Comments on Visible Particulate Inspection Guidance
AstraZeneca says it “welcomes FDA’s provision of clear guidance on the inspection of injectable products for visible particulates.” The company’s response to an agency draft guidance on the topic also includes line-by-line specific comments.
Boehringer Ingelheim’s response says the intent and overall goal of the draft is well understood and the value of such a document is acknowledged and appreciated. “However,” it says, “clearer guidance and clarification is required at some passages to avoid ambiguity or misinterpretation.” The company includes specific comments on areas it believes need more work.
The International Society for Pharmaceutical Engineering says the guidance “includes more topics than the title suggests.” While the title refers only to visual inspection, it says, the content comprises additional issues such as manufacturing and product lifecycle considerations and investigations. “We suggest improving the title to reflect the full content of the document (for example, reference to pharmacopeia, product design, and good manufacturing practice topics such as facilities design, equipment design, etc,” ISPE says. It also includes specific comments.