CGMP Issues in Laboratoires Clarins Inspection

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A 9/17-9/21/18 FDA inspection at Laboratoires Clarins, Pontoise, France, found significant violations of current good manufacturing practice (CGMP) regulations for finished pharmaceuticals. A 4/23 Warning Letter lists specific violations as: 

  •          failing 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;
  •          failing to establish adequate written procedures for production and process control designed to assure that drug products the firm manufactures have the identity, strength, quality, and purity they purport or are represented to possess; and
  •          failing to clean, maintain, and, as appropriate for the nature of the drug, sanitize and/or sterilize equipment and utensils at appropriate intervals to prevent malfunctions or contamination that would alter the safety, identity, strength, quality, and purity of the drug product beyond the official or other established requirements.

The letter says that due to the nature of the violations identified at the firm and the fact that it failed to correct repeat observations, FDA strongly recommends that it engage a qualified consultant to assist it in meeting CGMP requirements.

The company was told to respond with a list of specific steps taken since the inspection to correct the violations and prevent their recurrence, with a timetable for completion.

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