USP stepped up to the plate there, and tried to help assure the quality, given the fact FDA hadn't finalized their GMPs yet.
We call that our Dietary Supplement Verification Program (see "Some Bark, Little Bite").
Some Bark, Little Bite
Where else is USP asserting its influence?
USP had its origins in compounding. And I've even heard people say that manufacturing may change so it becomes more like compounding,
so that people can get the right dose at the right dose frequency. Or complex new biologics are going to be assembled at the
bedside before delivery.
We want to reach back to compounding practitioners and the community pharmacists through our Pharmacists' Pharmacopeia, which
was a line extension, as we call it, of USP-NF. [An official publication, issued by USP, that gives the composition, description, method of preparation, and dosage for
drugs. The book contains two separate official compendia—the USP and the National Formulary.] We have to be very careful in
those line extensions that we preserve our status as having two of the three official compendia of the United States: The
only one we don't have is the American Homeopathic Pharmacopeia. The other two are National Formulary and United States Pharmacopeia.
FDA is obviously going through some problems. What is USP's role in resolving some of the issues that have been raised about
drug safety and oversight.
I go back to that point of independent testing. Let's say Company X has a problem with their potency or their strength. Well,
you don't want FDA to have to knock on their door and say, "May we use your reference standards to test the quality of your
products?" I'm a strong advocate for FDA to be able to test independently.
Where do you get your reference standards?
We get what we call candidate bulk materials from all over the world—pioneers, generics, chemical supply houses. At the end
of the day, however, we think of them as unknown things that we then move through a very careful process to establish a public
That process involves us checking chemically to make sure we know exactly what we've got, sending it out for collaborative
testing so that everybody can do an additional check against us, and then packaging and making it available for sale one lot
at a time so that all the manufacturers throughout the world can test to a single standard.
That's the value of the "one-lot" concept. When that one lot goes down, we replace it with another lot. If you think about
it, it's not the way pharmaceutical manufacturing works. There can be a multiple of lots, even from one manufacturer. And
when you get to generic substitution, there could be scores of lots in the marketplace at any one time. But they all should
be testing to this single standard.
It's a very nifty system if you think about it. And as much as I like PAT [process analytical technology]—I'm very supportive
of the science in back of PAT—it makes me nervous when they don't talk about end-product testing. Because if you don't do
end-product testing to a single reference point, pretty soon you start losing that link between all lots and all manufacturers.
But who would argue with better quality by design? In my mind, those are things people should be doing anyway without the
sort of cheerleading aspect of it.
Some people would say FDA doesn't need to cheerlead, it needs to get out of the way.