CGMP Violations at Phase 4 Pharmaceutical

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A 4/26-5/2/17 FDA inspection at Phase 4 Pharmaceutical, Aventura, FL, found significant violations of current good manufacturing practice regulations for finished pharmaceuticals. A 4/18 Warning Letter says specific violations were: 

  •          failing to establish a quality control unit with the responsibility and authority to approve or reject all components, drug product containers, closures, in-process materials, packaging materials, labeling, and drug products;
  •          failing to establish and follow written procedures designed to assure that correct labels, labeling, and packaging materials are used for the products, including procedures to prevent mix-ups and cross-contamination by physical or spatial separation from operations on other drug products;
  •          failing to establish a system by which the distribution of each lot of drug product can be readily determined to facilitate its recall if necessary; and
  •          failing to ensure that drug products bear an expiration date that is supported by appropriate stability testing.

 The letter says FDA tested OTC transdermal patch products the company repackages and found multiple samples to be sub-potent with no active ingredient content. The agency testing also found nondeclared ingredients (DHEA and pregnenolone) in samples of the firm’s Power Patch.

Phase 4 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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