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Special Report


                                                                          the general pool. Officials told GAO
       Investigator positions                                             that new investigators typically  need
       250
                                                                          two to three years of experience before
                                                                          they can conduct foreign inspections in-
       200
                                                                          dependently, and they must have expe-
                                                                          rience conducting foreign inspections
       150
                                                                          before they are qualifi ed for a position
       100                                                                in the foreign cadre or for an assign-
                                                                          ment as a foreign offi ce investigator. As
        50                                                                of June 2024, 36% of investigators in
                                                                          the general pool did not have the neces-
        0                                                                 sary experience to conduct independent          PRODUCT RANGE
         Nov. 2021   2022    2023  2024 (partial)  Nov. 2021   2022    2023  2024 (partial)  Nov. 2021   2022    2023  2024 (partial)
           Domestic-based General Pool  Dedicated Foreign Drug Cadre  Foreign Offi ce Investigators*  foreign inspections. Offi cials told GAO
         Fiscal year                                                      that the limited pool of qualifi ed investi-
             Vacant                                                       gators was one of the top challenges in
             Filled
                                                                          recruiting  investigators  to  fi ll  foreign
                                                                          offi ce investigator positions.
                Fig 3: FDA Drug Investigator Vacancies, November 2021 – June 2024
       Source: GAO analysis of Food and Drug Administration (FDA) workforce data. / GAO-25-106775
                                                                             Investigator  attrition has reduced
       total number of positions in the cadre  attrition, according to the GAO analysis.  the  total number of inspections FDA
       because of funding received to conduct  According to FDA data, from the start  can conduct, according to the GAO
       inspections under the unannounced in-  of fi scal year 2022 to June 2024, FDA’s  analysis.  Having a  less-experienced
       spections pilot, which were expected to  Offi ce of Regulatory Affairs (ORA) hired  investigator workforce has also reduced
       largely be conducted by cadre investi-  105 new investigators into the general  inspection  capacity. In its analysis,
       gators, according to the GAO analysis.  pool of approximately 230 authorized  GAO said that FDA offi cials noted that
                                         investigators and lost 105. Of these 105  newly hired investigators do not have
       Foreign offi ce investigators      drug investigator losses, 61% left for  the same capacity to complete inspec-
          Vacancies increased among foreign  other FDA positions, including other  tions as experienced investigators. In
       offi ce investigators, particularly in China,  positions in ORA; 29% left FDA; and  addition, experienced investigators are
       according to GAO’s analysis. FDA data  10% retired. The turnover rate for ORA  less effi cient in completing inspections
       show  that,  in November  2021,  there  investigators in the general pool was  because they are training newer staff.
       was one vacancy among six positions in  more than twice as high as the ORA-  According to GAO’s review  of FDA
       India and four vacancies among nine  wide turnover rate in fi scal years 2022  data and information, about 63% of
       positions in China. As of June 2024, four  and 2023. As of June 2024, hiring for  current investigators were hired with-
       of seven positions in India were vacant  fi scal  year  2024  has  been  greater  than  in the last fi ve years, as of May 2024.
       and seven of nine positions in China.  attrition, according to the GAO analysis.  GAO noted that in its analysis, offi cials
                                                                          stated that, even if the total number of
       Investigator attrition and impact on   High rates of attrition in the general  drug investigators  currently on board
       inspections                       pool of investigators limit FDA’s ability  was similar to past years, it is a large
          FDA  has  continued to  recruit  and  to fi ll positions in the foreign cadre and  challenge to maintain a similar number
       hire investigators, but vacancies per-  the foreign offi ces, which are fi lled by  of inspections  to previous  years with
       sist due to challenges with investigator  more experienced investigators from  so many new investigators.
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       172                                                                 Chemical Weekly  December 31, 2024


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