Changes Recommended in Draft Quality Metrics Guidance

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Perrigo says the flexibility provided by FDA in a revised quality metrics draft guidance to allow reporting by site or by product “has the potential to create added confusion for key partners across the supply chain due to the potential for some partners to prefer site reporting and others to prefer consolidated product reporting.” The comment letter says Perrigo recommends that metric data be collected and reported by site to reduce the complexity burden and assure transparency. The company also asks for more flexibility in metrics so that companies and sites may use specific definitions that fit their processes and may be more consistent with currently collected data and metrics.

In its letter, Gilead asks for further clarity on FDA’s approach to enforcement after the voluntary phase of metrics collection. It also says that for products manufactured at multiple sites, preference should be given to the product reporting rather than the site reporting option.

Celgene praises the draft for contributing to the foundation of a global quality mindset across the industry. It says it encourages the agency to first understand what utility it is seeking with the metric data for the short and long-term, how it plans to validate the data, and how it will share such plans with the public.

Specific line-by-line comments on the draft were submitted by Baxter, Allergan, and Sanofi.

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