PME
PME
PME
In this letter FDA listed four major violation of the firm. Firstly,
they failed to follow appropriate written procedures that are designed
to prevent microbiological contamination of drug products purporting
to be sterile. According to FDA the firm cannot validate their process
and the claim that it achieves “sterilization” as they cannot implement
adequate microbial control for povidone-iodine drug products, which
should be sterile. The process of sterility relies on (b)(4) which is used
as a biological indicator organism as it is found to be less resistant
than organisms routinely found in the manufacturing environment,
such as Bacillus licheniformis, but they failed to characterize the anti-
microbial effects on (b)(4), which assess biological indicator organism
suitability. Further, after repeated warning about the spore-forming
microorganisms found in sterility test since at least 2012, found in
sterility test, they failed to prevent the recurrence of these
contamination incidents. They assured the FDA about the quality
control and wanted a 14 to 18 months’ time period for revalidation but
failed to give any fruitful result.
They also failed to test numerous product lots for sterility using
USP <71> or an equivalent method and instead used a surrogate
sterility test that lacks a representative sample of the batch and is
insufficiently sensitive. Neither they have a classified area for the
manufacturing of povidone-iodine drug product that purport to be
sterile, nor they have any separate or defined areas which are
necessary to prevent contamination or mix-ups. This level of
monitoring is insufficient to protect the drug and its packaging
components during production, even to evaluate whether the
manufacturing environment is in control. For instance, the (b)
(4) samples collected in March 2015 by FDA were identified
as Bacillus species, which are spore-forming bacteria.