Warning Letters from 2012 – Q1 2014 Show FDA’s GMP Enforcement Focus Shifting Overseas; Foreign Labs Draw Particular Attention

An analysis of FDA drug GMP warning letters issued since the beginning of 2012 highlights the agency’s increasing focus on enforcement outside the US – and on laboratory practices at foreign facilities, in particular.

In 2012, for the first time, foreign warnings began outpacing those issued domestically. Between 2012 and the first quarter of 2014, 48 drug GMP warning letters were issued internationally compared to 44 in the U.S. [Editor’s Note:  At the end of the story is a chronological listing of all 92 of the drug GMP warning letters issued between the beginning of 2012 and the first quarter of 2014, categorized into U.S. and International. The key concerns that each of the warning letters address and links to the letters themselves are provided.]

The roadmap for an increased enforcement effort overseas was laid out in FDA’s “Beyond Our Borders” initiative (IPQ September 7, 2011), and given further support by the passage in mid-2012 of the FDA Safety and Innovation Act (FDASIA), and its generic drug user fee and supply chain provisions, in particular (IPQ January 23, 2014).

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