PADE Reporting Violations at STI Pharma

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A 7/11-7/21 FDA inspection at STI Pharma, Langhorne, PA, found serious violations of Postmarketing Adverse Drug Experience (PADE) reporting requirements, according to an 11/21 Warning Letter from the agency’s Philadelphia District Office. Specific violations included failing to develop adequate written procedures for the surveillance, receipt, evaluation, and reporting of postmarketing adverse drug experiences. The letter says that STI does not have any written procedures that describe how it, and the contractors acting on its behalf, comply with PADE regulations.

“Given your reliance on contractors to carry out PADE activities,” FDA says, “we are concerned about your firm’s fundamental understanding and implementation of PADE regulations, including how they relate to your use of contractors. As the application holders of two NDAs and five ANDAs, you are ultimately responsible for ensuring compliance with the [Federal Food, Drug, and Cosmetics] act and the PADE reporting regulations. The lack of written procedures and the examples of failing to report safety information to FDA in a complete, accurate, and timely manner raise concerns about your firm’s ability to assess the safety of your drug products.”

The company was told to take prompt action to correct the violations and to respond with a list of specific steps taken, documentation of each step, and a timetable for completion.

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