Consolidate Alternative Inspection Guidances: PhRMA

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FDA should consolidate its recent draft guidance on “Remote Interactive Evaluations (RIE) of Drug Manufacturing and Bioresearch Monitoring Facilities” with similar draft guidances due to an overlap in content and to minimize confusion. In comments submitted to FDA, Pharmaceutical Research and Manufacturers of America (PhRMA) says the RIE guidance should be consolidated with draft guidances: (1) Conducting Remote Regulatory Assessments Questions and Answers; and (2) Alternative Tools: Assessing Drug Manufacturing Facilities Identified in Pending Applications.

PhRMA’s comments also urge FDA to update the guidance to “explicitly affirm that the agency will consider inspection findings consistent with existing Mutual Recognition Agreements (MRAs) in determining when and whether to utilize an RIE. Further, we recommend FDA add a sentence to the draft guidance confirming that any materials collected or reviewed in the course of an RIE are protected in a similar manner as materials collected during on-site inspections under FOIA.”

Additionally, PhRMA says FDA should revise the guidance to stipulate that:

  • FDA provide at least three weeks advance notice of any planned RIE when feasible
  • FDA explicitly inform the facility whether the agency intends to request video recordings or live camera viewings as part of the RIE
  • FDA notify firms if it expects certain manufacturing operations to be ongoing at the time of the RIE
  • FDA provide details on how it intends to formally acknowledge the closure of an RIE, including expected timelines

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