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After Heparin: - The Pew Charitable Trusts

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PHARMACEUTICAL MANUFACTURING: GLOBALIZATION AND QUALITY MANAGEMENT<br />

Ranbaxy is not the only large Indian company to be placed on import alert by the FDA. In June<br />

2010, an intravenous antibiotic product manufactured by Claris Lifesciences Limited, in India, was<br />

discovered to be nonsterile (which can cause infections) and to contain floating white particles,<br />

identified in at least one case as mold. 184 Three intravenous antibiotic products were then recalled<br />

by Claris and by three companies that sold the drugs in the United States under their labels through<br />

licensing agreements: Pfizer Inc., Sagent Pharmaceuticals and West-Ward Pharmaceuticals. 185,186<br />

In November 2010, the FDA placed Claris Lifesciences under import alert, preventing its products<br />

from entering the United States. 187<br />

1.3.2 Drug ingredient quality issues resulting from deceptive practices<br />

In emerging economies, highly competitive markets and lower regulatory enforcement may combine<br />

to encourage deliberate circumvention of costly quality regulations and certifications. Such deceptions<br />

have affected the U.S. drug supply (see case studies 1, 3, 4). <strong>The</strong> FDA has uncovered falsification of<br />

data several times in recent years. In a January 2010 warning letter, the FDA claimed that employees at<br />

XiAn Libang Pharmaceutical Co., Ltd., in Shaanxi Province, China, were manipulating testing data. 188<br />

<strong>The</strong> agency informed the API manufacturing plant that it would not consider new marketing applications<br />

until the observed violations were sufficiently addressed. 189 In February 2010, Indian manufacturer<br />

Glochem was found to have falsified batch-manufacturing records for clopidogrel, an antiplatelet<br />

medicine. E.U. inspectors discovered at least 70 batch-manufacturing records in the plant’s waste yard.<br />

All of the records had been re-written, and in some cases original entries had been changed. 190 And as<br />

discussed, in 2008, the FDA cited Indian manufacturer Ranbaxy Laboratories Limited for a number of<br />

U.S. GMP violations, including alleged falsification of stability testing records. 191<br />

Noncompliant drug-ingredient manufacturers may hide uncertified materials or production sites by<br />

physically concealing these factory rooms or warehouses (see figure 10) or through misrepresentations<br />

in documentation and packaging. One auditor in China suggested that some manufacturers claim<br />

regulatory certifications they do not possess. 192 Such deceptions may permit unqualified manufacturers<br />

to gain business inappropriately, and may mislead regulators and industry efforts to assess quality and<br />

safety standards.<br />

Another documented misrepresentation is the relabeling of materials produced at unknown or unapproved<br />

sites (see case studies 3 and 4). Such falsification poses risks to patients because neither the<br />

purchaser nor regulators can ensure a product’s quality without knowing the conditions of its manufacture<br />

(which is why the FDA requires manufacturing sites to be listed in a drug’s marketing application).<br />

While testing may ultimately show some improperly sourced materials to be safe, their untracked and<br />

unvalidated origins could conceal substandard material or poor production.<br />

Economic motivation often drives these behaviors. Drug-ingredient suppliers may bring in additional<br />

material from unreported sources to meet growing product demand, as was the case for Biochimica<br />

<strong>After</strong> <strong>Heparin</strong>: PRotecting Consumers from the Risks of Substandard and Counterfeit Drugs 29

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