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FDA’s effectiveness in managing the foreign drug inspection
program continues to be hindered by weaknesses in its databases. FDA does not
know how many foreign establishments are subject to inspection. Instead, FDA
relies on databases that were not designed for this purpose. Further, these
databases contain inaccuracies that FDA cannot easily reconcile. One database
indicates there were about 3,000 foreign establishments registered to market
drugs in the United States in fiscal year 2007, while another indicates that
about 6,800 foreign establishments actually imported drugs in that year. FDA
recognizes these flaws. Further, because the databases cannot exchange
information, any comparisons of the data are performed manually, on a
case-by-case basis. FDA officials told GAO that they have not generated an
accurate count of foreign establishments whose drugs are imported into the
United States.
FDA inspects relatively few foreign establishments. Data from
FDA suggest that the agency may inspect about 7 percent of foreign
establishments in a given year. At this rate, it would take FDA more than 13
years to inspect each foreign establishment once, assuming that no additional
establishments require inspection. However, FDA cannot provide an exact number
of foreign establishments that have never been inspected. Most of the foreign
inspections performed are conducted as part of a review associated with
processing an application to market a new drug, rather than inspections for
monitoring the quality of marketed drugs.

Although FDA uses a risk-based process to develop a prioritized
list of foreign establishments for inspections to monitor the quality of
marketed drugs, few are completed in a given year. This prioritized list was
used to select foreign establishments for inspection in fiscal year 2007.
According to FDA, about 30 such inspections were completed in that year and at
least 50 are targeted for inspection in fiscal year 2008.
The foreign inspection process involves unique circumstances
that are not encountered domestically. For example, FDA relies on staff that
inspect domestic establishments to volunteer for foreign inspections.

Unlike domestic inspections to monitor the quality of a
marketed drug, FDA does not arrive unannounced at a foreign establishment. It
also lacks the flexibility to easily extend foreign inspections if problems are
encountered, due to the need to adhere to an itinerary that typically involves
multiple inspections in the same country. Finally, language barriers can make
foreign inspections more difficult than domestic ones. FDA does not generally
provide translators to its inspection teams. Instead, they may have to rely on
an English-speaking representative of the foreign establishment being inspected,
rather than an independent translator.
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