After Heparin: - The Pew Charitable Trusts
After Heparin: - The Pew Charitable Trusts
After Heparin: - The Pew Charitable Trusts
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INTRODUCTION AND BACKGROUND<br />
<strong>The</strong> heparin tragedy may have been preceded by warning signs that could have suggested a heightened<br />
risk of economically motivated adulteration. <strong>The</strong> OSCS entered the supply chain at a time when a widespread<br />
swine virus outbreak had greatly diminished Chinese pig herds. 86 <strong>The</strong> price of pigs increased in<br />
2007, 87 and the cost of pure heparin as well as heparin crude increased more than 100 percent between<br />
May and November 2007 (see figure 4). According to an expert in the pharmaceutical chemical industry,<br />
an alert purchasing department might have identified the price increase as a signal of potential risk<br />
to the product. 88 A shortage of raw ingredient provides a motivation for deliberate substitutions of<br />
cheaper materials.<br />
Figure 4<br />
Monthly Chinese export prices for crude and refined heparin, 2006 and<br />
2007<br />
3000 $/KG<br />
2500<br />
2000<br />
Crude heparin 2006<br />
Crude heparin 2007<br />
Refined heparin 2006<br />
Refined heparin 2007<br />
1500<br />
1000<br />
500<br />
0<br />
JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC<br />
Source: Beijing Orientbit Technology Co., Ltd. 89<br />
Baxter reports that it has instituted a number of initiatives to secure its supply chain against future adulteration.<br />
It is examining its global supply chain practices to identify vulnerabilities, reviewing relationships<br />
with high-risk suppliers, reducing the number of suppliers, doing more concentrated audits and<br />
reviewing test methods. 90 Baxter does not sell heparin vial products today, although it continues to sell<br />
other heparin products, none of which is produced using the supplier implicated in the recalls. 91<br />
As FDA Commissioner Margaret Hamburg has noted, “In this day and age, companies must be able to<br />
effectively demonstrate that safety, quality and compliance with international and U.S. standards are<br />
built into every component of every product and every step of the production process.” 92 <strong>Heparin</strong>’s<br />
complex supply chain was vulnerable to abuse by perpetrators that have not been identified and therefore<br />
never penalized, and Baxter failed to prevent a serious adulteration of its product. Chapter 1 reviews<br />
issues of outsourcing, globalization and supplier management.<br />
20<br />
<strong>Pew</strong> Health Group