WARNING LETTER
Central Admixture Pharmacy Services, Inc.
MARCS-CMS 674736 —
March 29, 2024
Delivery Method:
VIA EMAIL WITH READ RECEIPT
Product:
Drugs
Recipient:
Recipient Name
Ms. Rachel C. Schwartz
Recipient Title
Director of Pharmacy
Central Admixture Pharmacy Services, Inc.
6580 Snowdrift Road Suite 100
Allentown
,
PA
18106-9331
United States
Issuing Office:
Division of Pharmaceutical Quality Operations I
United States
WARNING LETTER
WL # 674736
March 29, 2024
Dear Ms. Schwartz:
You registered your facility with the U.S. Food and Drug Administration (FDA) as an outsourcing facility under section 503B of the Federal Food, Drug, and Cosmetic Act (FDCA) [21 U.S.C. § 353b]
1
on February 28, 2014, and most recently on November 8, 2023. From February 27, 2023, to March 30, 2023, an FDA investigator inspected your facility, CAPS Allentown, located at 6580 Snowdrift Road, Suite 100, Allentown, PA 18106. During the inspection, the investigator noted serious deficiencies in your practices for producing drug products intended or expected to be sterile, which put patients at risk.
FDA issued a Form FDA 483 to your facility on March 30, 2023. FDA acknowledges receipt of your facility’s response, dated April 20, 2023, and subsequent updates. FDA acknowledges that on April 28, 2023, your firm initiated a voluntary recall of drug products intended or expected to be sterile, within expiry, due to lack of sterility assurance. Based on this inspection, it appears you produced drugs that violate the FDCA.
A. Compounded Drug Products under the FDCA
Under section 503B(b) of the FDCA, a compounder can register as an outsourcing facility with FDA. Drug products compounded by or under the direct supervision of a licensed pharmacist in an outsourcing facility qualify for exemptions from the drug approval requirements in section 505 of the FDCA [21 U.S.C. § 355(a)], the requirement in section 502(f)(1) of the FDCA [21 U.S.C. § 352(f)(1)] that labeling bear adequate directions for use and the Drug Supply Chain Security Act requirements in section 582 of the FDCA [21 U.S.C. § 360eee-1] if the conditions in section 503B of the FDCA are met.
An outsourcing facility, which is defined in section 503B(d)(4) of the FDCA [21 U.S.C. § 353b(d)(4)], is a facility at one geographic location or address that - (i) is engaged in the compounding of sterile drugs; (ii) has elected to register as an outsourcing facility; and (iii) complies with all of the requirements of this section. Outsourcing facilities must comply with other applicable provisions of the FDCA, including section 501(a)(2)(B) [21 U.S.C. § 351(a)(2)(B)], regarding current good manufacturing practice (CGMP), and section 501(a)(2)(A) [21 U.S.C. § 351(a)(2)(A)], regarding insanitary conditions. Generally, CGMP requirements for the preparation of drug products are established in Title 21 of the Code of Federal Regulations (CFR) parts 210 and 211.
B. Violations of the FDCA
Adulterated Drug Products
The FDA investigator noted that drug products intended or expected to be sterile were prepared, packed, or held under insanitary conditions, whereby they may have become contaminated with filth or rendered injurious to health, causing your drug products to be adulterated under section 501(a)(2)(A) of the FDCA. For example, the investigator observed that you did not perform adequate product evaluation and take appropriate corrective action after microbial contamination was recovered within the ISO 5 aseptic processing area.
The FDA investigator also noted CGMP violations at your facility, that caused your drug products to be adulterated within the meaning of section 501(a)(2)(B) of the FDCA. The violations include, for example:
1. Your firm failed to thoroughly investigate any unexplained discrepancy or failure of a batch or any of its components to meet any of its specifications, whether or not the batch has already been distributed (21 CFR 211.192).
2. Your firm failed to establish laboratory controls that include scientifically sound and appropriate specifications, standards, sampling plans, and test procedures designed to assure that components, drug product containers, closures, in-process materials, labeling, and drug products conform to appropriate standards of identity, strength, quality, and purity (21 CFR 211.160(b)).
Outsourcing facilities must comply with CGMP requirements under section 501(a)(2)(B) of the FDCA. FDA’s regulations regarding CGMP requirements for the preparation of drug products have been established in 21 CFR parts 210 and 211. FDA intends to promulgate more specific CGMP regulations for outsourcing facilities. FDA has issued a revised draft guidance,
Current Good Manufacturing Practice — Guidance for Human Drug Compounding Outsourcing Facilities under Section 503B of the FD&C Act.
This draft guidance, when finalized, will describe FDA’s expectations regarding outsourcing facilities and the CGMP requirements in 21 CFR parts 210 and 211 until more specific CGMP regulations for outsourcing facilities are promulgated.
Under section 301(a) of the FDCA [21 U.S.C. § 331(a)], the introduction or delivery for introduction into interstate commerce of any drug that is adulterated is a prohibited act. Further, it is a prohibited act under section 301(k) of the FDCA [21 U.S.C. § 331(k)] to do any act with respect to a drug, if such act is done while the drug is held for sale after shipment in interstate commerce and results in the drug being adulterated.
C. Corrective Actions
We have reviewed your facility’s responses to the Form FDA 483. We acknowledge receipt of your facility’s response, dated April 20, 2023, and subsequent updates. We acknowledge that on April 28, 2023, your firm initiated a voluntary recall of all drug products intended or expected to be sterile, within expiry, due to lack of sterility assurance.
Some of your corrective actions appear deficient:
1. Your written procedure SOP-CAPS-4000582 states, “Action level results are documented using FRM-CAPS-4000302… ISO 5, ISO 7, and ISO 8 action level result investigations are further documented on RPT-CAPS-4000048 as appropriate.” This procedure does not appear to adequately ensure a thorough investigation, that includes implementation of appropriate corrective and preventive actions, will be performed each time action level microbial contamination is recovered within a classified area. In addition, in response to the microbial contamination recovered in your ISO 5 aseptic processing areas, you have not provided current environmental and personnel monitoring results of classified areas, including ISO 5 aseptic processing areas.
2. You have not further evaluated, or provided data to demonstrate, your firm’s rapid sterility test method is suitable for its intended purpose. Therefore, there is no assurance that your rapid sterility test method is able to provide valid results prior to release of each drug product lot.
In addition to the issues discussed above, you should note that CGMP requires the implementation of quality oversight and controls over the manufacture of drugs, including the safety of raw materials, materials used in drug manufacturing, and finished drug products.
See
section 501 of the FDCA. If you choose to contract with a laboratory to perform some functions required by CGMP, it is essential that you select a qualified contractor and that you maintain sufficient oversight of the contractor’s operations to ensure that it is fully CGMP compliant. Regardless of whether you rely on a contract facility, you are responsible for assuring that drugs you produce are neither adulterated nor misbranded. [See 21 CFR 210.1(b), 21 CFR 200.10(b).]
FDA strongly recommends that your management undertake a comprehensive assessment of operations, including facility design, procedures, personnel, processes, maintenance, materials, and systems. In particular, this review should assess your aseptic processing operations. A third party consultant with relevant sterile drug manufacturing expertise should assist you in conducting this comprehensive evaluation.
Repeat Violations at Multiple Sites
FDA identified similar CGMP deficiencies at other facilities in your company’s network. CAPS Phoenix and CAPS San Diego were also inspected and cited for CGMP deficiencies and insanitary conditions. These repeated failures at multiple sites demonstrate that management oversight and control over the manufacture of drugs is inadequate.
Your executive management remains responsible for fully resolving all deficiencies and ensuring ongoing CGMP compliance. You should immediately and comprehensively assess your company’s global manufacturing operations to ensure that systems, processes, and the products manufactured conform to FDA requirements.
D. Conclusion
The violations cited in this letter are not intended to be an all-inclusive statement of violations at your facility. You are responsible for investigating and determining the causes of any violations and for preventing their recurrence or the occurrence of other violations. It is your responsibility to ensure that your firm complies with all requirements of federal law, including FDA regulations.
You should take prompt action to address any violations. Failure to adequately address any violations may result in legal action without further notice, including, without limitation, seizure and injunction.
Within fifteen (15) working days of receipt of this letter, please notify this office in writing of the specific steps that you have taken to address any violations. Please include an explanation of each step being taken to prevent the recurrence of violations, as well as copies of related documentation. This letter notifies you of our concerns and provides you an opportunity to address them. If you believe your products are not in violation of the FDCA, include your reasoning and any supporting information for our consideration. If you cannot completely address this matter within fifteen (15) working days, state the reason for the delay and the time within which you will do so.
Your written notification should refer to the Warning Letter Number above #674736. Please send your electronic reply to Nancy Espinal, Compliance Officer at Nancy.Espinal@fda.hhs.gov, and ORAPHARM1_RESPONSES@fda.hhs.gov.
Sincerely,
/S/
Lisa Harlan
Program Division Director
U.S. Food and Drug Administration
OPQO Division I
cc:
Mr. Jim W. West, President (via jim.west@bbraunusa.com)
Central Admixture Pharmacy Services, Inc.
901 Marcon Blvd.
Allentown, PA 18109
___________________
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See Pub. L. No. 113-54, § 102(a), 127 Stat. 587, 587-588 (2013).
Content current as of:
05/14/2024
Regulated Product(s)
Drugs