Learn about U.S. FDA Pre-Approval Inspections (PAI) and how to prepare for your onsite inspection. It is important to understand Pre-Approval Inspections during your drug development and planning process. If you understand what the U.S. FDA will be looking for during a PAI, then you can prepare and organize your data in advance. Having a successful inspection requires planning and good communication throughout the organization.
We always say that the worst thing you can do is to let an inspection happen to you. A Pre-Approval Inspection is not just time taken out of your day, or a speed bump on the way to regulatory approval. A Pre-Approval Inspection is your firm’s opportunity to put your best foot forward and clearly demonstrate to the U.S. FDA that you know what you are doing, your application is accurate, and you are ready for commercial manufacturing. This is the opportunity to demonstrate that you (as a firm) have a clear understanding of your process and the associated risks. At the conclusion of your inspection, you want the FDA inspectors leaving your site with their questions answered, and with a high degree of confidence in your product/process. If there are any questions regarding safety, efficacy, purity, identity, or reproducibility of your drug product you will have a difficult road to approval.
Inspectors do not work in a silo, and neither should you. The FDA field investigators, reviewers, and center liaisons (CDER, CBER, CDHR, etc.) all share information and work together. FDA Reviewers will send their questions to the FDA Field Inspectors to address with the firm. Similarly, the field inspectors will be verifying the information submitted in the firm’s filing and subsequent correspondence. One question we often receive is, “Should a firm re-evaluate its submission documents in light of a pending inspection.” The answer to this question is a resounding YES! It is strange how many companies still sequester this information and dole it out sparingly to only a few people. Employees should be aware of the submission information for their technical operation or area of expertise. For example, the purification team should be aware of relevant submission documents for purification, the process control strategy, purification specifications, process flow diagrams, etc. Subject Matter Experts (SMEs) can’t explain and defend information that is not shared, therefore limiting this information within your company is never a good strategy.
“Pre-Approval Inspection Compliance Program 7346.832, Rev. 4, eff. 5/12/2010 The Food, Drug, and Cosmetic Act provides that FDA may approve an NDA or ANDA only if the methods used in, and the facilities and controls used for, the manufacture, processing, packing, and testing of the drug are found adequate to ensure and preserve its identity, strength, quality, and purity.” §§ 505(d) and 505(j)(4)(A) (21 U.S.C. §§ 355(d)(3) and 355(j)(4)(A))
In Layman’s terms, you must be able to demonstrate to the US FDA the drug will have adequate processes and controls in place to ensure the drug’s identity, strength, quality, and purity in order to approve an NDA (New Drug Application, used for new drugs) or an ANDA (Abbreviate New Drug Application.) The way that the FDA ensures adequate controls are in place is to evaluate the methods, facilities, and controls that the firm has implemented. You will notice that the FDA chooses its’ words very carefully.
Before approval, FDA evaluates the establishment by on-site inspections and/or by establishment file review when the firm is named in the Chemistry, Manufacturing, and Controls (CMC) section of a New Drug Application (NDA), Abbreviated New Drug Application (ANDA) or Biologic License Application (BLA).
Which sites generally trigger a facility evaluation for a Pre-Approval Inspection? Facility evaluations are conducted for: Finished Dosage Manufacturers, API Manufacturers, Finished Dosage and API testing sites, Primary packaging and labeling sites, and when using animal derived APIs they may review the facility that performs the crude extraction. (Ref https://www.fda.gov/media/94064/download ). PAIs may also be conducted for excipient manufacturers (for novel or critical excipients) or intermediate manufacturers if they are critical to the quality of the drug product.
How does the FDA evaluate if a site requires a Pre-Approval Inspection? The FDA uses risk-based priority inspection criteria to make the decision to inspect a firm based on their potential Facility Risk, Product Risk, and Process Risk. The U.S. FDA uses the following criteria to determine which site to inspect for a PAI:
If the FDA determines that an inspection is needed, they will assign investigators as well as specialists such as microbiologists, chemistry experts, process development experts, formulation experts, sterility experts, etc.
A pre-approval inspection (PAI) is performed to contribute to FDA’s assurance that a manufacturing establishment named in a drug application is capable of manufacturing a drug , and that submitted data are accurate and complete . Pre-Approval Inspection Program (7346.832).
The inspection is one part of the approval process. The FDA’s lead investigator will make a formal recommendation at the end of the inspection of either Recommend Approval or Recommend Withholding of Approval . Recommend Approval indicates that the inspection found no significant issues and that the onsite inspectors have completed their review of (1) readiness to perform commercial manufacturing (2) Conformance to the application and (3) Data integrity review. The firm’s responses to any FDA observations or follow up inquiries is important. Recommend Withholding of Approval indicates that the investigators observed that the site is not GMP compliant, information in CMC is not consistent with site records, or information submitted is not accurate and complete. The firm’s response to observations is absolutely critical.
It is important to remember that CDER’s Office of New Drugs or Office of Generic Drugs makes the ultimate decision on whether to approve or withhold approval of the application or licensure. A successful onsite inspection (PAI) is just one step towards product approval.
To ensure a successful PAI inspection it is important to understand the intended purpose of the Pre-Approval Inspection (PAI) and what documentation will be requested. Manufacturers should remember to “Have A Game Plan” and “Avoid The Silo.” The recommendation from the onsite FDA investigator will confirm the site’s readiness to perform commercial manufacturing, their conformance to the application filed with the US FDA, and the integrity of the data the application relies on. For more information on US FDA Inspection Readiness contact Exemplar Compliance. email: Info@ExemplarCompliance.com
Rebecca Waterbury ChE, JD. Rebecca is a Senior Quality Consultant with Exemplar Compliance, LLC and has worked in the life science space for over 18 years. She has experience in medical devices, drug products, combination products, IVDs and biologics. She specializes in leading quality organizations and in preparing for product approval and commercialization.