Defining Quality Metrics is No Easy Task - Pharmaceutical Technology

Latest Issue

Latest Issue
PharmTech Europe

Defining Quality Metrics is No Easy Task
ISPE and PDA take on the challenge of recommending quality metrics.

Pharmaceutical Technology
Volume 38, Issue 2, pp. 10


IVT’s 5th Annual
Validation Week EU

March 25-27, 2014
Dublin, Ireland

Brochure | Register


More in GMPs/Validation

In its Strategic Plan for Preventing and Mitigating Drug Shortages, FDA reiterated its position that shortages of drugs and biologics pose a significant public health threat and preventing drug shortages remains a top priority. The agency also identified two central goals: improving mitigation response to shortages and implementing strategies for the long-term prevention of shrotages by focusing on the root causes of shortages.

FDA cites some recent success in working with manufacturers to mitigate shortages and restore lost production. A six-fold increase in early notification of possible shortages, combined with allocation of additional FDA resources, resulted in a decrease in the number of new shortages from 251 in 2011 to 117 in 2012, FDA reports. Despite this improvement, there is still much work to be done, particularly to address manufacturing and quality issues that are the root cause of drug shortages.

FDA strategies to move toward long-term prevention include the establishment of a proposed Office of Pharmaceutical Quality within the Center for Drug Evaluation and Research (CDER) and the establishment of risk-based approaches to identify early warning signs for manufacturing and quality problems. In response to FDA calls for input on a third strategy, the broader use of manufacturing metrics to assist in the evaluation of manufacturing quality, two industry associations have offered proposals for potential metrics programs.

In December 2013, the International Society of Pharmaceutical Engineers (ISPE) released ISPE Proposals for Quality Metrics Program - Whitepaper, in which the organization proposed “an initial list of quality metrics which are reportable to FDA to support a risk-based inspection program as given in sections 704 to 706 of US Food and Drug Administration Safety Act (FDASIA) and assist industry in moving towards the ‘desired state’.”

The ISPE team, with representatives from a range of pharmaceutical organizations, identified metrics that are mostly site-based. The intention, ISPE reports, is to start with indicator metrics and consider refinement in subsequent phases to better link to FDA’s six systems used in the inspection program and to products.

The initial six metrics, all lagging indicators, are batch rejection rate, rework and reprocessing rate, confirmed out-of-specification (OOS) rate unconfirmed OOS rate, critical complaints rate, and % annual product quality reviews complete on time. ISPE also offered definitions for these metrics, suggested alternative metrics, an implementation program, and options for next steps. For more information, see

The Parenteral Drug Association (PDA) developed a “Points to Consider” document, which puts forth the current thinking of the organization’s membership. The Inside PDA column (see pages 18 and 22) details the organization’s position on metrics and its approach to developing the document. PDA recommends that FDA collect and assess both product and site quality metrics. Trend metrics collected per product include confirmed product quality complaint rate by product; batch reject rate by product; and confirmed OOS rate (drug substance and drug product) by product. Suggested trend metrics collected by site are confirmed OOS rate (drug substance and drug product) by site and batch reject rate by site.

These initial efforts of ISPE and PDA to provide some guidance to FDA should be commended. However, there is much work to be done. We will be monitoring developments in these pages and on

Rita Peters
Rita Peters

About the Author
Rita Peters is the editorial director of Pharmaceutical Technology.




blog comments powered by Disqus
LCGC E-mail Newsletters

Subscribe: Click to learn more about the newsletter
| Weekly
| Monthly
| Weekly

FDASIA was signed into law two years ago. Where has the most progress been made in implementation?
Reducing drug shortages
Breakthrough designations
Protecting the supply chain
Expedited reviews of drug submissions
More stakeholder involvement
Reducing drug shortages
Breakthrough designations
Protecting the supply chain
Expedited reviews of drug submissions
More stakeholder involvement
View Results
Eric Langerr Outsourcing Outlook Eric LangerTargeting Different Off-Shore Destinations
Cynthia Challener, PhD Ingredients Insider Cynthia ChallenerAsymmetric Synthesis Continues to Advance
Jill Wechsler Regulatory Watch Jill Wechsler Data Integrity Key to GMP Compliance
Sean Milmo European Regulatory WatchSean MilmoExtending the Scope of Pharmacovigilance Comes at a Price
From Generics to Supergenerics
CMOs and the Track-and-Trace Race: Are You Engaged Yet?
Ebola Outbreak Raises Ethical Issues
Better Comms Means a Fitter Future for Pharma, Part 2: Realizing the Benefits of Unified Communications
Better Comms Means a Fitter Future for Pharma, Part 1: Challenges and Changes
Source: Pharmaceutical Technology,
Click here