CGMP Violations at France’s Biologique Recherche

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A 9/18-9/22/17 FDA inspection at Biologique Recherche, Suresnes, France, found significant violations of current good manufacturing practice (CGMP) regulations for finished pharmaceuticals, according to a 6/8 Warning Letter. Specific violations noted in the letter were: 

  •          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;
  •          failing to conduct at least one test to verify the identity of each component of a drug product and failing to establish the reliability of component supplier analyses on which the company relies in lieu of certain tests through appropriate validation of the supplier’s test results at appropriate intervals;
  •          failing to establish written responsibilities and procedures applicable to the quality control unit;
  •          failing to establish and follow an adequate 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; and
  •          failing to establish adequate written procedures for production and process control designed to assure that the drug products the company manufactures have the identity, strength, quality, and purity they purport or are represented to possess.

“Significant findings in this letter indicate that your quality unit is not able to fully exercise its authority and responsibilities,” the letter says. “Your firm must provide the quality unit with the appropriate authority and sufficient resources to carry out its responsibilities and consistently ensure drug quality.” FDA recommends that the company engage a qualified consultant to perform a comprehensive audit of its entire operation for CGMP compliance. It also says the firm’s corrective and preventive action program should be evaluated by the consultant to help ensure systemic remediation before the company pursues resolution of its compliance status.

FDA placed Biologique Recherche on a 1/17 import alert. The company was told to respond with a list of steps taken since the inspection to correct the violations and prevent their recurrence, with a timetable for completion.

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