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Special Report                                                                   Special Report



   Drugs shortages once again in the spotlight in the US  manent  discontinuances and interrup-  advanced pharmaceutical quality  input from 23 individuals/entities. The
       tions in manufacturing and FDA’s own  systems; technical excellence; and  feedback  will  assist CDER in further
       actions are helping to reduce the threat  employee  engagement and empower-  developing its QMM program.
 n June this year, the FDA published   to increases in demand, according   PATRICIA VAN ARNUM  and impact of drug shortages. In 2023,  ment. The paper provided examples of
 its annual report to Congress   to FDA’s report(1). Manufacturers   Editorial Director, (DCAT)  FDA said it worked with manufacturers  elements within each practice area that   In addition, in April 2023, FDA
 Idetailing the level of drug short-  are now not required to notify FDA   to successfully avoid a large number of  may be considered during an assess-  issued a draft guidance document,
 ages and efforts the agency is taking   about shortages related to increases  Low prices: Drug products, commonly   drug shortages, helping to prevent 236  ment.  Notifying FDA of a Discontinuance or
 to mitigate them. In 2023, 55 new drug   in demand, and FDA is seeking new  older generics, with low prices have a   shortages. For a comparison to recent   Interruption in Manufacturing of
 shortages were identifi ed by the FDA.   authority to require notifi cation from  higher risk of drug shortage  years, FDA helped prevent 317 short-  FDA also  participated in a peer-  Finished Products or  Active Pharmaceu-
 What products and areas  were most   manufacturers related to product   USP’s analysis shows that in 2023,   ages in 2021 and 222 in 2022.  reviewed  journal  article(3),  published  tical Ingredients Under Section 506C of
 prevalent and  what is  the impact on   demand – related drug shortages. FDA  product discontinuation increased by   in  January  2023,  that  shared  lessons  the FD&C Act, to assist applicants and
 drug manufacturers?  has put forth legislative proposals in  40%  in  one  year,  from  100  drug  pro-  FDA pointed to actions that it took  learned from two QMM pilot programs  manufacturers in providing FDA timely
 its  fi scal  year  2025  proposed  budget  ducts in 2022 to 140 in 2023, suggesting   in  2023  to  address  and  prevent  drug  conducted  with separate  contractors  and informative notifications about
 Tracking drug shortages  that would include authorities  tightening margins forced manufactu-  shortages, including among other  to assess the QMM of drug manufac-  changes in the production  of certain
 During calendar year 2023, 55 new   intended to promote the agency’s  rers to tap out of the market. The report   things, incentivize drug manufacturing  turers. One pilot program evaluated  fi nished drugs, biological products, and
 drug  shortages  were  identifi ed  by  the   response efforts, such as requirements  also showed that the average price of   establishments’ use of quality manage-  seven establishments located within the  certain APIs that may, in turn, help the
 US Food and Drug  Administration’s   for manufacturers to notify FDA of  sterile injectable medicines in shortage   ment maturity (QMM) practices. FDA’s  US that produce fi nished dosage form  agency prevent and mitigate drug short-
 (FDA) Center  for Drug Evaluation   an increase in demand that the manu-  was nearly 8.5 times lower than those   QMM program aims to encourage manu-  products marketed in the US. A second  ages. A revision of the draft guidance
 and Research (CDER) and Center for   facturer likely will be unable to meet  not in shortage.  facturers of CDER – regulated drugs to  pilot program evaluated eight establish-  document was issued in February 2024.
 Biologics Evaluation  and Research   without meaningful shortfall or   implement quality management prac-  ments located outside the US that
 (CBER), according to a recent FDA   delay and to provide manufacturing  Manufacturing complexity: Drugs   tices that go beyond current good manu-  produce  APIs  used in drug products  REFERENCES
 report on drug shortages(1). Although   volume and supplier information. If  with higher manufacturing complexity,   facturing practice (cGMP) to support a  marketed in the US.  1.  US Food and Drug Administration,
 the number of new drug shortages has   enacted, FDA says these proposals  such as sterile injectables, are more   more reliable drug supply chain.  Report to Congress: Drug Shortages
 declined since a peak high reached in   would greatly enhance its ongoing  vulnerable to shortage  In addition, following the commit-  CY 2023, June 2024.
 2011,  when  251  new  drug  shortages   work to address potential drug short-  Manufacturing complexity can also   Among  the actions taken by  FDA  ment made at FDA’s Pharmaceutical  2.  US Food and Drug Administration,
 were reported, drug shortages continue   ages.  be seen in certain therapeutic  classes,   in  2023  relating  to  QMM  include  the  Science and Clinical Pharmaco-  “CDER’s Quality Management
 to be a problem. The 55 new shortages   such as certain antibiotics needing dedi-  publishing of a white paper on QMM,  logy Advisory Committee in November   Maturity (QMM) Program: Practice
 in 2023 were an increase over the 49   In a separate analysis, the U.S.  cated facilities – and in certain active   CDER’s Quality Management Maturity  2022,  CDER  engaged  with  over  10   Areas and Prototype  Assessment
 new  drug  shortages  reported  in  2022   Pharmacopeia (USP), an independent  ingredients that require complex chemi-  (QMM)  Program: Practice  Areas and  stakeholder  groups  in  2023  through   Protocol Development.”
 and the 41 new drug shortages reported   scientific  organization, released  its  cal synthesis.  Prototype  Assessment Protocol Deve-  facilitated  discussions to solicit  their  3.  J. Maguire  et al., “Lessons from
 in 2021.  inaugural Drug Shortage Report in June   lopment(2). The paper introduced fi ve  input  on  the  perceived  benefi ts  of  the   CDER’s Quality Management
 2024,  which  encompasses  trends  up  Geographic concentration  practice areas in the prototype assess-  QMM program. FDA’s CDER also   Maturity Pilot Programs,” The AAPS
 Although there has been a levelling   to  the  end  of  2023  in  the  US.  The   Drugs in which the active pharma-  ment protocol: management  commit-  established  a  public  docket  (September   Journal,  January  10,  2023,  doi:
 off  of  new  shortages  over  the  past   report showed that shortages are lasting  ceutical  ingredient  (API)  and/or  fi ni-  ment  to quality; business continuity;  15 to December 14, 2023) that garnered   10.1208/s12248-022-00777-z.
 decade, 2023 has been a challenging year   longer – the average drug shortage  shed dose are made in a single or few
 for shortages. One data point of note is   lasts for over three years compared to  locations are more susceptible to   Target Your Market More Effectively
 the number of ongoing shortages yet to   about two years in 2020 – and impact  shortage.  IndiaChemTrade
 be resolved from previous years. As of   a wide range of therapeutic classes.   Free for subscribers of Chemical Weekly
 December  31,  2023,  FDA  had  identi-  More  than  half,  53%,  of  new  drug  Quality concerns  IndiaChemTrade provides consolidated trade statistics of India. The information provided here is based on
 fi ed  98  ongoing  CDER-and  CBER-  shortages were generic sterile inject-  Quality-related issues  that  surface   the annual trade data published by the Directorate General of Commercial Intelligence and Statistics,
 tracked  shortages,  which  included  94   able medicines.  in regulatory  agency  inspection  out-  Government  of  India. The  database  can  be  searched  by:  Chemical  Name/Harmonised  Code  to  obtain  the
 drug shortages identifi ed by CDER and   comes and manufacturer recalls can   consolidated trade (import or export) in that item; or by Country to obtain the trade (import or export) in all chemicals
 four by CBER.  Through  its  USP’s  Medicine  Sup-  also inform drug shortage risk but must   and related products between India and that country.
 ply Map, a tool that identifi es, charac-  be used  along with other information
 Although the majority of drug   terizes, and predicts risk in the supply  to be meaningful.  ChemXchange
 shortages have historically been   chain, the report highlights four factors   Open to all – no subscription required
 linked to quality and GMP is-  that singularly, or in combination, can  Impact on drug manufacturers  ChemXchange – the chemical exchange with a difference – is where you can identify your buyers and
 sues,  in  2023,  drug  shortages  also   leave a drug more vulnerable to short-  In its report, FDA says that based on   supplyers on-line, any time. Listing in this unique platform is free to all advertisers in the print version of Chemi-
 occurred as a result  of  increased   age: low prices, manufacturing  com-  its experience and its data on drug short-  cal Weekly for a period of 12 months.
 demand. More than half of the short-  plexity, geographic concentration, and  ages it believes that  the requirements   For more information contact: 022-24044471 / 72
 ages seen in 2023 were due, in part,   quality concerns.  related to the early notifi cation of per-  Email: corporate@chemicalweekly.com or log on to chemicalweekly.com


 172  Chemical Weekly  July 16, 2024  Chemical Weekly  July 16, 2024                                   173


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