requirement violations. The next highest category of letters issued (22%) was for misbranding/unapproved drug product violations, according to a just-released Office of Compliance FY 2023 Annual Report. Compared to last year, the Center saw an increase in Warning Letters citing a failure to respond to FDA-issued requests for records and other information pursuant to section 704(a)(4) of the Federal Food, Drug, and Cosmetic Act.

The report notes that the most common GMP citation last year in Warning Letters to drug manufacturing facilitites involved quality units (21 CFR 211.22). This was followed by control and testing citations (21 CFR 211.84), written procedures and deviations (21 CFR 211.100), production record review (21 CFR 211.192), and equipment cleaning and maintenance (21 CFR 211.67(b)).

CDER says the majority of drug GMP or adulteration Warning Lletters were issued after an on-site inspection, either a facility’s first inspection or a reinspection, adding that 28% of these resulted from findings documented under FDA’s remote oversight tools.

Additionally, the report says the Center classified 264 recall events totaling 1,178 violative drug products, including 28 events that were potentially life-threatening. The top three reasons for recall were GMP deviations, lack of assurance of sterility and failed impurities/degradation specifications.

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