One important effort has been to establish a risk-based approach for identifying top priority drug manufacturing sites for GMP inspections. FDA also is applying risk models to selecting drug samples for laboratory testing as well as companies that warrant review of their adverse-event reporting systems.Of some 1,200 to 1,400 drug manufacturing sites that FDA inspected in 2006, about 500 were categorized as high-risk based on plant size and operations, product types, process control, and contamination potential. The Office of Compliance in the Center for Drug Evaluation and Research (CDER) is issuing an updated white paper that describes the program's first year of operation and, based on this experience, has refined its methods for making priority inspection assignments for 2007. FDA hopes to inspect high-risk facilities every two years. Low-risk plants, the agency concedes, may be visited only every five or six years unless the manufacturer experiences production problems or runs into difficulties maintaining product quality.
BIOLOGICS TOO RISKY
While risk-based models are proving useful in identifying manufacturers and products that warrant closer and more frequent regulatory scrutiny, this approach may be less appropriate for many biotech products, according to Mary Malarkey, director of the Office of Compliance and Biologics Quality in the Center for Biologics Evaluation and Research (CBER). She pointed out at the PDA/FDA Joint Regulatory Conference in Washington in September that almost all therapies regulated by CBER are fairly high risk, so "there's not much wiggle room." In fact, CBER recently decided to inspect vaccine makers annually—instead of every two years— due to recent concerns about vaccine quality and supply, and CBER continues to review its production inventory on a biannual basis.
At the same time, Malarkey is looking to make CBER's compliance program more efficient. The agency is continuing efforts to better integrate preapproval and GMP inspections and to implement a systems-based inspection approach for biological drugs and blood and source plasma establishments; Malarkey's office plans to update this program in 2007.
CBER has developed a risk model to set inspection priorities for the large number of facilities involved in processing human cells, tissues, and cellular and tissue-based products (HCT/Ps) that have evolved into a major new industry. This approach is part of a formal compliance and inspection program established in 2005 as part of a broader FDA Tissue Action Plan. However, FDA is likely to ramp up its oversight of HCT/P operations due to a number of serious incidents involving falsified records and manufacturing deficiencies. FDA issued a guidance in September clarifying that tissue establishments are responsible for ensuring that contractors comply with good tissue practices, and a Task Force on Human Tissue Safety is evaluating the need for increased inspection and regulation of human tissue firms.
KEEPING THE TEAM
Another initiative involves updating the Team Biologics program. FDA conducted a broad reassessment of Team Biologics two years ago as part of its GMP modernization initiative. The basic conclusion was to make some changes while continuing this program for overseeing biotech manufacturers, including blood facilities, vaccine makers, and biotech therapies now regulated by CDER.
A Team Biologics Operations Group, which includes officials from CBER, CDER, and the Office of Regulatory Affairs, has developed a Quality Management System to improve Team Biologics operations and revise standard operating procedures and quality assurance programs for inspection and compliance activities. A main initiative has been to develop metrics to assess the impact of the Team Biologics program on industry. To this end, the Pharmaceutical Quality Research Institute conducted an online survey of manufacturer opinions on Team Biologics' effectiveness; the results are being evaluated, even though industry response has been sparse, Malarkey pointed out.