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Since US Fiscal Year 2003, Concept Heidelberg has been evaluating FDA's
warning letters annually on behalf of the European Compliance Academy. Every
year, the findings are summarised in the Warning Letters Report based
exclusively on the GMP-relevant information contained in these documents
issued by the American health authority. In a first step,
the GMP-relevant warning letters are separated from those regarding other
areas, e.g. wrong information on the package and on the leaflet. Other
warning letters irrelevant to GMP are those concerning different industries,
like the food industry.
The GMP-relevant warning letters deal with deviations from
the CFR paragraphs of the cGMP Guide (21 CFR 210/211). All deviations are
then compiled within the framework of a statistical analysis. The result is
a top-10 list for finished medicinal products and a top-3 ranking for blood,
blood products and biologics.
What is especially useful is the compilation of "original
citations", i.e. the deviations from the CFR paragraphs are listed for each
year. Since the deficiencies in API production are of particular importance
to the respective manufacturers, original citations are also listed for this
area. Here you can find an
example of this
list for finished pharmaceuticals from the latest Warning Letters
Report.
For the period observed, the Warning Letters Report offers
another source of information: The frequency of the individual deficiencies
is indicated for each year. From these numbers one can conclude where the
focus of inspections was placed and where this trend points. Here you can
find an example
from the 2005 Report (comparison with 2004).
For further information on the current Warning Letters
Report, please consult the
table of
content. The Report can be ordered at EUR 399. Together with the
Report, you will receive the FDA Navigator CD-ROM. This CD is an excerpt
from the GMP Guideline Manager 9.0 CD. All GMP-relevant FDA documents are
arranged in a clear tree structure (here you will see a
screenshot). A
full-text search enables you to search all guidelines, warning letters and
the Warning Letters Report for a keyword. To order the Warning Letters
Report and the FDA Navigator CD, please go to our
GMP Publications page.
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