February 16, 2020
The manufacture of pharmaceutical drugs is a highly complex process that involves advanced scientific analysis and instrumentation at all stages of production and storage. In order to guarantee the safety and efficacy of both human and veterinary drugs, the FDA strives to verify data integrity in all cGMP records used to document and guide the manufacturing process.
The FDA first identified failures in data governance and data integrity in the year 2000 with a warning letter issued to Schein Pharmaceuticals that cited lack of proper controls over computerized laboratory systems. In the years since, the FDA focus on compliance with data integrity regulations in facility inspections has increased significantly. We have written extensively about how the FDA defines data integrity and the current FDA regulations and guidance in this area. For more information on these subjects, see here and here and here.
Enforcement actions by the FDA due to failure to comply with data integrity regulations can result in serious financial consequences for an organization due to facility shutdown, product recalls, import and/or distribution bans, delayed or denied drug approvals, substantial remediation costs, and loss of customers due to a damaged reputation. In addition, manufacturers who are found in violation of data integrity regulations may lose the trust of the FDA and face more frequent and in-depth inspections in the future.
As such, it is critical for organizations to take appropriate steps to ensure compliance with applicable data integrity regulations governing the production of pharmaceutical drugs. In this blog, we will discuss recent trends in FDA warning letters and 483s in the pharmaceutical industry with regards to data integrity, and also highlight the importance and benefits of incorporating independent data integrity assessments into your organization’s quality management system (QMS) as part of cGMP audit programs.
FDA Form 483s and Warning Letters
The FDA conducts all inspections of regulated products, research sites and manufacturers through its Office of Regulatory Affairs (ORA). When the FDA inspects a pharmaceutical company’s facility, they can either show up unannounced or alert the company ahead of time. Once the inspection is complete, the inspectors can communicate any observed conditions and/or practices that may be in violation of FDA requirements through a Form 483 or a warning letter. While both of these documents serve to inform sponsors and principal investigators of issues that require corrective action, there are important differences in terms of the seriousness of the infraction(s) being highlighted:
FDA Form 483
An FDA Form 483 is essentially a list of identified regulatory deficiencies that an ORA inspector provides to company management at the end of an inspection. As the FDA expects that these deficiencies will be remediated, it is important to respond thoughtfully to the FDA within 15 days detailing your plan for corrective actions in order to avoid a warning letter. A Form 483 response will usually require input from many different aspects of your organization, so it should be all hands on deck upon receiving the 483 to facilitate a good response detailing a comprehensive plan of action within 15 days.
FDA Warning Letter
An FDA warning letter is issued by ORA inspectors for more serious compliance deficiencies, often involving previous Form 483s that have not been effectively remediated. Warning letters should be taken very seriously and answered in a timely fashion within the required time frame. A comprehensive remediation plan needs to be developed, implemented and adhered to, along with consistent communication with the FDA during the process to avoid further enforcement actions.
Trends in Pharmaceutical Company Form 483s and Warning Letters Citing Data Integrity Violations
The Big Data and AI Analytics firm Govzilla found that, regardless of company size, roughly 50% of all global drug 483s that have been issued over the 5 year period from 2014-2018 cite data integrity concerns. Data integrity violations are even more prevalent in warning letters, with 79% of global drug warning letters during this period citing data integrity issues. Additionally, the total number of FDA warning letters referencing data integrity deficiencies has increased significantly in recent years.
While 21 CFR Part 11 is known as the data integrity rule, deficiencies in Part 11 are rarely cited in 483s or warning letters – almost all deficiencies cited are failures to comply with cGMP predicate rules (specifically, 21 CFR Parts 210, 211 and 212). Two predicate rules that are frequently cited are Parts 211.68 and 211.194.
Part 211.68 specifies requirements for “Automatic, Mechanical and Electronic Equipment.” Common citations in this area include:
- The company did not implement effective computer system controls to ensure only authorized individuals had access to the systems.
- Access was not consistent with appropriate roles and responsibilities. For example, laboratory analysts could delete or modify data, change configuration settings (e.g., disable audit trails), could adjust date and time stamps for electronic data to falsify the date/time when data was initially acquired.
- Data was not backed up appropriately to allow data reconstruction activities in future.
- Audit trail data did not match data in printed chromatograms.
Part 211.194 is cited when companies do not review and include all relevant data when making lot release decisions. Common citations in this area include:
- Companies fail to review critical data and/or metadata that would allow them to identify out of specification (OOS) events that require investigation in lot release decisions.
- The company falsifies test results, destroys data, or does not have the data necessary to support a test result.
- Laboratory analysts reprocess or manipulate data, or delete OOS data, so the result will meet acceptance criteria.
Other recently cited deficiencies include:
- Utilizing “pre-injections” of product samples outside of full sample sets to determine if results pass acceptance criteria, and then deleting/ignoring results if they fail.
- Disabling audit trails intermittently to obscure results
- Deletions or modifications of results
- Use of integration suppression settings to minimize data that would likely cause an OOS result
- Aborting test runs with no justification
One common theme in recent warning letters to pharmaceutical companies has been the clear and consistent encouragement by the FDA to employ “independent” data integrity assessments as part of the strategy for remediating identified issues. A few examples include:
- On August 10th, 2018, a warning letter was issued to the manufacturing facility of Kyowa Hakko Bio Co., Ltd. in Japan that stated: “We recommend that a qualified third party with specific expertise in the area where potential breaches were identified should evaluate all data integrity lapses.”
- On March 26th, 2019, a warning letter was issued to the manufacturing facility of Winder Laboratories, LLC in Georgia that stated: “Your quality system does not adequately ensure the accuracy and integrity of data to support the safety, effectiveness, and quality of the drugs you manufacture…. We strongly recommend that you retain a qualified consultant to assist in your remediation.”
- On June 13th 2019, a warning letter was issued to the manufacturing facility of Akorn Inc. in Illinois that stated: “Your quality system does not adequately ensure the accuracy and integrity of data to support the safety, effectiveness, and quality of the drugs you manufacture…. We acknowledge that you are using a consultant to audit your operation and assist in meeting FDA requirements.”
Data integrity is a growing focus of the FDA, and it is therefore critical for organizations to ensure compliance with applicable data integrity regulations governing the production of pharmaceutical drugs. While this blog specifically highlights FDA trends in Form 483s and warning letters for pharmaceutical drug manufacturers, the recommendations communicated are also applicable to biotech companies, clinical research and CROs, medical device manufacturers, R&D laboratories, etc.
In order to ensure compliance, working with an external consultant that has expertise in data integrity evaluations to audit your laboratory environment is best practice, as an expert with fresh eyes will be able to effectively locate data integrity issues you missed. A data integrity assessment performed by a qualified team of regulatory experts provides a number of important benefits for your organization:
- Strengthens Your Organization’s Data Integrity Focus – Helps reinforce the fact that your organization is committed to data integrity compliance for all company employees.
- Provides Peace of Mind – You know that your data integrity issues have been identified and are being addressed.
- Reduces Costs – The cost of remediating data integrity issues identified by the FDA is generally much more significant than when the issues are proactively identified and corrected internally.
- Stay Focused on Your Core Business – Proactively identifying and correcting data integrity issues allows your organization to spend less time on compliance issues so you can stay focused on your core business.
Astrix Technology Group has an experienced team of expert informatics consultants that bring together technical, strategic, regulatory and content knowledge to provide the most effective solutions to problems faced by scientific organizations. Astrix provides experienced professionals knowledgeable about FDA regulations to conduct a thorough assessment of your laboratory informatics environment to identify data integrity risks. If you have any questions about Astrix Technology Group service offerings, or if you would like have an initial consultation with someone to explore how to reduce your compliance risk around data integrity, don’t hesitate to contact us.