FDA commissioner Andrew von Eschenbach's solution is the high profile "Beyond our Borders Initiative," which is establishing
on-the-ground regulatory offices in critical parts of the world. The first in-country operation will be in China, with offices
in Beijing, Shanghai, and Guangzhou by year's end. A relatively small staff of 13 will conduct some site inspections, but
they will work primarily with Chinese regulatory authorities to better track local enforcement activities, become more informed
of legal and political issues affecting drug regulation, and further acquaint Chinese regulators and manufacturers with US
drug quality standards and clinical research requirements. An additional $20 million from the June supplemental appropriation
will enable FDA to establish the Chinese offices, plus operations in India, Europe, and Latin America by the end of next year;
a Middle East office in Amman, Jordan may follow.
Establishing official foreign operations takes time and patience. In December 2007, FDA signed a Memoranda of Agreement (MOA)
with the Chinese to improve the safety of drugs and medical devices. It calls for registration of Chinese firms exporting
to the US, enhanced drug tracking by Chinese authorities, and FDA notification of inspection failures involving plants that
export to the US. The State Department approved the assignment of FDA staffers to Chinese offices in March, but a final agreement
was delayed by a request from the Chinese for a similar presence in the US, which the State Department has yet to approve.
In addition, FDA will be sending more inspectors to foreign plants and research sites in the coming year. FDA conducted 322
foreign inspections in fiscal year 2007—a big jump up from 212 in FY 2006, and 260 in 2004. The plan is to carry out 500 foreign
inspections in 2009. Most of these visits involve pre-approval inspections that are required for every new plant listed on
market applications or supplements before a new product can be distributed in the US.
FDA also aims to boost routine inspections of overseas manufacturers, implementing a risk-based approach for scheduling site
visits: At the top of the list will be facilities producing higher risk dosage forms, without an inspection in the last three
years, with high shipping volumes, and with a history of past compliance issues with either FDA or local regulators. The agency
is establishing an international cadre of inspectors to conduct site visits around the world, and to be ready to conduct "for
cause" inspections when problems emerge about the safety of a regulated product.
Internal IT modernization may further help FDA cope with the globalization of the pharmaceutical supply chain with its ever-growing
number of brokers, traders, distributors, repackagers, and manufacturers. A top priority is to build an interoperable electronic
data system for facility registration and product listing that can identify more accurately who manufactures which products,
and what is being distributed in the US.
Because FDA will never have enough resources to inspect all facilities frequently enough to catch all safety and quality problems,
FDA officials seek to leverage resources and reduce redundant oversight activities through collaborative initiatives with
» Sharing foreign inspection reports FDA has more than 70 cooperative arrangements with foreign counterparts that permit mutual access to certain manufacturing
information. Some 30 confidentiality agreements allow FDA to share actual inspection reports, which provide information on
foreign facilities that can help target foreign inspection activities.
» Joint inspection pilot FDA is teaming up with the European Medicines Agency (EMEA) and Australia's Therapeutic Goods Administration to consult on
inspection schedules and reports, initially for API manufacturers in China and India. The aim is to avoid redundant site visits
and to cover more facilities. The three agencies will review which facilities are on each other's lists and agree on which
agency should go in first. In some important cases, all three regulators may visit a certain plant together. If successful,
the program could expand from APIs to drug products.
» Third party certification FDA wants to accredit more government and independent entities as capable of verifying company or product compliance with
US safety standards. Drug import legislation could support these efforts, but there is skepticism on Capitol Hill about this
approach because such programs for medical devices have not been very successful.
Even with more information sharing and joint inspections, neither FDA, EMEA, nor other regulatory authorities are ceding the
right to evaluate and make independent enforcement decisions regarding any drug product or facility. The hope is that these
collaborations will breed confidence in the approaches and decisions of colleagues, explained EMEA head of inspections Emer
Cooke at the DIA meeting. Cooke anticipates that such joint efforts eventually will lead to increased reliance on each other's
Jill Wechsler is Pharmaceutical Executive's Washington correspondent. She can be reached at firstname.lastname@example.org