Shriram Institute FDA Inspection Found CGMP Issues
A 10/15-10/22/19 FDA inspection at Shriram Institute for Industrial Research, Delhi, India, found significant violations of current good manufacturing practice (CGMP) regulations for finished pharmaceuticals and significant deviations from CGMP for active pharmaceutical ingredients (API) in its work as a contract testing laboratory. A 4/15 Warning Letter lists the violations and deviations as:
- failing to exercise appropriate controls over computer or related systems to assure that only authorized personnel institute changes in master production and control records or other records;
- failing to establish adequate written responsibilities and procedures applicable to the quality control unit and to follow such written procedures; and
- failing to ensure that all test procedures are scientifically sound and appropriate to ensure that raw materials and API conform to established standards of quality and/or purity.
The letter notes that an 8/2-8/5/16 inspection cited similar CGMP violations and the firm had proposed specific remediations for those observations. “Repeated failures demonstrate that executive management oversight and control over the manufacture of drugs is inadequate,” it says.
FDA strongly recommended that the firm retain a qualified consultant to evaluate its operations and assist it in meeting CGMP requirements. It also recommended a consultant to address data integrity issues and asked for (1) a comprehensive investigation into the extent of the inaccuracies in data records and reporting; (2) a current risk assessment of the potential effects of the observed failures on the quality of drugs tested for commercial release, and (3) a management strategy for the firm that includes details of its global corrective and preventive action plan.
Shriram was told to respond with a list of specific steps taken since the inspection to correct the violations and deviations and prevent their recurrence, with a timetable for completing the steps.