Concerns About FDA QMM Program

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The Association for Accessible Medicines (AAM) says that while it recognizes FDA’s significant efforts and investments to design a quality management maturity (QMM) program, it and its members have questions and concerns about the design and planned implementation of the program. In its comment letter, AAM raises these issues:

  • it remains unclear whether the agency’s planned QMM assessments will result in accurate, meaningful, objective, measurable, and helpful QMM evaluations or ratings;
  • FDA should more clearly clarify and substantiate how it expects the program to reduce drug shortages;
  • it remains unclear how FDA will be able to separate QMM assessments from its evaluation of current good manufacturing practice reliance;
  • it remains unclear how QMM evaluations would not be affected by establishment size or age, or the types or number of products produced;
  • it is unclear whether FDA has the requisite expertise and staff at this point to implement a QMM program at scale;
  • QMM evaluation ratings and reports should remain private for the foreseeable future;
  • FDA should rely primarily on third-party contractors to conduct on-site QMM evaluations;
  • FDA should, for the foreseeable future, not use QMM evaluations in deciding which establishments to inspect; and
  • FDA should clarify how it would protect trade secret and confidential commercial information acquired through the QMM process.

In its comment, Lonza thanks FDA for soliciting comments and responds to the agency’s questions.

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