cover story of this issue of Pharmaceutical Technology is devoted to over-the-counter (OTC) medications—how they're regulated, and what safeguards are in place to help ensure their
quality and safety. These complex issues have been in the news quite a bit lately. Consumer confidence has been shaken by
multiple recalls of common products. The US Pharmacopeial Convention (USP) plays a specific role in ensuring the quality of
OTC drugs by setting standards for drug formulators and manufacturers in the US Pharmacopeia–National Formulary (USP–NF). The adulteration and misbranding provisions of the 1938 Food, Drug, and Cosmetic Act establish USP–NF in US law and are enforceable by FDA.
USP cannot create and update standards—whether written monographs or physical reference materials—without a close partnership
with industry as well as FDA. Currently, USP is working on an ambitious project that it started more than a year ago to update
key monographs to incorporate modern analytical methods and technologies. FDA has provided valuable guidance to this project
by identifying priority monographs, based on exposure to the population and relative risk of quality concerns (e.g., inadvertent
contamination or economically motivated adulteration). The Consumer Healthcare Products Association (CHPA) is also collaborating
on the project. Most of the priority monographs are used for nonprescription products, although some (e.g., acetaminophen
with codine) are prescription as well. CHPA's participation in the effort highlights the unique collaboration taking place
in industry to ensure the quality of OTC medications for the marketplace.
FDA Commissioner Margaret Hamburg exressed support for USP's standards modernization project during her remarks at the USP
Convention meeting in April 2010. She cited the effort as one of the most pressing tasks facing USP and FDA given the disturbingly
frequent incidents of poor-quality products in the OTC and prescription arenas.
The project thus far has involved identifying and prioritizing a master list of existing monograph procedures of interest
as candidates for modernization. A list of the top 300 (200 are for drug substances, 100 are for excipients) monographs selected
for modernization was posted on the USP website in February 2011. Of the initial list of monograph candidates, about 25%
are OTC-related. It is important to note that the same product or ingredient can be OTC, for example, in low doses, and available
as a prescription at high doses or in a different dosage form.
USP has begun to seek external (primarily from industry) and internal support (primarily from USP laboratories around the
world) for the project. The convention is focusing on: replacing outdated technology and methodology with current procedures;
adding critical tests to monographs (e.g., for impurities); and deleting tests that are no longer relevant, such as those
for odor or melting point. A primary challenge is obtaining the best procedures and acceptance criteria from the manufacturing
community. To address this challenge, USP has launched several outreach programs, including a public webinar.
USP has traditionally relied on donated procedures with supporting documentation from industry as the primary basis for its
standards. The proposals are put through USP's rigorous, public, and transparent vetting process, involving many volunteer
experts who evaluate the standards and seek input from industry, regulators, and other interested stakeholders. The resulting
public standards (as compared with a manufacturer's private specifications, which are a component of the drug-approval process
for new drug and biologics license applications) are beneficial to the donor and the public in following ways:
- Public standards level the playing field for buyers and sellers by helping to establish the identity and quality of medicines
- A public standard defines an "article of commerce" and is accessible to everyone
- USP monographs provide a legal standard of quality for the United States and international markets
- USP monographs help ensure product quality across manufacturers, contributing to public confidence in the medicine supply.