A cross-sectional study of USFDA warning letters issued for cGMP violations pertaining to medical devices

Most of the prior studies concentrated on warning letters issued for clinical investigation, Institutional review board,and infringement of promotional claims, no studies assessed the warning letters issued for infringements of CurrentGood Manufacturing Practice (cGMP) pertaining to medical devices. Hence, there is a need to carry out a crosssectional study of these warning letters. Publically available U.S. Food & Drug Administration (USFDA) letters underthe law of the freedom of Information Act sent to the pharmaceutical company were accessed from the USFDA website.A standard data collection tool (Excel Spreadsheet) with all letters of warning issued from January 2008 to July 2018was developed. Letters have been manually screened. Warning letters related to medical device breaches of cGMPwere screened based on the letter's subject and content. Overall, 669 warning letters issued for medical device cGMPviolations were reviewed between January 2008 and November 2018. From 2008 to 2013, there was a downward trendin the issuance of warning letters. The number of warning letters issued in 2014 was 101, followed by 106 in 2015,as the USFDA focused more on data integrity issues, while the number decreased to 53, 27, and 19, respectively, in2016, 2017, and 2018. The highest number of warning letters were issued to manufacturers located in the USA (379),followed by Canada (52), and China (37). Section 820.30 of Title 21 CFR was found to be most violated with 603infringements. This section represents the design control requirements for cGMP. Class 2 type of medical devices werefound to be most violated (82%), followed by Class 3 with 7%. Only 32% of the companies responded to the warningletters although 52% Not Issued the closeout letter followed by 16% of the letters were considered as non-applicableletters. With the time, scientific developments and increased awareness of both regulatory authorities and industries/academic organizations, overall improvement are observed with significant decrease in the number of warning letters.

Analysis on FDA's CGMP Warning Letters of Medical Products / 中国药房

OBJECTIVE: To provide references for Chinese enterprises to grasp the trend of quality management of worldwide medical products and to improve the quality management level.METHODS: FDA's CGMP Warning Letters on medical products issued by the USA during 2002～2006 were analyzed statistically,and FDA's emphasis and intent on quality management system of medical products was discussed.RESULTS & CONCLUSIONS: The contents stated in FDA Warning Letters are of great importance for Chinese enterprises to grasp the trend of quality management of worldwide medical products and to improve the quality management level.Chinese enterprises can probe into the problems and solutions of quality management of medical products by analyzing FDA's emphasis and intent on quality management system of medical products as well as field investigation.