CGMP Violations at China’s Concept Products
An 8/3-8/5/15 FDA inspection at Concept Products Limited, Tianjin, China, identified significant violations of current good manufacturing practice regulations for finished pharmaceuticals, according to a 7/26 Warning Letter. Specific violations observed during the inspection included:
- failing to have, for each batch of drug product, appropriate laboratory determination of satisfactory conformance to final specifications for the drug product, including the identity and strength of each active ingredient, prior to release;
- failing to withhold from use each lot of components, drug product containers, and closures until the lot had been sampled, tested, or examined, as appropriate, and released for use by the quality control unit;
- failing to establish and follow a written testing program designed to assess the stability characteristics of drug products and to use results of such stability testing to determine appropriate storage conditions and expiration dates;
- failing to establish written procedures for production and process controls, including validation protocols and reports, designed to assure that the firm’s drug products have the identity, strength, quality, and purity they purport or are represented to possess; and
- failing to establish written procedures for cleaning and maintaining equipment used in the manufacturing, processing, packaging, or holding of a drug product.
The letter said that the firm’s response acknowledged the significance of the CGMP observations and that it did not commit to any corrective actions regarding the violations observed in the inspection.
The company was told that if it resumed manufacturing drugs for the U.S. market, FDA strongly recommended engaging a qualified consultant to assist it in meeting CGMP requirements. It was told to respond with a list of specific steps taken to correct the violations and prevent their recurrence, along with supporting documentation and a timetable for completion.