Smoking hot filters
"At first we thought we had found the smoking gun (pun intended), but the filter contact materials were no different than what we had used in many other products and processes. Something else was going on, and we couldn't figure it out."Working closely with the filter manufacturer, we found the problem was the filter assembly and manufacturing process. This meant that we would have to test each lot of filters with our product to be sure the same problem didn't continue. What a pain! And we still had to reject and destroy those two lots."
Out with the old
"The marketing manager thought he could increase sales by keeping an old injectable product viable. He figured we could market it as a syringe product as well as the current vial format," our GMP Agent-in-Place explains.
"Because it was a small-volume product, the project never had a lot of activity, and the project just perked slowly along for years. When the marketing manager left the company, the new manager looked at the market and the product and asked, 'Why are we spending money on this old dog?' And he killed the project."
A diluent by any other name
"An FDA inspector noted that our sterile water-for-injection that was used as a diluent with our freeze-dried product failed to meet pH specifications during our routine stability studies," says our GMP Agent-in-Place. "We receved a 483 observation for this failure.
"When I visited the plant to help them fix the problem, I found out that the diluent was filled into Type II glass. I explained that in that type of system, the water will tend to extract ions from Type II glass, and because it isn't buffered, will readily change the pH.
"The resolution to the problem was relatively easy: We renamed the diluent as 'Sterile Diluent' rather than 'Sterile WFI,' and eliminated the pH specification after proving that the pH of the mixture of product and diluent didn't result in product pH failure."
What does corporate do anyway?
"We were undergoing a regular FDA inspection until the inspector decided to check on follow-up actions we promised because of our product recall," says our GMP Agent-in-Place. "Recalls are managed out of the corporate office, half-way across the country where the sales and marketing staff are, but the local FDA district still expects us to have all the details.
"We had committed to send out a second letter to the customers after this particular recall. The corporate quality expert said he would do it, but he never did. FDA wanted to talk to him directly and called him from my office—no warning, just a call from an inspector during an inspection! Boy was he surprised. FDA kept him on the line while files were retrieved and memories searched, still ending with a 483 observation. What does corporate quality do anyway?"
Pharmaceutical Technology's monthly "Agent-in-Place" column distills true-life cautionary tales from the secret files of Control, a senior compliance officer. If you have a story of clueless operators, oblivious management, inopportune lapses of judgment, or Murphy's Law in action, please send it to Control at [email protected]