Continue Modernizing Foreign Inspections: Study

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Academic researchers say FDA should continue modernizing its foreign inspection framework, ensuring that high-import-volume mutual recognition agreement countries such as Ireland receive scrutiny proportional to their market share, and developing additional metrics to assess whether the unannounced inspection mandate translates into measurable improvements in oversight rigor. Writing in the open-source Journal of Pharmaceutical Innovation, the researchers say the combined inspection-per-billion-U.S. dollars and inspection-outcome-rate frameworks established in the study “offer forward-looking tools to evaluate these policy outcomes as the agency adapts to the globalization of pharmaceutical manufacturing.”

The researchers say they found that increasing import volumes corresponded with declining inspection frequencies from 2014 to 2019. For every additional billion dollars of drug imports to the U.S., they say, there were 23 fewer inspections conducted during 2014-2019. Additionally, while import volumes increased in leading import nations, inspections declined over the same period in most cases.

“The reality of declining inspection volumes based on sheer import of pharmaceutical products into the United States is clear,” the authors say. “FDA’s foreign inspection activity did not keep a uniform pace with the globalization of pharmaceutical manufacturing. Over half of manufacturers supplying the U.S. market are now overseas, many of which are located in India and China. This assessment of nations that import pharmaceutical products to the United States reveals significant disparities in enforcement practices between countries under mutual recognition agreements and those without such agreements. FDA oversight of drug manufacturing in allied MRA regions appears less intensive relative to the volume of imports, whereas countries like China and India face far more frequent scrutiny.”

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