USP: New General Chapter Supplier Qualification <1083>
On August 01, 2023, the new USP Chapter "<1083> Supplier Qualification" will officially enter into force. In the USP Forum, the draft chapter could be viewed and commented on until the end of November 2021.
Is a Pharmacy allowed to sell Pharmaceuticals on Amazon?
The German Federal Court of Justice (BGH) has submitted questions to the Court of Justice of the European Union (ECJ) on the permissibility of selling pharmaceuticals via Amazon. Specifically, the issue is whether a pharmacist who sells pharmaceuticals on an Internet sales platform is in breach of the data protection provisions applicable to health data. In addition to the data protection aspects (DSGVO), the two underlying legal disputes also concern provisions of the German Medicines Act (AMG), the German Drug Advertising Act (HWG), the Pharmacy Operations Regulation (ApBetrO) and the Professional Code of Conduct for Pharmacists.
Qualification of Customers - What needs to be considered?
According to the EU GDP Guidelines, wholesale distributors must ensure they supply medicinal products only to persons who are themselves in possession of a wholesale distribution authorisation or who are authorised or entitled to supply medicinal products to the public. But what is the rationale for this point and how are the requirements to be implemented?
GDP in the US: Consent Decree of Permanent Injunction against Importer and Distributor of APIs
A federal court has entered a consent decree of permanent injunction against a Florida-based drug importer and distributor. It prohibits the company from distributing active pharmaceutical ingredients (APIs) not manufactured, processed, or held in compliance with the Federal Food, Drug, and Cosmetic Act (FD&C Act). This was preceded by a legal dispute with the U.S. Food and Drug Administration (FDA).
USP pre-posts Revision to General Chapter <1079.2> and Stimuli Article on Mean Kinetic Temperature (MKT)
The United States Pharmacopeia (USP) has published a Notice of Intent to Revise General Chapter <1079.2> Mean Kinetic Temperature in the Evaluation of Temperature Excursions During Storage and Transportation of Drug Products. With the revision, the inclusion of temperature excursion limits for climatic zone IVb is being proposed. In a Stimuli Article, the rationale for the revision is outlined. Both documents were now pre-posted, to allow stakeholders additional time for reading and understanding.
Is it acceptable that storage conditions are not monitored for medicinal products which do not have any predefined storage conditions on the outer packaging? This is one of three new questions answered by the European Medicines Agency (EMA) on its website. The other two questions relate to the activities of brokers with parties outside the EEA.
FDA Warning Letter due to Inadequate Storage Conditions and Repacking/Relabeling Operations
The U.S. Food and Drug Administration (FDA) has published a Warning Letter to a drug repackaging and relabeling facility located in Pennsylvania. The document summarizes significant deviations from current Good Manufacturing Practice (CGMP) for Active Pharmaceutical Ingredients (APIs). It also addresses Good Distribution Practice (GDP) aspects.
GDP in the US: FDA warns Company for Violation of Drug Supply Chain Security Act
The U.S. Food and Drug Administration (FDA) has published a so-called untitled letter to a US company. The FDA states that the firm violated the Drug Supply Chain Security Act (DSCSA). Specifically, the letter concerns a former subsidiary of the company that was a licensed pharmacy and wholesale drug distributor.
The GDP Non-Compliance Reports of 2022 - An Overview
If the outcome of an inspection is that the wholesale distributor does not comply with Good Distribution Practice (GDP), a statement of non-compliance may be entered into EudraGMDP. We have prepared an overview of the GDP Non-Compliance Reports published in 2022 and the respective reasons for issuing these reports.
GDP Non-Compliance Report: Numerous Major GDP Violations at Irish Wholesale Distributor
The Irish Health Products Regulatory Authority has added a new GDP Non-Compliance Report to the EudraGMDP database. During an inspection of a wholesale distributor, a number of major deviations from Good Distribution Practice were found, leading to an immediate suspension of the authorisation.
Any change from design or predefined processes requires risk assessment and potential impact evaluation for both the transport process and, consequently, the product. This article discusses the importance of having a structured, compliant Change Control (CC) process in place for medicinal product manufacturers as well as for their qualified logistics vendors.
Qualification of Suppliers - What needs to be considered?
According to the EU GDP Guidelines, wholesale distributors must obtain their supplies of medicinal products only from persons who themselves hold a wholesale distribution authorisation or a manufacturing authorisation which covers the product in question. Thus, all suppliers must be qualified in an adequate way. But what is the rationale for this point and how to implement the requirements?
The U.S. Food and Drug Administration (FDA) has issued Warning Letters to Amazon and Walmart. Laboratory analyses showed that both companies sold products that contained diclofenac, which was not listed on the product labels. The FDA sees this as a potential health risk for consumers.
GDP for Veterinary Medicinal Products: EMA updates Q&A Document
The European Medicines Agency (EMA) has updated the answers to frequently asked questions on Good Manufacturing Practice (GMP) and Good Distribution Practice (GDP) on its website. The newly inserted section revolves around the requirement relating to the nature of check at the reception of veterinary medicinal products before being transferred to saleable stock.